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New Climate Reality is Passing New York By

Note: For quite a while now I have put my Citizens Guide to the Climate Act article as the top post on the website because it summarizes the Climate Leadership & Community Protection Act (Climate Act). This post updates my current thoughts about the Climate Act and will replaces that post at the top of the list of articles on October 2, 2023

There is a new climate reality and it is passing New York by.  New York decision makers are going to have to address the new reality that proves that the Hochul Administration’s Scoping Plan to implement the Climate Act will adversely affect affordability, reliability, and the environment.  This post highlights articles by others that address my concerns.

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 have major unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act 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. 

Climate Science

In the past several weeks there have been multiple articles highlighting issues that call into question the rationale for the Climate Act and Climate Act net-zero transition.   The rationale for the Climate Act is that there is an existential threat due to climate change.  However, the Epoch Times reports that is not a universally held position:

There’s no climate emergency. And the alarmist messaging pushed by global elites is purely political. That’s what 1,609 scientists and informed professionals stated when they signed the Global Climate Intelligence Group’s “World Climate Declaration.”

The article gives a good overview of the World Climate Declaration.  The declaration’s signatories include Nobel laureates, theoretical physicists, meteorologists, professors, and environmental scientists worldwide. The article quotes a few signatories who when asked by The Epoch Times why they signed the declaration stating that the “climate emergency” is a farce, they all stated a variation of “because it’s true.” 

In my case, I signed the Declaration because I do not think we understand natural climate variability well enough to be able to detect the effect of a relatively small change to the atmosphere’s radiative budget caused by mankind’s greenhouse gas (GHG) emissions.  There are so many poorly understood factors at play and the mathematical challenges of simulating the chaotic, non-linear processes are so immense that I think that claiming that Global Climate Models can simulate the atmosphere well enough to make major changes to the energy system of the world is absurd.

There is another important aspect.  One of the key points made in the Declaration is that climate science is overly politicized:

“Climate science should be less political, while climate policies should be more scientific,” the declaration begins. “Scientists should openly address uncertainties and exaggerations in their predictions of global warming, while politicians should dispassionately count the real costs as well as the imagined benefits of their policy measures.”

It seems to me that every day there is another mass media story attributing any extreme weather event to climate change and insinuating that the “science” has unequivocally shown that there is a link to mankind’s GHG emissions has made the weather more extreme.  The fact is that the latest research and the Intergovernmental Panel on Climate Change are finding that as Roger Pielke, Jr. explains the “projected climate futures have become radically less dire”.  He argues that the consensus has accepted a large change in expected warming due to a doubling of GHG emissions — from 4oC to 2.5oC or less.   Pielke notes that he has documented this trend  for years and has “been talking about the incredible shift in expectations for the future” recently.  Unfortunately he also notes: “Despite the growing recognition that our collective views of the future have changed quickly and dramatically, this change in perspective — a positive and encouraging one at that — has yet to feature in policy, media or scientific discussions of climate.”   He concludes “That silence can’t last, as reality is persistent.”

Affordability

I think this is the one issue that might force political change to the Climate Act net-zero transition.  A coalition of business organizations have called for a “reassessment” of how the Climate Act is being implemented highlighting current policies to determine “what is feasible, what is affordable and what is best for the future of the state.”  In response, Department of Environmental Conservation Commissioner Basil Seggos told Capital Tonight that “the costs of inaction are much higher.”  He goes on: “Listen, we know from two years of very intensive research that the cost of inaction on climate in New York far exceeds the cost of action by the tune of over $100 billion”. I disagree.

The Scoping Plan that documents this claim by Seggos has been described as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”.  No where is this more evident than in the tortuous documentation for this cost claim.  I documented the issues with costs and benefits in my  comments (social cost of carbon benefits, Scoping Plan benefits, and electric system costs).  In brief, the Hochul Administration has never provided concise documentation that includes the costs, expected emission reductions and assumptions used for the control strategies included in the Integration Analysis documentation making it impossible to verify their assumptions and cost estimates. 

The claim that the costs of inaction are more than the costs of action compares real costs to New Yorkers relative to societal benefits that can be charitably described as “biased high” or more appropriately “cherry picked” to maximize alleged benefits and, more importantly, do not directly offset consumer costs.  The benefits claimed are also poorly documented, misleading and the largest benefit is dependent upon an incorrect application of the value of carbon.  The plan claims $235 billion societal benefits for avoided greenhouse gas emissions.  I estimate those benefits should only be $60 billion.  The Scoping Plan gets the higher benefit by counting benefits multiple times.  If I lost 10 pounds five years ago, I cannot say I lost 50 pounds but that is what the plan says.  The cost benefit methodology was duplicitous because the cost comparisons were relative only to Climate Act requirements that did not include “already implemented” programs.  For example, this approach excludes the costs to transition to electric vehicles because that was a requirement mandated before the Climate Act.  I maintain that the total costs to transition to net-zero should be provided because that ultimately represents total consumer costs.  

It is also frustrating that the State ignores that other jurisdictions are finding costs are an issue.  In a recent article I noted that the Prime Minister of Great Britain, Rishi Sunak, said he would spare the public the “unacceptable costs” of net zero as he scaled back a string of flagship environmental policies. The fact is that every jurisdiction that has tried to transition away from fossil-fueled energy has seen a significant increase in consumer costs.  For example, Net Zero Watch recently published a report that describes six ways renewables increase electricity bills that makes that inevitable.   The article explains:

In order to reduce bills, a new generator generally has to force an old one to leave the electricity market — otherwise there are two sets of costs to cover. But with wind power, you can’t let anything leave the market, because one day there might be no wind.

The article goes on to explain that as well as adding excess capacity to the grid, renewables also have a series of other effects, each of which will push bills up further:

Renewables need subsidies, they cause inefficiency, they require new grid balancing services that need to be paid for; the list of all the different effects is surprisingly long. There is only one way a windfarm will push your power bills, and that’s upwards.

Reliability

Another flawed aspect of the Climate Act narrative is that a transition to a zero-emissions electric system is straight-forward and there are no significant technological challenges.  Terry Etam summed up the issues evident in the German transition that will also occur in New York.  In an article about the ramifications of the energy requirements for implementing artificial intelligence applications, he argued that the fossil-fired energy growth in the developing nations has been discouraged by the G7 nations.  However, those nations are pushing back on anything that is not in their best interests.  He writes:

The second big tectonic shift was on full display at the recent G20 summit. The African Union was admitted as a member, which was kind of a big deal, particularly for Africa, but also for the world in general. The addition acknowledges that other voices need to be on the world stage, a sense of humility the G7 has long lacked. The final communique issued at the end of the G20 summit included doses of common sense lacking from typical utterances of the G7: “We affirm that no country should have to choose between fighting poverty and fighting for the planet…It is also critical to account for the short-, medium-, and long-term impact of both the physical impact of climate change and transition policies, including on growth, inflation, and unemployment.” 

Contrast that with the west’s bizarre self-lobotomization when it comes to energy, as best personified by the entity furthest along the rapid-transition path, Germany: the dwindling economic powerhouse is chained to a green freight train it insists is under control, has shut down nuclear power plants with no low-emissions baseload to replace it, and in a final stunning swan dive to the pavement, is orchestrating the installation of 500,000 heat pumps per year to the grid, which will be in most demand in cold weather and will perform worst in cold weather, and will add a potential 10 gigawatts of cold-weather demand at the very instant the grid is least able to afford it, and for which there is no supply available anyway. A German energy economic university think tank says the additional cold-weather demand could only be met by new gas-fired power plants, which are not being built. In sum: Germany has shuttered its cleanest, most reliable energy; it has or is trying to banish hydrocarbons and replace them with intermittent power; and finally, is hastening adoption of devices that will function very well in 80 percent of conditions when it doesn’t matter much but will fail in a spectacularly deadly way at the point in time when they are needed the very most, because heat pumps will be turned up to 11 at the very time the grid will be the most taxed. German engineering isn’t what it used to be.

In the last several years I have concluded that intermittency of wind and solar is the fatal flaw for that technology.  The most important consideration is the need for energy storage.  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.”  This report suffers from the same problems afflicting the Climate Act Scoping Plan.  Menton explains:

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.

I believe that the insurmountable problem with energy storage backup for wind and solar is worst-case extremes.  The Royal Society report notes that “it would be prudent to add contingency against prolonged periods of very low supply”.  This contingency is the theoretical dispatchable emissions-free resource that the Integration Analysis, New York State Independent System Operator, New York State Reliability Council, and Public Service Commission in the Order Initiating Process Regarding Zero Emissions Target in Case 15-E-0302 all acknowledge is necessary.  Incredibly, the loudest voices on the Climate Action Council clung to the dogmatic position that no new technology like this resource was necessary and excluded any consideration of a backup plan to address the contingency that a not yet commercialized technology might never become commercially viable and affordable.

If New York State were to embrace nuclear energy, then there might be a chance to significantly reduce GHG emissions without affecting reliability.  Instead, the Scoping Plan placeholder option for this resource is green hydrogen.  Menton describes the hydrogen option proposal in the Royal Society report:

Since hydrogen is the one and only possible solution to the storage problem, the authors proceed to a lengthy consideration of what the future wind/solar/hydrogen electricity system will look like. There will be massive electrolyzers to get hydrogen from the sea. Salt deposits will be chemically dissolved to create vast underground caverns to store the hydrogen. Hydrogen will be transported to these vast caverns and stored there for years and decades, then transported to power plants to burn when needed. A fleet of power plants will burn the hydrogen when called upon to do so, although admittedly they may be idle most of the time, maybe even 90% of the time; but for a pinch, there must be sufficient thermal hydrogen-burning plants to supply the whole of peak demand when needed.

The Scoping Plan proposal is slightly different.  It envisions that the electrolyzers will be powered by wind and solar to create so-called “green” hydrogen.  Menton and I agree that the biggest unknown is the cost.  He raises the following cost issues:

  • How about the new network of pipelines to transport the hydrogen all over the place?
  • How about the entire new fleet of thermal power plants, capable of burning 100% hydrogen, and sufficient to meet 100% of peak demand when it’s night and the wind isn’t blowing.
  • They use a 5% interest rate for capital costs. That’s too low by at least half — should be 10% or more.
  • And can they really build all the wind turbines and solar panels and electrolyzers they are talking about at the prices they are projecting?

It gets worse in New York.  Ideologues on the Climate Action Council have taken the position that “zero-emissions” means no emissions of any kind.  They propose to use the hydrogen in fuel cells rather than combustion turbines because combustion turbines would emit nitrogen oxides emissions.  This adds another unproven “at the scale necessary” technology making it even less likely to succeed as well as adding another unknown cost.  In addition, it ignores that there are emissions associated with the so-called zero-emissions technologies that they espouse.  All they are advocating is moving the emissions elsewhere.

Environmental Impacts

I addressed the implications that the Scoping Plan only considers environmental impacts of fossil fueled energy in my Draft Scoping Plan Comments.  The life-cycle and upstream emissions and impacts are addressed but no impacts of the proposed “zero-emissions” resources or other energy storage technology are considered.  The fact is that there are significant environmental, economic, and social justice impacts associated with the production of those technologies. Furthermore, the most recent cumulative environmental impact analysis only considered a fraction of the total number of wind turbines and area covered by solar PV installations proposed in the Scoping Plan.  As a result, the ecological impacts on the immense area of impacted land and water have not been adequately addressed.

One of the more frustrating aspects of the Hochul Administration’s Climate Act implementation is the lack of a plan.  For example, consider utility-scale solar development.  There are no responsible solar siting requirements in place so solar developers routinely exceed the Department of Agriculture and Markets guidelines for protection of prime farmlands.  My solar development scorecard found that prime farmland comprises 21% of the project area of 18 approved utility-scale solar project permit applications which is double the Ag and Markets guideline. 

I am particularly concerned about environmental impacts associated with Off Shore Wind (OSW).  This will be a major renewable resource in the proposed Climate Act net-zero 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.  I summarized several OSW issues in a recent article that highlighted an article by Craig Rucker titled Offshore Wind Power Isn’t ‘Clean and Green,’ and It Doesn’t Cut CO2 Emissions.  He explains:

A single 12 MW (megawatts) offshore wind turbine is taller than the Washington Monument, weighs around 4,000 tons, and requires mining and processing millions of tons of iron, copper, aluminum, rare earths and other ores, with much of the work done in Africa and China using fossil fuels and near slave labor.

Relying on wind just to provide electricity to power New York state on a hot summer day would require 30,000 megawatts. That means 2,500 Haliade-X 12 MW offshore turbines and all the materials that go into them. Powering the entire U.S. would require a 100 times more than that. 

These numbers are huge, but the situation is actually much worse.

This is because offshore turbines generate less than 40% of their “rated capacity.” Why? Because often there’s no wind at all for hours or days at a time. This requires a lot of extra capacity, which means a lot more windmills will have to be erected to charge millions of huge batteries, to ensure stable, reliable electricity supplies.

Once constructed, those turbines would hardly be earth or human friendly, either. They would severely impact aviation, shipping, fishing, submarines, and whales. They are hardly benign power sources.

The environmental impacts on whales of the OSW resources necessary to meet the net-zero transition are especially alarming.  Earlier this year I described the Citizens Campaign for the Environment virtual forum entitled Whale Tales and Whale Facts.  The sponsors wanted the public to hear the story that there was no evidence that site survey work was the cause of recent whale deaths.  I concluded that the ultimate problem with the forum was that they ignored the fact that construction noises will be substantially different than the ongoing site surveys and will probably be much more extensive when the massive planned construction starts.  The virtual forum noted a lack of funding for continued monitoring necessary to address the many concerns with massive offshore wind development to allay the concerns of the public.   Since then, the Save Right Whales Coalition (SRWC) has found issues with the incidental harassment of whales associated with the noise levels associated sonar surveys done in conjunction with OSW development.  I am very disappointed that the Hochul Administration is not investing in an adequate monitoring program that confirms that whales are not being harmed. 

Conclusion

This article was intended to summarize my current concerns about the impacts of the Climate Act transition on affordability, reliability, and the environment.  There is a growing realization that the alleged problem of global warming is not as big a threat as commonly assumed. Combined with the fact that 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 the rationale for doing anything is weak.  It may not mean that we should not do something, but clearly we have time to address the affordability, reliability and environmental impact issues.

The Scoping Plan has not provided comprehensive and transparent cost estimates so New Yorkers have no idea what this will cost.  I explained why the Hochul Administration claim that the costs of inaction are more than the costs of action is misleading and inaccurate.  I believe that all New Yorkers should let it be known that they need to know the expected costs so they can determine if they support the transition.

When the energy system becomes all-electric the reliability of the electric system will be even more critical than today.  The State plan is to proceed as if there are no implementation issues.  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.  There is no sign that is being considered.

It is particularly galling that organizations who claim to be in favor of a better environment have failed to support comprehensive cumulative environmental impact assessment and on-going impact monitoring assessment to potential impacts from wind, solar, and energy storage development on the scale necessary for the net-zero transition.  Maybe they don’t want to know that the concerns are real.

Mark Twain said: “It is easier to fool someone than it is to tell them they have been fooled.”    The politicians who support the Climate Act net-zero transition have been fooled into thinking it is affordable, will not affect reliability, and benefits the environment.  Unfortunately, it is very difficult to slow down, much less stop the unfolding train wreck of these policies.  I encourage readers to keep asking for a full cost accounting of all the proposed programs as the most obvious concern.

Status Update on New York Wind and Solar Capacity Factors

Last year I published an article describing the New York Independent System Operator (NYISO) Load & Capacity Data Report (also known as the “Gold Book”) and how I used it.  This post uses the latest edition to determine the wind and solar capacity factors last year.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions 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 (CAC) was responsible for preparing the Scoping Plan that outlined 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  That process is falling behind as the enormity of the challenge becomes clearer.

Capacity Factor

The capacity factor is a useful metric to understand electric generation resources.  The annual capacity factor for a generator equals the actual observed generation (MWh) divided by maximum possible generation (capacity in MW times the hours in a year).  Projections for the amount of future wind and solar generation capacity needed for the Climate Act depend on capacity factor assumptions.

Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  Worse, there has not been any indication that the Scoping Plan is being refined to incorporate the lessons learned in the years since it was drafted or address any of the issues u raised in the comments.  The capacity factor assumptions are a prime example of an issue that needs to be addressed.

Wind and Solar Capacity Factor Projections

I have previously summarized future resource projections. The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook is part of the NYISO Comprehensive System Planning Process.  That analysis included several scenarios for the future grid that includes capacity factor projections.  The Integration Analysis also included several scenarios and capacity factor projections.  In both instances the capacity factor projections determine how much wind and solar capacity will be needed in the future.

I am not the only one who submitted comments about the Scoping Plan capacity factors.  I pointed out that the Integration Analysis land-based wind capacity factors were unrealistically high.  The model projected the 2020 generation with a capacity factor of 29% but the 2021 observed capacity factor was only 22%.  The Integration Analysis model could not even get the starting year correct.  As a result, the Integration Analysis projections for the land-based wind capacity needed to meet the load are too low.  It is particularly disturbing that the State has never attempted to reconcile the NYISO projections and assumptions with the Integration Analysis.  For all renewable resources the Integration Analysis capacity factors are higher than the NYISO projections as shown below.

2023 Wind and Solar Observed Capacity Factors

The New York Independent System Operator (NYISO) 2024 Load & Capacity Data Report (also known as the “Gold Book”) is now available and has been posted on the NYISO website: 2024 Load & Capacity Data Report (Gold Book).  Many of the most useful tables are also provided as spreadsheets.  The following supplemental materials have also been posted:

The Existing Generating Facilities spreadsheet was used to calculate New York capacity factors.  The first table sums the capacities and net energy for all the combinations of primary fuel type and secondary fuel type for all the generators tracked by the NYISO.  This includes units that are in the market system as well as others that are not.  The nameplate capacity of generating units that use natural gas and can also burn number 2 fuel oil is the largest category in the state.

2024 NYISO Gold Book Tables III – 2a NYISO Market Generators and Table III – 2b Non-Market Generators 2023 Capacity, Energy, and Capacity Factors

The next table lists the capacity data and net energy produced for the wind generating units in New York.  Using that data, it is possible to calculate the capacity factors for each facility.  The NYISO Resource Outlook and the Integration Analysis both assume a 34% capacity factor in 2030.  Only two wind farms exceeded 34% and there were only three more that were over 30% capacity of the 31 wind farms in New York.  The overall capacity factor was 21.8%.  In order to achieve the assumed capacity factor for 2030 most of the existing wind farms will have to be replaced.  The Integration Analysis does not retire any of the existing wind farms which I suspect is so that the cost estimate does not have to include those costs.

I have been tracking the wind farm capacity factors since 2006 as shown in the next table.  There is nothing to suggest that 2023 was an abnormal year.  In order to meet the 2030 projections these wind farms are going to have to be replaced or a large number of wind farms with much higher capacity factors that will bring the average up will have to be built.  The data shown are also interesting as they show large interannual variation by site and the state overall.  Finally note that the NYISO wind capacity factor for 2019 was modeled as 25% but the observed capacity factor was  22.3%.  The Integration Analysis did not get their first year correct either.  It modeled the 2020 capacity factor as 29% but the observed capacity factor was only 23.9%.

New York State Wind Facility Capacity Factors Based on NYISO “Gold Book” Load & Capacity Data Reports Table III-1

There is much less historical information available for solar facilities so only the 2023 data are presented.  In 2023 the capacity factor of the solar facilities in New York was 16.8%, the highest capacity factor was 21.7% and the lowest credible capacity factor was 14.9%. The NYISO assumed a capacity factor of 15% from 2019  to 2040.  On the other hand, the Integration Analysis assumed a capacity factor of 17% in 2020 increasing to 20% by 2030. 

Discussion

The NYISO has interesting generation resource information available in its Gold Book.  As shown here, that information can be used to calculate the capacity factors for wind and solar resources in New York.  The annual capacity factors observed are consistently lower than the values used in the Integration Analysis which is being used to implement the state plan to meet the Climate Act mandates.  As a result, The Scoping Plan is underpredicting the wind and solar resources necessary to generate the energy they project will be needed. That also means that their cost projections are too low.

It is troubling that the differences shown here between the NYISO capacity factors and the Integration Analysis capacity factors have not been reconciled.  Worse, none of the differences between the two sets of projected resource projections have been addressed.  This matters not only because the differences affect the projected outcomes and the costs, but also because Integration Analysis projections are being used for the New York Cap-and-Invest (NYCI) Program proposal.  A key component of the NYCI plan is the trajectory for allowance allocations.  NYCI’s reduction trajectory is based on the Integration Analysis and the overly optimistic capacity factors used means that they are projecting lower emissions than is likely to occur.  That imbalance could have significant consequences to the allowance market.

One other point is that these are annual metrics.  In order to assure that the electric grid will be able to provide energy when it is needed the most the NYISO must deal with resource availability over shorter periods.  Think of it as the capacity factor over the coldest week of the year.  That is a much more difficult issue and one that the Scoping Plan has not addressed.

Conclusion

This post documents the most recent wind and solar capacity factors observed in New York.  It is notable that the wind data show a lot of interannual variation that should be considered when projecting future resource availability.  These data have not been incorporated into an updated analysis of the generating resources needed to achieve the Climate Act goals. 

I have long argued that the State’s plans for implementing the Climate Act mandates must include a feasibility study that could address the observed variability and lower capacity factors.  Given the tremendous uncertainties like these shown here, I have recently decided that a feasibility study is not enough.  No jurisdiction anywhere has successfully demonstrated an electric grid that depends on wind and solar to the extent that the Scoping Plan does.  Before New York goes any further it should prove it can be done with a demonstration project.  Anything less risks catastrophic blackouts and enormous costs.

GAO Information on Peaking Power Plants

Note: This is a version with NY specific information of a post that appeared at Watts Up With That. Tom Shepstone at the Energy Security and Freedom Substack summarized this detailed post.

Environmental Justice (EJ) advocates like the PEAK coalition argue that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.”   This post critiques a recent General Accounting Office (GAO) report on “Information from Peak Demand Power Plants” that was prepared in response to a question about pollution from these facilities by some congressional representatives.

This topic is a particular concern of mine because issues associated with peaking power plants have been one of my responsibilities since 2000.  Initially, my concerns were associated with developing an emissions tracking system to ensure compliance with air quality requirements for peaking plants.  Later I participated in the regulatory process to develop regulations to reduce their emissions but also keep the lights on, keep the costs down, and achieve improved air quality. It took many years but New York State developed a rule that fulfilled those requirements.  I doubt that I am the only one who participated in that process who was taken aback when environmental advocacy groups started campaigning against the power plants covered by the regulations put in place to address the peaking power plant pollution.


Further information on peaking power plants is available on a page that documents my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career. 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.

Introduction

The GAO website summary for the report explains why they did the study:

Environmental advocacy groups, and some congressional leaders have expressed concerns that peakers may be less efficient than non-peakers, meaning peakers may expend more energy that is not converted into electricity than other types of plants. Further, due to the nature of their operations, peakers may also negatively affect the air quality in communities around the plants, which may be historically disadvantaged or disproportionately low-income.

GAO was asked to examine pollution from peakers across the nation. This report provides information on the number and location of peakers in the U.S., their proximity to historically disadvantaged or disproportionately low-income communities, to what extent they emit pollutants and how these pollutants affect the health of people exposed, and alternatives for replacing them. To perform this work, GAO analyzed data from EPA, the U.S. Department of Energy, and other sources, reviewed relevant literature, and interviewed federal officials and stakeholders from 19 state, industry, and nongovernmental organizations representing a diversity of perspectives about peakers.

I am unimpressed with this report.  It is not clear to me whether the political implications of this topic or the naivete of the authors was the reason for the poor quality.  Whatever the reason, the report confirmed the biased concerns of environmental advocacy groups without addressing the fundamental problematic issues associated with peaking power.  It is especially galling that the report ignored air quality protections already in place.

Peaking Power Problem

I think the GAO report missed the opportunity to highlight the implications of peak power demand and how it could and should be addressed.  An Ozone Transport Commission presentation of issues associated with High Energy Demand Days (HEDD) from 2006 describes the tradeoffs.  Air quality and energy planning both prioritize energy demand peaks because the highest electric demand and worst air quality tend to coincide.  This is because the meteorological conditions that cause peak loads also exacerbate the air quality impacts of the increased emissions needed to match peak loads.  Reliably meeting the peaks results in using the dirtiest and most expensive units.  The key energy considerations slide describes the issues.

The GAO report overlooked this aspect of the peaking power plant issue.  Instead, when they explained why this issue matters, they only talked about daily peaks.  I think that devalues the criticality of the peak issue.  The real problem is that peak loads occur when customers need power the most.  If it is unavailable, then immediate acute safety and health problems occur. While the daily peak is a problem it is far less impactful than the annual peak load.

GAO Report

The GAO report determined how many peakers are in the country and where they are located.  This discussion failed to discuss another impactful nuance.  The GAO analysis determined the number of peaking power plants as a function of how much power plants ran in 2021:

For the purpose of our report, we generally define peakers as plants that use fossil fuels, including natural gas, coal, and oil; have a capacity factor (the percent of energy produced over a certain time frame, out of what could have been produced at continuous full power operation) of 15 percent or less; and have a nameplate capacity (the designed full-load sustained output of a facility) of greater than 10 megawatts (MW) of electricity.

This is a similar methodology to that used by Physicians, Scientists, and Engineers (PSE) for Healthy Energy in their report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  There is an unrecognized shortcoming to the approach.  The GAO report states that “Peakers are used to supplement other types of power plants, such as baseload plants, which run consistently throughout the day and night, and intermediate plants, which run mostly during the day and less at night”.  There is a difference between power plants designed to meet peaking applications and many facilities that now operate as intermediate or peaking units.  For example, around 1970 Consolidated Edison of New York needed peaking capacity within New York City that would only run infrequently but also needed to startup quickly.  They responded by building a fleet of around 100 simple-cycle natural gas turbines that were the cheapest capacity available.  Today many of the units that meet the GAO definition were originally designed as base-load units and cannot start up quickly.  I used to work at the Oswego Harbor generating station that had two 850 MW oil-fired units and took over a day to startup.  The units have met the capacity factor criteria for peaking units for years, but they were not designed to operate that way. 

The GAO report includes a map of plant locations but there is no capability to identify the plants on the map. If you are interested in specific facilities, the EPA Power Plants and Neighboring Communities website presents that information.  The GAO summary lists 999 peaking power plants in the following table.  The overall capacity factor of these plants is 6%. 

The GAO analysis determined how closely peakers are located to historically disadvantaged and low- income communities.  This analysis, the Physicians, Scientists, and Engineers, and even the draft New York regulations to address these facilities all use distance between the disadvantaged communities and the power plant as the metric of concern.  The GAO claims that “For example, based on our model and main definition of a peaker, a community that is 71 percent historically disadvantaged is expected to be 9 percent closer to the nearest peaker than the average community, which is 40 percent historically disadvantaged.” 

I do not think this is an unexpected result, but I also think it is meaningless.  The air quality impacts of any facility do not depend entirely upon distance between the source and a receptor location.  The stack characteristics (gas temperature, height of the stack, and stack exit dimensions) as week as meteorological conditions (wind direction, wind speed, and atmospheric stability) all affect air quality impacts.  The Con Ed turbines had exit ducts that released the pollutants that were less than 100 feet and the location of maximum downwind impact was relatively close.  On the other hand, the Oswego plant had 700’ stacks and the location of maximum downwind impact was quite a way from the plant.

The GAO report addressed the impact of emissions and the resulting health impacts: “When operating, peakers emit similar types of pollutants to other power plants that also use fossil fuels, and these pollutants are associated with various negative health effects, according to existing literature.”  The impacts section notes:

Compared to non-peakers, peakers emitted more pollutants—such as nitrogen oxides and sulfur dioxide—per unit of electricity generated, but fewer total annual pollutants in 2021, according to our analysis of EPA data (see table 2). In other words, peakers emit less in total because there are fewer peakers and they operate less frequently overall than non-peakers. However, when they do operate, they emit more pollution per unit of electricity produced. For example, the median sulfur dioxide emission rate for natural gas fueled peakers was 1.6 times more per unit of electricity generated than the median emission rate for non-peakers.

This language parrots the talking points of EJ advocates but is much ado about nothing.  It is obvious that fewer peakers that run less would have lower emissions than more numerous non-peakers that run more.  Advocates harp on the fact that emission rates are higher for peakers than non-peakers.  Highlighting the finding that “natural gas fueled peakers was 1.6 times more per unit of electricity generated than the median emission rate for non-peakers” is a naïve point because 0.008 versus 0.005 lb SO2 per MWhr is negligible for air quality impacts.  Moreover, I think there is an error in the methodology because the sulfur content in fuel determines the emissions not how it is burned, so there should be no difference in the rates.

Another issue I have with this analysis and other similar analyses is that they don’t recognize that the primary air quality issue with peaking power plants is ozone.  These units operate when energy demand is highest in the summer and those periods are typically hazy, hot, and humid.  Those conditions are conducive to the highest ozone levels (some of the haze) and there has been immense pressure to reduce their emissions to reduce ozone levels.  Ozone is a secondary pollutant produced in a photo-chemical reaction from nitrogen oxides and volatile organic compounds.  The conversion to ozone takes time and means that by the time it occurs the emissions from a power plant in a disadvantaged community have moved downwind.  For example, the location of highest downwind conditions for emissions from New York City is in Connecticut, far beyond neighboring disadvantaged communities.  Moreover the reality is that nitrogen oxides scavenge ozone so that the peaking power plants actually reduce ozone concentrations close to the facility.

I have been involved with air quality issues since I started working in 1976.  The fundamental presumption has always been that the National Ambient Air Quality Standards (NAAQS) is the health metric used to determine health impacts.  EPA explains:

The Clean Air Act, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for six principal pollutants (“criteria” air pollutants) which can be harmful to public health and the environment. The Clean Air Act identifies two types of national ambient air quality standards. Primary standards provide public health protection, including protecting the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.

As an air pollution meteorologist one of my jobs was to run air quality models to determine the air quality impacts of existing and proposed facilities.  The primary consideration was whether the modeling proved that the projected impacts were less than the NAAQS.  The basis of my work was that when I showed compliance with those standards, I proved that we were protecting the health of “sensitive” populations such as asthmatics, children, and the elderly.  Regulatory agencies are required to ensure that any facility that cannot show compliance with the NAAQS must to modify its permitted operations or it cannot be allowed to operate. 

The GAO report does not mention the NAAQS protections.  Instead, the analysts follow the lead of EJ activists and claim that there are health effects from peaking power plants.  The health effects section states: “Multiple pollutants that are emitted from peakers and other plants are associated with various negative health effects for the people exposed, according to federal agency reports we reviewed”.  What they reviewed were the EPA Integrated Science Assessments:

EPA’s Integrated Science Assessments integrate information on criteria pollutant exposures and health effects from controlled human exposure, epidemiologic, and toxicological studies to form conclusions about the causal nature of relationships between exposure and health effects. For more information, see the EPA Preamble for Integrated Science Assessments at Preamble To The Integrated Science Assessments (ISA) | ISA: Integrated Science Assessments | Environmental Assessment | US EPA (accessed 8/30/2023). 

The presumption in the report is that any level of pollution is bad: “For instance, short-term exposure to sulfur dioxide—the indicator for sulfur oxides used in EPA’s assessments—can lead to negative respiratory effects, such as decreased lung function, cough, chest tightness, and throat irritation.”  The GAO report summarizes health effects from short-term exposures.  All this is nice but it ignores the NAAQS process to determine acceptable ambient air quality levels.

The EJ activists pushing the negative impacts of the peaking power plants presume that there are alternatives.  The GAO report looked at some available alternatives that could potentially replace fossil-fueled peakers at the same high-level used throughout the analysis.  The report claims that “alternatives such as battery storage systems could potentially replace fossil-fueled peakers, according to studies we reviewed and stakeholders we interviewed”.   The report lists battery storage, pumped-hydro storage, thermal energy storage, and notes that renewable energy systems (e.g., wind and solar) may be paired with energy storage.  It claims that “adding roof-top solar and battery storage to houses could reduce the demand for peakers in adjacent areas.”  It includes two other possibilities:

Transmission and distribution infrastructure improvements: Upgrades or expansions to increase the capacity of current infrastructure that transmits and distributes electricity.  These upgrades or expansions may help enable existing underutilized plants to meet peak demand.

Efforts to decrease consumers’ use of power during peak times: Efforts to incentivize consumers to reduce or shift electricity use during times of peak use to off-peak times.

To its credit the report does address the “potential challenges of replacing peakers” including cost, reliability, and location.  In my opinion, the responses downplayed those challenges.

The report notes that “some alternatives may have higher capital and operating costs compared to current fossil-fueled peakers”:

Replacing peakers, some of which have already paid off their capital costs, will likely lead to additional up-front or operating costs compared to keeping the existing peakers. Further, the U.S. Energy Information Administration (EIA) reported that solar and wind plants had higher average construction costs compared to natural gas-fired plants in 2023.

It is remarkable that this Federal report documented that construction costs of solar and wind are greater than natural gas plants but there is a missing nuance.  While I am not an economist, I still question what kind of business model could justify developing a new resource that will operate as a peaking facility running less than 15 percent of the time.  Surely the facility will have to charge very high rates when it does operate.

Appropriately the report notes that “current alternatives may not be able to provide the same reliability of current fossil-fueled peakers”:

Similarly, some alternatives may create reliability challenges. For the grid to be reliable, the energy resources in an area need to be able to supply power to meet peak demand for as long as it lasts, according to U.S. Department of Energy (DOE) officials. Some battery storage systems provide up to 4 hours of output, but peak demand may be longer in some areas. In contrast, a fossil-fueled peaker is only limited by fuel availability—a natural gas-fueled peaker could keep operating so long as natural gas is available.

This is an important point universally ignored by the activists that want to shut down peaking power plants now.  The other nuance is that the overly broad definition of a peaking power plant covers facilities that provide different services than just peaking support.  The 1700 MW at Oswego Harbor are within ten miles of three nuclear units.  Nuclear units are required to shutdown when the grid goes down and in the 2003 blackout Oswego Harbor came on line to replace those units until the grid stabilized.

The GAO report also noted that “alternatives may not be able to be installed because of space and location concerns”:

Some alternatives may also run into space constraints or location concerns. For example, a densely populated urban community likely would not have sufficient space for a large renewable energy system paired with battery storage to help meet peak electricity demand.

I agree with this point, but it could have been expanded.  Location matters within the grid.  The transmission system is designed based on the location of the generating resources.  The requirement that energy must be available at the location of the New York City peaking power plants is not acknowledged by the EJ activists, but it is a critical reliability constraint.

Most disappointing to me is that the report does not acknowledge the following challenges to the end of the main report.  I believe that at least a hint of the following information should have been right up front:

In general, recognizing these challenges, some officials with whom we spoke identified trends that may lead to the continued use of fossil-fueled peakers. According to DOE officials, some U.S. peakers may not be able to be replaced with existing alternatives within cost, reliability, and location constraints.

Combinations of electricity generation and storage technologies, transmission and distribution improvements, and efforts to decrease consumer’s use of power during peak times may be too costly for consumers in some areas to provide an adequate level of grid reliability. Further, officials at two utilities noted that due to increased use of intermittent renewable resources on the grid (e.g., wind and solar power), the continued use of peakers to meet electricity demand may be necessary to maintain grid reliability. For example, the availability of sunlight for a solar installation may not match with peak demand in the evening when the sun goes down. Therefore, additional supplemental energy resources would be needed to fill the gaps and meet demand.

It gets worse.  Buried in the technical appendix the last sentence in the last paragraph before the end notes is the caveat that there is no basis for concern (my highlight):

Limitations. We took several steps to assess the validity and sensitivity of our models, but certain limitations remain. Importantly, our measure of distance does not include other aspects—such as stack height, wind speed, or wind direction— that play important roles in the dispersion of pollutants and potential populations exposure. In addition, although we include some variables to control for factors that could influence the findings, it is possible that other controls might be important and were not accounted for in our model. Inclusion of a state fixed- effect partially addresses this by controlling for factors that vary by state. Still, our findings of associations between distance to peakers and historically disadvantaged racial and ethnic communities does not imply any causal relationships.

NY Peaker Rule

The New York Independent System Operator (NYISO) 2020 Reliability Needs Assessment includes a detailed summary of the New York Department of Environmental Conservation (DEC) “Peaker Rule”: Ozone Season Oxides of Nitrogen (NOx) Emission Limits for Simple Cycle and Regenerative Combustion Turbines.  This rule exemplifies how these units should be regulated to reduce emissions while maintaining reliability standards.   

After years of discussion DEC issued requirements to reduce emissions of ozone-forming pollutants from

peaking generation units in late 2019.  The rule was implemented as part of the state’s attainment planning requirements to achieve the ozone NAAQS.  The focus of the rule was on units designed to provide peaking power, the combustion turbines known as “peakers”.  NYISO explained that:

That peakers typically operate to maintain bulk power system reliability during the most stressful operating conditions, such as periods of peak electricity demand. In addition, these units are often called upon at any time, seven days a week and 24 hours a day, to be able to respond to contingencies or other near real time changes on the electric system. By being available on call, the peakers provide value to system reliability even when not actually generating power. 

Many of these units also maintain transmission security by supplying energy within certain areas of New York City and Long Island — known as load pockets. Load pockets represent transmission-constrained geographic areas where electrical demand can only be served by local generators due to transmission limitations during certain operational conditions.

The Peaker Rule phased in compliance for approximately 3,300 MW of simple-cycle turbines located mainly in the lower Hudson Valley, New York City and Long Island. The owners of the units were required to submit compliance plans to the DEC in March 2020 to either install pollution control equipment or retire the units over a phase in period.  The NYISO resource adequacy planning process determined whether unit retirements would adversely affect reliability.   The NYISO Reliability Needs Assessment indicated that “approximately 1,800 MW of nameplate capacity (approximately 1,500 MW of net operating capability) are proposed to ultimately be unavailable during the summer to comply with the emissions requirements “.

One of the important features of the rules is a provision to allow an affected generator to continue to operate up to two years, with a possible further two-year extension, after the compliance deadline if the generator is designated by the NYISO or the local transmission owner as needed to resolve a reliability need until a permanent solution is in place.  Earlier this year this provision was involved for a couple of facilities.

I think this is the appropriate way to deal with these facilities.  Keep in mind that if these facilities had been shown to contribute directly to a local non-attainment issue modifications to their permits would have been required in a different process.

Lastly, in my opinion, this rule and the New York City peaking power plant replacement issue is an artifact of New York electric system deregulation.  Prior to deregulation, when DEC identified the problem the utilities owning the peakers would have proposed either installing control equipment or replacing the units themselves with modern clean and more efficient turbines.  The Department of Public Service would have reviewed the proposal with the DEC and eventually an approved rate case would include the proposed solution.  In the de-regulated market the owners of the facilities considered those options and in at least a couple of cases developed permits to install replacements.  However, market considerations led to the decision by the owners to go ahead with the replacements.  Without de-regulation there is no question in my mind that all of the old peaking turbines would have been replaced before 2010.  Unfortunately, it also appears that the EJ activists would still have made this an issue.

Discussion

The GAO was asked to respond to a question about pollution from peaking power plants by some congressional representatives.  The response is a disappointment.  The report summary found that:

  • Historically disadvantaged racial or ethnic communities tend to be closer to peakers.
  • Fossil-fueled peakers are primarily fueled by natural gas and emit air pollutants associated with various negative health effects, including on respiratory, cardiovascular, and nervous systems.
  • Alternatives are available that could potentially replace or provide similar services as peakers, but we identified challenges for their use related to costs, reliability, space, and location.

I do not dispute that disadvantaged racial or ethnic communities tend to be closer to peakers but the fact the “findings of associations between distance to peakers and historically disadvantaged racial and ethnic communities does not imply any causal relationships” indicates that the basis for the concerns is weak.  If the GAO report had evaluated the status of the communities of concern relative to the NAAQS or at least mentioned that there are standards designed to protect those communities, it would have been obvious that this is a non-problem conjured up by activists.

The second finding is another lost opportunity to inject reality into the conversation.  Obviously, fossil-fueled peakers emit air pollutants and they can be “associated with various negative health effects, including on respiratory, cardiovascular, and nervous systems.”  The complete disregard of the NAAQS protections in place unnecessarily scares the residents in the communities of concern. In addition, regarding emissions in isolation, focusing only on the negatives and disregarding any benefits creates an unnecessarily pessimistic outlook, hinders growth, and could lead to unintended consequences.

The final summary point begrudgingly admits that there are “costs, reliability, space, and location challenges” for replacements to peaking power plants.  The GAO report should have emphasized these challenges in my opinion.  The reality is that in order to deal with peaking power plants and the net-zero ambitions we do not have the generating or transmission technologies needed. 

Conclusion

The GAO report fails to adequately address the challenges ignored by the congressional representatives who asked for the report and the EJ activists who have conjured this up as an issue.  In doing so they did a real disservice to society.  The reality is that we need peaking units and the public is protected from direct harm from these units by the NAAQS. 

It is troubling that the report does explain why the concerns are unwarranted, but the presentation hides them.  It is only possible through a complete reading of the entire report to discover contrary evidence eviscerating this as an issue. 

The bigger picture problem is the potential threat that political and activist pressure will force premature retirement of peaking power plants with a marked increase in potential reliability risks.  A blackout will have real ramifications as opposed to the over-hyped risks claimed.  I believe that if this report had emphasized the issues instead of burying them that the possibility of a rash premature retirement initiative would have been much reduced.

Articles of Note May 26, 2024

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered.   This is a summary of articles that I think would be of interest to my readers.

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

Videos

Costs of the Net-Zero Transition

National Grid announced their plans to “invest an estimated $75 billion across the company’s service territory in the UK and US over the next five years, with nearly half of the funding dedicated to US energy system improvements in Massachusetts and New York.”   Their announcement includes:

In New York, National Grid is investing around $21 billion between now and 2029. Among those investments is the Upstate Upgrade which comprises more than 70 transmission enhancement projects across Upstate New York. The portfolio of projects will transform the grid, improve reliability and resilience, and enable National Grid to deliver renewable energy to homes and businesses across the state. This investment will also generate thousands of new jobs and create additional economic growth, all while ensuring the grid is able to meet the growing demand for electricity.

In New England, our five-year investment will total roughly $14 billion.  As part of this investment, National Grid will implement innovative solutions, like smart meters, to help consumers manage energy use; build modernized energy infrastructure; construct and upgrade infrastructure to make it less susceptible to extreme weather events; and maintain and improve the quality of our existing gas and transmission assets. 

Wind Energy Follies

I had intended to link to Robert Bryce’s article on last year’s wind energy but instead I suggest you check out Ron Clutz’s summary because he has some hilarious cartoons to illustrate his summary of the article. Bryce found that “Weather-dependent generation sources are…weather dependent: Last year, despite adding 6.2 GW of new capacity, U.S. wind production dropped by 2.1%.”

Environmentalism is Dead

I admire the work of Robert Bryce.  In this post he argues that concerns for the environment that “once aimed to protect landscapes, wildlands, whales, and wildlife — has morphed into the NGO-corporate-industrial-climate complex. Rather than preserve wildlands and wildlife, today’s “green” NGOs have devolved into a sprawling network of nonprofit and for-profit groups aligned with big corporations, big banks, and big law firms” pushing “climatism and renewable energy fetishism.”  He documents the “anti-industry” industry money and finds it is a $4.7 billion-per-year business.  He concludes:

America needs a new generation of activists who want to spare nature, wildlife, and marine mammals by utilizing high-density, low-emission energy sources like natural gas and nuclear energy. We need advocates and academics who will push for a weather-resilient electric grid, not a weather-dependent one. Above all, we need true conservationists who promote a realistic view of our energy and power systems. That view will include a positive view of our place on this planet, a view that seeks to conserve natural places, not to pave them.  

EPA Clean Power Plan

Before retirement I would have been very involved in the response to these new regulations.  I am very happy that I don’t have to try to respond because this is madness.  This summary of the rule explains:

Coal and natural gas plants provide 60% of the U.S.’ affordable, reliable, and baseload power. In a time of increased electricity demand, America needs to double down on harnessing these sources—not abandon them.

The Environmental Protection Agency (EPA)’s recently finalized Clean Power Plan 2.0 (CPP) rule, however, takes the country in the wrong direction. Under this regulation, one that is arguably illegal, existing coal and new natural gas power plants will be mandated to install emissions control technologies that aren’t yet commercially viable. Plants that don’t comply risk permanent closure. This unrealistic mandate is advanced under the guise of reducing greenhouse gas emissions 90% by 2032.

If this initiative was accompanied by an announcement of a nuclear renaissance it would be one thing.  However, the worst thing about this is that the Biden Administration apparently believes that these resources can be replaced by wind and solar.  That will never work.

Net-Zero Challenges

Ed Reid describes the all-electric experiment.  He runs the numbers and finds that the costs of storage could be between 7 and 70 times the cost of wind and solar.

Climate Change Debate

Everything Climate covers both sides of the climate debate.

Another Offshore Wind Problem

Bud’s Offshore Energy describes the glauconite challenge.   When pile drivers attempt to drive the monopiles for wind turbines into sediments with the mineral glauconite transforms them into a sticky, clay-like sediment that can “cause pile refusal or difficulty installing the foundation to its target depth”. This mineral has been identified in the lease area for the recently approved Empire Wind project off Long Island. Not to worry New York has plenty of money to cover any unforeseen construction problems.

Energy and the Economy

Gail Tverberg notes that “Energy and the economy work together in very strange ways” in her recent article about offshored industrialization.  This article notes that:

Industry is based on the use of fossil fuels. Electricity also plays a role, but it is more like the icing on the cake than the basis of industrial production. Industry is polluting in many ways, so it was an “easy sell” to move industry offshore. But now the United States is realizing that it needs to re-industrialize. At the same time, we are being told about the need to transition the entire economy to electricity to prevent climate change.

I find her work fascinating but, in my opinion, her emphasis on finite resources does not account enough for technical innovation. Nonetheless, I agree with her point that maintaining fossil fuel supply should be a priority over trying to move away from them because of the importance of fossil fuels to today’s society.  She argues that:

The feasibility of moving away from fossil fuels without killing off a very major portion of the world’s population seems to be virtually zero. The world economy is a dissipative structure in physics terms. It needs energy of the right kinds to “dissipate,” just as humans are dissipative structures and need food to dissipate (digest). Humans cannot live on lettuce alone, or practically any other foodstuff by itself. We need a “portfolio” of foods, adapted to our bodies’ needs. The economy is similar. It cannot operate only on electricity, any more than humans can live only on high-priced icing for cakes.

Status of RGGI Third Program and Acadia Center RGGI Letter to State Officials

The Acadia Center recently sent me an email asking if I would sign a letter to State Officials regarding the Regional Greenhouse Gas Initiative (RGGI) Third Program Review.  That prompted me to prepare this article that summarizes the status of the Third Program Review and describes my response to the Acadia Center.

I am a retired air pollution meteorologist and worked on every cap-and-trade program affecting electric generating facilities in New York since 1990 including the Acid Rain Program, Regional Greenhouse Gas Initiative, and several Nitrogen Oxide programs since the inception of those programs. I also participated in RGGI Auction 41 and successfully won allowances which I held for several years. When I retired I started this blow where a regular topic is the RGGI cap and invest CO2 pollution control program.  The opinions I express 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.

The description of RGGI program review states:

The RGGI participating states are committed to comprehensive, periodic review of their CO2 budget trading programs, to consider successes, impacts, and design elements (Program Review). The RGGI states completed the First Program Review in February 2013 and completed the Second Program Review in December 2017, resulting in the 2017 Model Rule.

On February 2, 2021, the RGGI states released a statement announcing the plan for the Third Program Review, and in Summer 2021 the states released a preliminary timeline for conducting the Third Program Review. In November 2022, the states released a Program Review Update which includes an updated Program Review timeline.

Last September RGGI hosted a public meeting as part of the process and discussed the following topics:

  • Environmental Justice and Equity
  • Program Elements for Consideration
  • Electricity Sector Analysis

I prepared two articles after the meeting.   The first described 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 followed up with another article that described the comments submitted at the time by others.  Aside from an announcement on May 21, 2024 that “The participating states in the Regional Greenhouse Gas Initiative (RGGI) released the RGGI CO2 Emissions Dashboard on the RGGI website” there hasn’t been any other signs of progress on the program review process.

Acadia Center Draft Letter to RGGI

On May 22 I received an email that included the following:

I hope you’re doing well. I’m reaching out to ask for your support by signing onto another one of our RGGI letters, and this time we’re sending it to State Officials. The two-page letter aims to both ask for more information on the timeline on the Third Program Review and urge state officials to prioritize equity considerations in their decision-making processes for Third Program Review. Your signature would amplify our message and encourage your state officials to prioritize equity in their decision-making.

The draft letter is set up to go representatives in each of the RGGI states.  The New York draft is addressed to  Department of Environmental Conservation (DEC) Deputy Commissioner Jon Binder and the Chair of the New York Public Service Commission Rory Christian.  There are two requests in the letter.  Previous program reviews were completed much quicker than this one and included more collaborative opportunities between the States and stakeholders.  The first request asked, “when should we expect the RGGI states to take action to complete the Program Review?”  In the following discussion of my impression of the status of the program I will describe why I think this process is dragging but I certainly do not disagree with this request.  The second request in the letter is a request on the “need for the RGGI states to respond, from a substantive point of view to the comments you solicited, and we provided.”  I do not disagree with either sentiment.  The problem is that I don’t think they are able to respond to either one at this time as I will explain below.

My bigger issue with signing the letter is that I disagree with the following section of the letter:

Environmental justice and equity concerns for electricity ratepayers and frontline communities is notably the overarching issue that stands out among the many comments filed with the RGGI states. Of the various issues raised in the two rounds of 2023 program review stakeholder comments, 17 of the 38 filings from March and September mirror the language of the RGGI state’s initial Program Review announcement. They request that the RGGI states prioritize the needs of frontline communities.

The number of filings is only one piece of this story–it is also important to look at who filed comments. Multiple organizations signed on to comment letters. For example, the RGGI Advocates Coalition filing represents 18 organizations, while the Earthjustice et al. comments were signed by 16 organizations. Thus, an overwhelming majority of the organizations submitting 2023 program review filings urged the RGGI states to prioritize environmental justice-related issues in their program review. These issues and accompanying requests and recommendations include:

  • Adopt a definition of “environmental justice”, a necessity for states that do not have one;  
  • Set a percentage commitment of funds to allocate towards the RGGI ratepayers that have historically suffered from unfair treatment and disproportionate exposure to the harmful environmental conditions;
  • Increase frontline community participation in decision-making and participation in investment planning;
  • Address frontline community members’ exposure to poor air quality from criteria pollutants exacerbated by the electric generators covered by the program, and generators that are not yet covered by the program;
  • Lower the 25 MW program threshold to include smaller generating units in the program;
  • Expand air quality monitoring, particularly in disproportionately impacted areas at relevant levels of granularity
  • Set a new cap that is in line with the States’ goals, we are in support of a cap that goes to zero by 2040.

Before addressing my specific issues with this section of the letter I will describe all the comments.

Impression of Comments

My article on the comments submitted to RGGI was published on November 7, 2023 but RGGI posted another tranche of comments on November 9, 2023.  I did not update my article to address the comments that came in after the requested submittal date.  I noted that the comments concentrated on particular aspects of the proposed revisions to the RGGI program.  My article categorized the first set of comments and I updated that summary of comments for this article.  In brief these were the major themes:

  • Biomass Concerns – The Partnership for Public Policy and five individuals from Vermont complained about biomass power plants and the existing provision for “eligible” biomass to be treated as having zero emissions. 
  • Emissions Traders – One emission trading company and the International Emissions Trading Association submitted comments that I believe have market implications that traders could exploit at the expense of everyone else.
  • Support the Narrative – Five commenters including the Acadia Center agreed with the RGGI States suggestion to tighten the allowance caps and incorporate an environmental justice component. 
  • Cashing in on Advocacy – One comment on behalf of seven organizations in Pennsylvania read like a mission statement for advocates hoping to cash in on RGGI auction proceeds.
  • The Nature Conservancy comments were in a class by themselves.  They supported most of the issues raised in the Acadia Center letter but their support was based on naïve understanding of the issue.  They apparently have committed to offset projects that most environmental advocacy organizations do not accept.
  • Industry Concerns – Four industry comments argued for caution in any proposed changes because the compliance success to date is threatened as the program goes into unprecedented levels of allowance supply relative to expected emissions.  Another important point made is that the technology necessary to eliminate fossil fuel electric generating units does not exist today so setting a zero-emissions target must consider technological feasibility.

I also submitted personal comments.  I described my comments in an earlier post.  I explained that I am afraid that the RGGI States are placing so much reliance on their 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 modeling results should be considered relative to historical observations. 

Most advocates do not recognize that since the beginning of the RGGI program, RGGI funded control programs have been responsible for only 6.7% of the observed reductions.  My analyses indicate that most of the observed reductions of emissions are due to fuel switching from coal and residual oil to natural gas and that there are few opportunities for additional switching reductions in most RGGI States.  That means that future reductions are going to have to rely on displacing existing generator operations with zero-emission alternatives.  Ostensibly the auction revenues from RGGI are supposed to encourage development of those alternatives.  I have  found that when the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $927 per ton of CO2 reduced.  I think that the cost per ton reduced is too high to afford to develop the resources necessary for the reductions required to meet the aggressive allowance trajectories proposed.  In addition, as the allowances available go down either allowance prices will have to increase sharply or the revenues available for reduction investments will drop sharply.

My impression of the comments affect my response to the Acadia Center emphasis on equity portion of the draft letter to State Officials.  There is no question that many disadvantaged communities suffer disproportionate environmental impacts but it is important to understand what causes the harms and balance expectations and potential solutions. I agree that a definition of environmental justice for all RGGI states is needed  On the other hand, specific percentage commitment of funds is a problem for me because it will likely reduce the already poor effectiveness of investments to reduce emissions.  None of the RGGI states have a good record reducing emissions. The overall cost effectiveness of $927 per ton of CO2 reduced far exceeds the current Social Cost of Carbon.  Because fuel switching options to reduce emissions are just about tapped out, future emission reductions will only be possible when zero-emissions resources displace fossil plants.  The feasibility of that transition has never been proven and no jurisdictions have succeeded in that transition when depending upon wind and solar resources.  The recent New York technical conference that characterized the observed wind and solar resource cap and the resources necessary to address it conclusively show that existing technology is insufficient.

Another of the themes of the Acadia Center equit portion of the letter is to get the environmental justice communities more involved in the regulatory process: “Increase frontline community participation in decision-making and participation in investment planning”.  Electric and environmental resource planning is complex and there are reliability considerations that preclude some options that are endorsed by environmental justice advocates and the non-governmental organizations that provide them with technical support.  I certainly do not have an issue with their involvement but I do not see much value given their level of understanding.  Worse if it is impossible to accommodate all their demands the responses have not been constructive.

Environmental Justice advocates want to reduce “exposure to poor air quality from criteria pollutants exacerbated by the electric generators covered by the program, and generators that are not yet covered by the program”.  The New York City peaking power plant issue is a prime example of this concern and the disconnect between reality and activist demands.  Even though direct emissions from those plants comply with all existing environmental regulations and have dropped significantly over time, activists claim that they are the “most egregious energy-related example of what environmental injustice means today.”   Activists got a consultant to give them arguments to that effect and they have been promoting the issue ever since.  However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends.  In fact, analyses for the New York Cap-and-Investhave shown that was that the inhalable particulate emissions claimed as a particular problem are primarily from other sources based on the expanded air quality monitoring in disadvantaged communities.  Despite that finding the calls for shutdowns continue despite the fact that the organizations responsible for electric system reliability are on record saying that is unacceptable at this time.

Finally, the Acadia letter suggests setting a new cap that is in line with the States’ goals.   As noted previously this is problematic because the technology required is not available. 

Third Program Review Status

In my opinion the delays in the implementation of the Third Program Review recommendations are related to two problems: the participation of Virginia and Pennsylvania and the conflicting de-carbonization goals of the RGGI States.

The participation of Virginia and Pennsylvania has been mired down in politics and litigation.  Virginia is officially out currently but there is pending litigation to re-join.  Pennsylvania has never officially participated, and litigation is still holding back joining.  The problem is that both states have significant emissions and opportunities for further reductions.  In 2022, Virginia emissions were 23% of total RGGI emissions, Pennsylvania emissions were 27% of RGGI emissions including Virginia and 32% of total emissions excluding Virginia.  The allowance reduction trajectory feasibility depends on their participation so I suspect there is reluctance by the RGGI states to commit to something that will have to be scrapped if Virginia and Pennsylvania participation changes.

The other issue is that the de-carbonization goals of the RGGI states differ.  New York State has a law that mandates zero-carbon electric emissions by 2040.  Other states have different targets.  I believe that New York wants RGGI to comport with their mandate, but other states may not want to be so ambitious.  New York is setting up an economy-wide cap-and-invest program like RGGI but the latest version includes safety valves for reliability concerns.  I do not recall that the RGGI presentations have acknowledged that might be necessary so there is another controversy that must be resolved.

I am not surprised that the RGGI states have not been able to proceed with the Third Program Review.  I do not think it is possible to submit a letter that will accelerate the process given the complexity of the issues and all the uncertainties. The Acadia Center draft letter requested that the RGGI states to “respond, from a substantive point of view to the comments you solicited, and we provided.”  Given the wide range of possible outcomes and disparate interests of the states I do not think that they are able to respond to the comments now.

Conclusion

I agree with the concepts in the Acadia Center draft letter to State Officials.  An update on the status is overdue and responses to comments are appropriate.  However, I don’t think the status update is going to satisfy anyone because of all the uncertainties that preclude a firm schedule.   Until the differences between Virginia and Pennsylvania participation and RGGI state policy differences are reconciled it is impossible to respond to the proposed letter.  Therefore, I do not plan to sign the letter even if I am still welcome after this article is published.

My primary concern with RGGI relates to its ultimate goal of CO2 emissions reductions while maintaining a reliable and affordable electric system.  The Acadia Center letter and most of the comments were notable with respect to the motivations of the authors.  They mostly were at odds with the emission reduction goal.  There is a faction that despises a biomass facility in Vermont and commented on that.  Emissions traders support revisions to their advantage and not the rest of us.  One comment was a blatant marketing proposal to get money but it could be argued that many other commenters were doing the same thing just less obviously.

The RGGI state narrative now is to incorporate environmental justice considerations and comments supporting that were frequent.  In a recent post I addressed the tradeoffs between equity in a zero-sum approach relative to a positive-sum approach.  All the comments supporting environmental justice equity promoted the zero-sum approach with no recognition of potential unintended consequences.  I think the well-meaning emphasis on environmental justice is a problem because advocates are unduly pessimistic.  They ignore current environmental quality and improvements and focus on much smaller and less certain environmental risks all the while ignoring the benefits of a reliable electric system. 

Graduation Speech Essay You Need to Hear has Climate Response Implications

I think this marvelous Robert Parham essay deserves wide distribution.  It addresses the mis-placed pessimism of students in colleges today.  Parham is an assistant professor at the University of Virginia’s McIntire School of Commerce. Witnessing firsthand the growing distress among college students, Parham originally published his essay “To the Class of 2024: You Are All Diseased,” in The Free Press.  This post addresses the parallels between his college concerns and the environmental movement.

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.

To the Class of 2024

I recommend reading the essay but will summarize it here.  The introduction states:

If you are graduating from college this year, I suspect you’re not too familiar with George Carlin. So before you become inflamed about the (intentionally) harsh title, let me tell you I plagiarized it from Carlin, who was one of the best American comedians of the last 100 years. His show You Are All Diseased is available on YouTube, and it is so good that I was willing to start by alienating you a bit just to plug it here. You’re welcome. It is especially recommended if you’re in any kind of altered state of mind.

Speaking of states of mind: I’m worried about yours.

Rates of anxiety, depression, and suicide among people your age in the U.S. are skyrocketing. I myself lost a student to suicide a few years ago—an experience I wish on no one. I’m here to tell you that I think it’s partly our (your professors’) fault. We, along with others, have been feeding you a distorted view of the world and your place in it, and I think this has caused a considerable part of the existential angst you all feel.

But I’m not just aiming to point fingers.

I want to lay a vision of the present and future, which I genuinely believe and yet know many of you don’t share. After all, exposing you to unfashionable ideas is a core part of a healthy education. My deeper hope in doing so is to start a conversation on changing this sad state of affairs and to get you on your way to a happy and healthy life. Isn’t that what commencements are all about?

The thrust of the article is that today’s college students are deeply pessimistic about the future despite, as he argues, the fact that human beings have never had it so good. 

Based on every objective measure of well-being—safety, health, wealth—if you are a college student in America today you are better off and wealthier than the king of England was 300 years ago. You have better access to education, entertainment, leisure, and healthcare. You have cleaner water and more abundant food. You have a significantly safer and longer life. And you have access to all of the world’s knowledge, including this piece, in the palm of your hand.

Then he states: “Which then raises the question: Why? Why is it that “everything is amazing and nobody is happy”? He explains that the reason why we don’t think of ourselves as better off than the King of England:

We economists call this phenomenon “relative wealth concerns” or “keeping up with the Joneses.” These are just fancy terms to describe a simple psychological fact: we are constantly busy comparing ourselves to our peer group, and feel bad when we fall short in that comparison.

He goes on to describe our peer group:

“Peer group” is an essential term in the previous sentence. No one cares that they’re enormously better off than their grandparents; they just care that they’re worse off than Jeff Bezos or Elon Musk. You don’t feel wealthy, despite the fact the median human lives on the equivalent of $5,000 per year. Yes, you read that right. Imagine if you lived in the U.S., but only spent $5K a year at current U.S. prices, and you’ve imagined the life of the median human today. Your “peer group” isn’t humanity; it’s social media influencers and billionaires, and you are deeply unsatisfied when comparing your lives to theirs.

You live in the wealthiest country in the history of the world, yet you feel economic anxiety. The late Charlie Munger summarized it succinctly: “The world is not driven by greed. It’s driven by envy.” And in this era of instantaneous communication networks and social media, envy has been put into hyperdrive.

Professor Parham is not a fan of the emphasis on equity or fairness.  He argues that envy is no longer a deadly sin, it has become the fairness virtue.  He points out fairness issues for American college graduates relative to the rest of the world:

The world is unfair. Deeply so. It’s just that you’re the lucky ones. You won the birth lottery.

In a truly fair world, any dollar you make or spend above $5,000 a year would instead be given to someone else. Maybe a poor Kenyan, or Bangladeshi, or Indian. But that’s not the kind of fairness and equity anyone talking about “fairness” and “equity” around you seeks.

You’ve been lied to. You’ve been told, by the media, social networks, and not least your professors, that this fantastic world we live in is evil. Not only that, you’ve been told it’s your fault. You’re too racist, too greedy, too white, too privileged, not sufficiently attuned to the plight of the marginalized. It is not enough to be non-racist, they say, you must be anti-racist. Anything less than that, and you’re complicit in evil. Some of you are better by default due to some accidents of birth; some of you are worse. Small wonder you feel suffocated, anxious, and depressed.

Any human, weighed down with this responsibility and guilt, would be just as down. The cognitive dissonance of being told colonialism is evil, American slavery is uniquely evil, that wealth and the markets that enable it are evil, while going to school at a top-tier U.S. institution built on “Monocan land” using slave labor would incapacitate anyone.

He includes an informative description of the concept of money and how that creates a transaction where both parties become better off because of it.  As society has evolved away from one-on-one transactions between people, now the transactions are between people and corporations.  People earn money and can purchase what they need and want.  He explains that when that happens: “We’re better off, the company we bought things from is better off, its employees and suppliers are better off, and so are their employees and suppliers. But in colleges today capitalism is frequently described as evil:

Without fail, at the end of the class a few students tell me that the content of the course was diametrically opposed to what they had been taught so far. Prior, they had class discussions about the exploitative nature of the market system and its inherent unfairness; the evil and greed of corporations; and the fight of exploited workers against oppressive capitalists.

In response he states:

I point out to them that these paradigms imply a zero-sum world in which wealth can only be created by taking it from others, whereas they live in the positive-sum world of markets, in which wealth is created by exchange. Markets have deposited a magic wand in their hands, which allows them to freeze moments in time, observe what is currently happening in foreign lands, and conjure loved ones for a face-to-face conversation out of thin air. Kings would have given half their kingdom for such a wand, but now anyone can have it for the low, low price of $69.99 per month. Or about five hours of student work. This is how we got wealthy.

He goes on to say:

My students arrive at my class steeped in zero-sum ideas, in which one person’s gain must be another person’s loss, and the only way to get a thing is by “oppressing” it from someone else. Then, they are shocked to hear heretical ideas about a world in which wealth is created, not stolen, and human interactions can be win-win and make all of us immensely well-off. The dissonance is severe, and they’re unsure how to deal with all the shame and guilt accumulated by years of accused “oppression.”

I hence want to close by telling you, the class of 2024: it’s not your fault. You are not evil. Being white / black / privileged / downtrodden / well-educated / illiterate / wealthy / poor / healthy / sickly / cisgendered / non-conforming does not make you bad (or good, for that matter). The sins of your forefathers are not your own. You did nothing wrong by being born. Yes, aiming to improve the state of human affairs is noble, but choosing instead to study, play games, and make out with the cute person you have your eye on does not make you bad. It makes you a normal, healthy human being. And no one seems to bother to tell you that. So there, I said it. You are not subject to the “original sin.” Go forth and have a happy and healthy life. There is still (much) room for progress, but things are currently better than they’ve ever been, and improving fast.

Or as Carlin put it, in his direct way: “Life gets really simple once you cut out all the bullshit they teach you in school.”

Environmental justice Parallels

I believe the environmental parallel is related to the “zero-sum idea”.  The common perception is that emissions from a power plant or a factory are exploitive and come at the expense of harm to others, especially environmental justice communities. The concept that, within limits, emissions have positive-sum benefits is ignored.

No where is this dissonance more pronounced than the environmental justice movement.   The EPA defines environmental justice:

“Environmental justice” means the just treatment and meaningful involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision-making and other Federal activities that affect human health and the environment so that people:

  • are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers; and
  • have equitable access to a healthy, sustainable, and resilient environment in which to live, play, work, learn, grow, worship, and engage in cultural and subsistence practices

The difference between zero-sum and positive-sum environmental approach is in the definition of “disproportionate and adverse human health and environmental effects”.  The environmental justice position I hear most often is a demand for no health and environmental effects.

In that regard I think my career is an instructive positive-sum example.  When I completed my master’s degree in 1976 the United States Environmental Protection Agency (EPA) was only six years old and corporate America was just coming to grips with environmental management.  I worked for five years for three different consulting companies that did contract work for EPA.  In 1981 I started to work for Niagara Mohawk Power Corporation a vertically integrated electric utility.  The environmental progress since I started working in the New York electric generating business has been astounding but is ignored by environmental justice activists.

One of my responsibilities at Niagara Mohawk was to prepare and submit emissions data to regulatory agencies.  I recently found annual emissions data back to 1984.  One of our facilities was the coal-fired Dunkirk Generating Station in Western NY.  The facility had two 100 MW units and two newer 200 MW units.  In 1984 the facility emitted 54,709 tons of SO2 at a rate of 3.26 lb per mmBtu and 10.020 tons of NOx at a rate of 0.598 lb per mmBtu.  Over my time supporting the station, they installed controls for SO2, NOx, particulates, and mercury.   In my last year with responsibilities for reporting at the station (2010) the facility emitted 7,380 tons of SO2 at a rate of 0.505 lb per mmBtu and 2,342 tons of NOx at a rate of 0.160 lb per mmBtu.  Since then, the facility has been shut down.  In 2023, the total electric generating sector emissions in the entire state of New York were 645 tons of SO2 at a rate of 0.003 lb per mmBtu and 7,488 tons of NOx at a rate of 0.030 lb per mmBtu.  That is astounding progress.

Despite this tremendous reduction, environmental justice activists carry on about the egregious harm caused by power plants and claim numerous health effects from existing sources.  However, if their health effect claims were true then there should be enormous observable improvements from the improvements made since 1984.  I have not seen any such analysis. The other counter narrative is that the reason for the improvement is that natural gas became the cheapest fuel source and that occurred because of the fracking revolution that the environmental justice activists love to hate.

Discussion

My takeaway from Parham’s speech is that things are much better than portrayed by many academics.  “There is still (much) room for progress, but things are currently better than they’ve ever been, and improving fast.”  That sentence sums up the status of the environment in the US.  There are environmental issues that still need to be addressed.  However, the health of the environment has never been better in this country.  There has been tremendous improvement over the last 40 years.

My concern is that as is the case with the academic focus on pessimism there are those who ignore environmental improvements and focus on current much smaller environmental risks all the while ignoring the benefits of a reliable electric system.  The New York City peaking power plant issue is a prime example.  Even though direct emissions from those plants comply with all existing environmental regulations, activists claim that they are the “most egregious energy-related example of what environmental injustice means today.”   The activists paid a consultant to give them that answer and have been promoting the issue ever since.  However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends.  In fact, analyses for the New York Cap-and-Invest have shown that was that the inhalable particulate emissions claimed as a particular problem are primarily from other sources.

Nonetheless, environmental justice activists are demanding that those facilities shut down.  This is a problem because we do not have a zero-emissions technology that can replace them and maintain the same levels of reliability.  If they are shut down too soon then blackouts are inevitable that will cause real impacts rather than the conjured impacts used to argue for the shutdowns.  Their efforts would be better served by promoting inhalable particulate emission reductions from diesel trucks.  Environmental justice advocates are arguing that would be appropriate but imagine that a zero-emissions solution is necessary.  There could be a tremendous improvement using existing technology that only needs development of infrastructure but compressed natural gas has emissions and the natural gas used would be fracked so this practical solution is ignored.

Conclusion

Parham’s essay stands on its own as a great message for today.  The difference between a zero-sum society in which wealth can only be created by taking it from others, and a positive-sum society in which wealth is created by exchange is being improperly ignored.  Worse academics are promoting the zero-sum concept to the detriment of their students.

In my opinion, I think there are zero-sum versus positive-sum environmental parallels.  The United States has developed a comprehensive set of environmental standards and there have been unquestioned overall environmental quality improvements over the last several decades.  The sum of benefits and costs are positive.  Regarding emissions in isolation, focusing only on the negatives and disregarding any benefits is an approach like the zero-sum concept of wealth. It creates an unnecessarily pessimistic outlook, hinders growth, and could lead to unintended consequences.

Grid Planning to Meet Climate Act Goals Documentation

Note:  This documents all the slides in the Grid Planning to Meet Climate Act Goal presentation.  I also prepared a summary of the material in this post.

In order to meet the Climate Leadership & Community Protection Act (Climate Act) mandates for a zero-emissions electric grid by 2040 a massive effort to deploy wind, solar, and energy storage resources and an enormous upgrade to the electric transmission system is needed.  I have previously described issues associated with generating portion of this transition.  This post documents the Alliance for Clean Energy New York (ACENY) webinar “Grid Planning to Meet Climate Act Goals” that addressed the transmission challenges in a lot of detail.  A summary is also available.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions 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 (CAC) was responsible for preparing the Scoping Plan that outlined 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. 

ACENY Webinar

On April 11, 2024, Alliance for Clean Energy New York (ACENY) hosted a webinar entitled “Grid Planning to Meet Climate Act Goals” that was recorded on a video.  The webinar was moderated by Chris Casey, from the NRDC and featured speakers from the Department of Public Service (DPS), New York Independent System Operator (NYISO), and National Grid.  This article describes each speakers presentation and provides links to sections of the video so that readers can follow the presentations.

Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his introduction ticked all the boxes.  New York is on the “forefront of the transition to address the “impacts of destructive climate change”, increase access to “affordable” renewable energy, bolster “resilience against life-threatening extreme energy events”, all while “creating jobs and delivering substantial economic benefits”.  Behind the rhetoric, however, reality lurks, and it does not look so grand.  In the following sections I include slides and links to the section of the video that discusses the slide.

DPS Presentation

Elizabeth Grisaru (Senior Policy Advisor) from the DPS made the first presentation “Planning for Future Electric System Needs”.  One of her main job responsibilities is transmission planning associated with the Climate Act transition.  During her introduction she included a slide that illustrates the connections between generators and customers that were the focus of the webinar.

The “Impact of Climate Objectives” slide describes the general issues associated with the transition.

The description of the slide “PSC Initiatives since 2020” outlined projects costing over $6 billion that are over and above what is needed to keep the system running.  The investments are for both Climate Act needs and reliability issues.  What was not included was the breakdown between the two needs or any estimate of how much more will be needed.  It is clear that many more investments will be required.

The transition to an electric system that depends upon diffuse wind and solar requires a significant upgrade to the transmission system.  The PSC has a new “Coordinated Grid Planning Process” to address this issue. 

Note, however, that the first of the new CGPP reports is not going to be available until the Fall of 2025.  It is not clear if the CGPP is going to help at all to meet the 2030 target.

The DPS final slide addresses outstanding issues.  On one hand existing sources of generation are being forced to retire while on the other hand electrification initiatives are increasing loads.  She claimed that at the PSC “We all agree reliability is the most important thing we have to worry about”.

NYISO Presentation

NYISO Director of System Planning Yachi Lin talked about their plans to implement a clean and reliable grid.  Her introductory explanation gave a good overview of the NYISO.  The following slide describes the planning process.  There is a two-year cycle of reliability planning that includes quarterly checks on the status of the system. 

The following slide describes the generation system and the investments expected to be needed.  Existing generating capacity is 37.4 GW, but an additional 20 GW must be in service in seven years to meet the 2030 goal.  The unanswered question was whether this is feasible.

Lin explained that additional transmission is needed to meet the 2030 70% renewable energy goal.  The following slide shows different areas of the state that do not have adequate transmission capabilities to prevent curtailments.

To respond to the need for additional transmission the NYISO planning process is supporting “unprecedented expansion”.

The quarterly Short-Term Assessment of Reliability (STAR) reports should be required reading for anyone interested in the New York electric system so Lin’s explanation is important.  The following slide notes that last years second quarter report noted that there was a reliability deficit of 446 MW in the summer of 2025.  The deficit was projected because of fossil unit deactivations.  In response, NYISO opened a solicitation for market solutions or regulatory solutions.  No feasible market solution was submitted. 

To maintain reliability, NYISO had to resort to a regulatory solution.  They designated two peaking generation plants as reliability needs and postponed their retirement for two years.  The NY Department of Environmental Conservation “Peaker Rule” incorporates this provision and there is a potential for an additional two-year extension. If the Champlain Hudson Power Express transmission project is delayed beyond 2026 the additional extension might be required.

The Comprehensive Reliability Planning report incorporates changes associated with demand growth. In the following slide NYISO describes expected changes.  As mentioned previously, fossil generator retirements and growth in demand are primary changes to the system.  Part of the load demand shift changes the peak loads from summer to winter.  This is troublesome because the winter diurnal peak will occur when there is no solar.  She also mentioned the dual-fuel units.  Many New York generating units normally burn natural gas because it is cheaper but have the capability to switch to oil firing when natural gas is needed by residential consumers.  The increased reliance on these units which at the same time are targeted for retirement is a problem.  The CRP analysis also identified added risks.  The addition of the Micron chip fab plant near Syracuse will add load equivalent to the total load of Vermont and New Hampshire.  The New York Power Authority operates small natural gas plants in New York City that are supposed to be phased out by December 2030 due to political pressure.  Lin had to make the obligatory gesture to climate change extreme weather as a risk.  Finally, the shift to a weather-dependent generating system mans that reliability design criteria need to be revised to account for extreme weather conditions outside current planning horizons.

The next four slides summarize the challenges to meet the 2040 Climate Act mandate for a “zero-emissions” electric grid.  The next slide repeats the points raised in the previous slide.  Lin remarked that the year of the cross over from summer to winter peaking can only be guessed at this time.  Depending on the trends in load it could be almost anytime in the next decade.  The 90/10 and 99/1 forecasts are probability estimates for the likelihood of extreme weather events.  The final bullet in the slide points out that there could be substantial load growth needed to provide reliability services.  The NYISO includes a high load policy case that incorporates this load.

The next slide lists the challenges on the generation side.  Lin makes the point that generation issues extend beyond simply evaluating the capacity needed to match the load projections.  Wind, solar, and energy storage are inverter-based resources that require ancillary service support to make the transmissions system reliable.  Weak-grid interconnection and common mode failures are issues that most people, including me, do not understand well.  The key point is that all the people that I know understand these issues are worried but there was never any indication of concern by the Climate Action Council.  Consequently, the Scoping Plan outline produced by the Hochul Administration to guide the energy transition is incomplete.  Lin makes the little recognized point that the Dispatchable Emissions Free Resources are not needed just for the long periods of low renewable resource availability but also to provide these ancillary services.

The next slide addresses DEFR specifically. I will not discuss this much because I covered the Department of Public Service (DPS) two-day technical conference last December that focused on characterization of the potential “gap” caused by low renewable energy resource availability over long periods of time.  I mentioned but did not emphasize the importance of providing the “reliability attributes of retired synchronous generation”.

The focus of this webinar was on the transmission challenges as covered in the following slide.  Lin explained that transmission expansion is required to get the diffuse wind and solar energy from where it is collected to where it is needed.  The existing system is not adequate for this task.

In the next slide Lin explained how the NYISO is working with the PSC to identify the needed bulk and local transmission needed. 

The final slide in Lin’s presentation presented the planning process expected progress.  There is an enormous amount of work underway but the analysts have a big challenge dealing with changes in the development of resources.  As noted earlier, the 2026 expectation is that the Champlain Hudson Power Express project will be online.  Even after years of development work the right of way is still not fully permitted and there are numerous examples of supply chain issues delaying other projects so the planning process is subject to massive uncertainty.

National Grid Presentation

Brad Franey Vice President Clean Energy Development explained how National Grid is addressing the need for transmission support.  As he points out the utilities receive funding for their transmission and distribution (T&D) system investments from rate cases.  Those rate cases are, in no small part, influenced by politics.    As a result, none of New York’s utility companies are going to overtly challenge the political narrative that the Climate Act objectives can be achieved on schedules mandated by the law.  The following slide probably went through multiple iterations to achieve a description of plans that checks all the boxes for what the company thinks that the politicians want to hear. 

I live in Upstate New York so I was particularly interested in the “Upstate Upgrade” described in the following slide.  The following slide rationalizes the costs for the upgrades to over 1,000 miles of lines.  In his description Franey gave the example of a town that attracts snow mobile tourists in the winter.  The last two years there have been snow droughts because they “no longer have the snow like they used to.” Construction of a line nearby brought in a lot of business and locals said that those saved businesses.  The entire slide is devoted to the mantra that the Climate Act will create jobs and investments.  Last year I described the DPS rulemaking that foisted these projects on the Upstate ratepayers.  This slide avoids the things I found: National Grid residential ratepayers will see their bills increase 3.8%, the fact that these upgrades are needed to get renewable energy to Downstate so don’t benefit the ratepayers directly, or that the percentage increase for upstate ratepayers will be greater than the increase for ratepayers who directly benefit from the investments. 

The next slide gives an example of their proposed reliability solutions. He included the obligatory argument that we are seeing more “frequent storms” that ignores the differences between weather and climate.  He went on to give examples where a reduction in outages would positively impact their community.  The proposed solution is a microgrid with battery energy storage.  In my opinion, however, this is another example of a clean energy solution that works well most of the time but will fail when needed most.  The problem here is the specification for battery storage.  In the future New York system when home heating and transportation are both electrified the worst case will be an extended outage due to an extreme weather event like an ice storm.  Specifying the battery storage for an ice storm event that occurs every 20 years will probably be too costly but when the inevitable ice storm does occur everyone in the microgrid will be at extreme risk because the energy storage system will run out of power.  Fossil fuels are energy dense and can be stored making them much better for emergency backup.

Another initiative that National Grid is starting to support is public charging.  Again ratepayers get to pick up the tab for something that most will not use and don’t ever want to use.  Their analysis indicates that the load at the service plazas along the thruway could go up to 20 to 40 MW which is the same load as “a small town or major sports stadium.”  In order to provide that load they need to upgrade the local infrastructure.  They are planning to use mobile energy storage along the Thruway until infrastructure is developed.  This bridge to wires solution is a pragmatic approach given the likely futility of heavy duty electric trucks.

The latest rate case included funding for smart meters.  Franey describes this initiative in the next slide.  Ostensibly this is supposed to help consumers better understand their energy use and facilitate outage response but the ability to try to reduce peak loads either through rate mechanisms or eventually managing electric use are certainly on the table.

Questions and Answers

The question and answer portion of the webinar was interesting.   The first question asked was “Is reliability a prerequisite for everything else or is it co-equal with our policy objectives?”  I have heard suggestions that policy objectives should be considered more than they are currently but anyone hoping to hear that there have been changes to protections in place to make sure that our policies don’t get ahead of reliability would have been disappointed in the answers.  Elizabeth Grisaru from the DPS made it clear that reliability comes first, that there are “off ramps” for the implementation schedule and that the PSC will not let our zeal for meeting de-carbonization goals get out in front of reliability.  Yachi Lin from the NYISO emphasized the point that they are constantly evaluating reliability.  The quarterly Short term assessment of reliability and the longer term reliability needs assessment both address it.  She admitted that we are going to have outages because the network is not built to be 100% risk-free or outage free.  The alternative it “gold plating the system” which we cannot afford. 

The next question asked about interconnections when the grid is not ready to take new renewables.  How does that come into play and how will this be alleviated?  Grisaru from the DPS acknowledged that if the system is not ready then developer has to pay for interconnection upgrades.  They are trying to address this but it takes time. Franey from National Grid said that they are working on the issue but reliability has to be maintained.

There was a question about the different planning cycles.  I think this question came before the NYISO described their processes.  Grisaru from the DPS explained that the Coordinated Grip Plan Process is supposed to put it all together.  Liu from NYISO explained that constant planning is responding to continual changes to the system.  Every new development changes some aspect of the T&D system in some way.

The panel responded to the question how does the public policy planning processes differ.  Grisaru explained that when the DPS sees a need on the bulk transmission system they contact the NYISO to start a process to look for a solution.  The NYISO system outlook can also identify bulk transmission requirements.

A question about longer planning processes planning and deployment timing was also addressed.  Liu explained that the NYISO resource adequacy process identifies risk factors and the timelines to develop the responses.  Franey explained that the building component is the fastest but still takes years.  The process has to determine what is needed and where before the planning permitting, and construction plans can be developed.  Only when all that is done can construction begin but there are procurement and supply chain issues that also have to be addressed.

How can the state policies that affect energy use affect transmission planning.  Climate activists are proponents of smart grids, energy efficiency, and other technologies that reduce energy use as a way to minimize the need for transmission development.  In response, Grisaru explained that non-wires solution have been used for a long time and is incorporated into the Coordinated Grip Plan Process.  The problem is that the de-carbonization transformation is going to require transmission solutions.  Franey explained that urban city electrification (bringing rural diffuse renewables to the cities) is going to be the next challenge,

Discussion

My impression of the speakers at this meeting is that they were desperately trying to make the point that the transmission challenges for the Climate Act mandates and schedule were impossible goals without actually saying that.  I believe that all the technical people who really understand the electric grid in the DPS, NYISO and the electric companies are being held hostage to the political narrative that “All is well”.  That did not work out for Kevin Bacon in Animal House and it won’t work out here either.

The transmission challenges are different than the generation challenges.  While it may not be necessary to develop and deploy a not yet commercially available technology like the generation sector to make this all work there still are inverter-based resource integration issues that need to be resolved.  I have the utmost respect for the electric system engineers, but I fear that they will be hit by unanticipated combinations of conditions that they could not foresee.  The result will be blackouts.

In my opinion the bigger problem is the scale of the transmission upgrades and additions needed.  New York has already committed to $6 billion to start “unbottling” renewable resources which is code in New York for Upstate utilities paying for support for New York City access to renewables.  New York also has plans for three major bulk transmission projects to get hydroelectric power from Quebec, another to collect the energy from part of Upstate to New York City, and the third to start the process of connecting the expected 9 GW of offshore wind into the grid.  Nobody has admitted to the total costs.

The other New York problem that I suspect is common elsewhere is that the politicians who enacted these net-zero laws were more concerned with the optics of aspirational timelines and not the feasibility of those schedules.  A question about longer planning processes planning and deployment timing made the point that the NYISO resource adequacy process that identifies specific need for transmission development, New York’s de-regulated market process to propose, bid, and choose the development, and the project planning, permitting, and construction plans development which all need to  be completed before construction can begin takes a lot of time.  Reading between the lines all the speakers are highly skeptical that the artificial deadlines of the Climate Act can be achieved.

One final point not addressed in the webinar but certainly affecting the viability of New York’s energy transition goal is the decarbonization of heating and transportation.  That is going to require a complete rewiring of the distribution network.

Conclusion

The magnitude, costs, and technical challenges of the generation and transmission electric grid transition ensure that that there is no question that New York will hit the Green Energy Wall.  The Hochul Administration has not provided a feasibility analysis that includes the expected costs, ensures that current reliability standards can be maintained, and documents the cumulative environmental impacts of the generation resources and the transmission and distribution deployments for the electric system to meet the 2030 70% renewable energy mandate.  The fact that no jurisdiction anywhere has developed a system that depends on wind and solar as in the proposed New York system suggests that a proof of concept demonstration is appropriate.

Grid Planning to Meet Climate Act Goals Summary

Note:  This is a summary of the presentation that is a version of a post at Watts Up With That.  In order to prepare the summary, I documented all the slides and made that into another post.

In order to meet the Climate Leadership & Community Protection Act (Climate Act) mandates for a zero-emissions electric grid by 2040 a massive effort to deploy wind, solar, and energy storage resources and an enormous upgrade to the electric transmission system is needed.  I have previously described issues associated with generating portion of this transition.  This post summarizes the Alliance for Clean Energy New York (ACENY) webinar “Grid Planning to Meet Climate Act Goals” that addressed the transmission challenges in a lot of detail. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions 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 (CAC) was responsible for preparing the Scoping Plan that outlined 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. 

ACENY Webinar

On April 11, 2024, the Alliance for Clean Energy New York (ACENY) hosted a webinar entitled “Grid Planning to Meet Climate Act Goals” that was recorded on a video.  The webinar was moderated by Chris Casey, from the Natural Resources Defense Council (NRDC) and featured speakers from the Department of Public Service (DPS), New York Independent System Operator (NYISO), and National Grid.  This article describes each speaker’s presentation and provides links to sections of the video so that readers can follow the presentations.

Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his introduction ticked all the boxes.  New York is on the “forefront of the transition to address the “impacts of destructive climate change”, increase access to “affordable” renewable energy, bolster “resilience against life-threatening extreme energy events”, all while “creating jobs and delivering substantial economic benefits”.  Behind the rhetoric, however, reality lurks, and it does not look so grand.  In the following sections I include slides and links to the section of the video that discusses the slide.

DPS Presentation

Elizabeth Grisaru (Senior Policy Advisor) from the DPS made the first presentation “Planning for Future Electric System Needs”.  One of her main job responsibilities is transmission planning associated with the Climate Act transition.  During her introduction she included a slide that illustrates the connections between generators and customers that were the focus of the webinar.

Since the inception of the Climate Act, DPS has begun several initiatives.  These projects total $6 billion over and above what is needed to keep the system running.  The investments are for both Climate Act needs and reliability issues.  What was not included was the breakdown between the two needs or any estimate of how much more will be needed.  Clearly many more investments will be required.

The transition to an electric system that depends upon diffuse wind and solar requires a significant upgrade to the transmission system.  The PSC has a new “Coordinated Grid Planning Process” to address this issue.  However, the first report will not be available until the fall of 2025.  The Climate Act an interim 2030 electric grid target of 70% power from renewable sources by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. I have to say I don’t think the schedules match.

The DPS final slide addresses outstanding issues.  On one hand existing sources of generation are being forced to retire while on the other hand electrification initiatives are increasing loads.  Grisaru claimed that at the PSC “We all agree reliability is the most important thing we have to worry about”.

NYISO Presentation

NYISO Director of System Planning Yachi Lin talked about their plans to implement a clean and reliable grid.  The following slide describes the NYISO planning process.  There is a two-year cycle of reliability planning that includes quarterly checks on the status of the system.  NYISO is constantly evaluating future reliability needs.

The following slide describes the generation system and the investments expected to be needed.  Existing generating capacity is 37.4 GW, but an additional 20 GW must be in service in seven years to meet the 2030 goal.  Note that the feasibility question has been studiously avoided by the state and the NYISO and utility companies have not overtly called the aspirational schedule out as impractical.

Lin explained that additional transmission is needed to meet the 2030 70% renewable energy goal.  There are different areas of the state that do not have adequate transmission capabilities to move the solar and wind power out without curtailments.  To address those needs the NYISO planning process is supporting “unprecedented expansion”.

One of the planning reports is the quarterly Short-Term Assessment of Reliability (STAR).   Anyone interested in the status of the New York electric system would do well to listen to Lin’s explanation. The following slide notes that last year’s second quarter report noted that there was a reliability deficit of 446 MW in the summer of 2025.  The deficit was projected because of fossil unit deactivations.  In response, NYISO opened a solicitation for market solutions or regulatory solutions.  No feasible market solution was submitted so they had to go to Plan B.

To maintain reliability, NYISO had to resort to a regulatory solution.  They designated two peaking generation plants as reliability needs and postponed their retirement for two years.  The NY Department of Environmental Conservation “Peaker Rule” incorporates this provision and there is a potential for an additional two-year extension. If the Champlain Hudson Power Express transmission project is delayed beyond 2026 the additional extension might be required.

The Comprehensive Reliability Planning (CRP) report incorporates changes associated with demand growth. In the following slide NYISO describes expected changes.  As mentioned previously, fossil generator retirements and growth in demand are primary expected changes to the system.  Part of the load demand shift changes the peak loads from summer to winter.  This is troublesome because the winter diurnal peak will occur when there is no solar.  She also mentioned the dual-fuel units.  Many New York generating units normally burn natural gas because it is cheaper but have the capability to switch to oil firing when natural gas is needed by residential consumers.  The increased reliance on these units, which at the same time are targeted for retirement is a problem.  The CRP analysis also identified added risks.  The addition of the Micron chip fab plant near Syracuse will add load equivalent to the total load of Vermont and New Hampshire.  The New York Power Authority operates small natural gas plants in New York City that are supposed to be phased out by December 2030 due to political pressure.  Lin had to make the obligatory gesture that climate changes to extreme weather was a risk.  Finally, the shift to a weather-dependent generating system means that reliability design criteria need to be revised to account for extreme weather conditions outside current planning horizons.

The next four slides summarize the challenges to meet the 2040 Climate Act mandate for a “zero-emissions” electric grid.  The next slide repeats the points raised in the previous slide.  Lin remarked that the year of the cross over from summer to winter peaking can only be guessed at this time.  Depending on the trends in load it could be almost any time in the next decade.  The 90/10 and 99/1 forecasts are probability estimates for the likelihood of extreme weather events.  The final bullet in the slide points out that there could be substantial load growth needed to provide reliability services.  The NYISO includes a high load policy case that incorporates this possibility.

The next slide lists the challenges on the generation side.  Lin makes the point that generation issues extend beyond simply evaluating the capacity needed to match the load projections.  Wind, solar, and energy storage are inverter-based resources that require ancillary service support to make the transmissions system reliable.  Weak-grid interconnection and common mode failures are issues that most people, including me, do not understand well.  The key point is that all the people that I know who understand these issues are worried but there has not been any wavering of the official political position that all is well.  Consequently, the Scoping Plan outline produced by the Hochul Administration to guide the energy transition is incomplete.  Lin makes the little recognized point that the Dispatchable Emissions Free Resources are not needed just for the long periods of low renewable resource availability but also to provide these ancillary services.

The next slide addresses DEFR specifically. I will not discuss this much because I covered the Department The next slide addresses DEFR specifically. I will not discuss this much because I already covered the Department of Public Service (DPS) two-day technical conference last December that focused on characterization of the potential “gap” caused by low renewable energy resource availability over long periods of time.  I mentioned but did not emphasize the importance of providing the “reliability attributes of retired synchronous generation”.

The focus of this webinar was on the transmission challenges as covered in the following slide.  Lin explained that transmission expansion is required to get the diffuse wind and solar energy from where it is collected to where it is needed.  The existing system is not adequate for this task.

The final slide in Lin’s presentation presented the planning process expected progress.  There is an enormous amount of work underway, but the analysts have a big challenge dealing with changes in the development of resources.  As noted earlier, the 2026 expectation is that the Champlain Hudson Power Express project will be online.  Even after years of development work the right of way is still not fully permitted and there are numerous examples of supply chain issues delaying other projects, so this may not occur.  Clearly longer-term planning is subject to massive uncertainty.

National Grid Presentation Brad Franey Vice President Clean Energy Development explained how National Grid is addressing the need for transmission support.  As he points out the utilities receive funding for their transmission and distribution (T&D) system investments from rate cases.  Those rate cases are, in no small part, influenced by politics.    As a result, New York’s utility companies are held hostage and are not going to overtly challenge the political narrative that the Climate Act objectives can be achieved on schedules mandated by the law.  The following slide probably went through multiple iterations to achieve a description of plans that checks all the boxes for what the company thinks that the politicians want to hear.

In the remainder of his presentation he described specific projects that the utility is doing in its service territory.  If you are interested in that information, check out my post that covers all the slides.

Questions and Answers

The question and answer portion of the webinar was interesting.   The first question asked was “Is reliability a prerequisite for everything else or is it co-equal with our policy objectives?”  I have heard suggestions from climate activists that policy objectives should be considered more than they are currently but anyone hoping to hear that there have been changes to protections in place to make sure that those policies don’t get ahead of reliability would have been disappointed in the answers.  Elizabeth Grisaru from the DPS made it clear that reliability comes first, that there are “off ramps” for the implementation schedule, and that the PSC will not let the zeal for meeting de-carbonization goals get out in front of reliability.  Yachi Lin from the NYISO emphasized the point that they are constantly evaluating reliability.  The quarterly short term assessment of reliability and the longer term reliability needs assessment both address it.  She admitted that we are going to have outages because the network is not built to be 100% risk-free or outage free.  The alternative it “gold plating the system” which we cannot afford. 

that the NYISO resource adequacy process identifies risk factors and the timelines to develop the responses.  Franey explained that the building component is the fastest but still takes years.  The process has to determine what is needed and where before the planning permitting, and construction plans can be developed.  Only when all that is done can construction begin but there are potential delays due to procurement and supply chain issues that also must be addressed. 

Discussion

My impression of the speakers at this meeting is that they were desperately trying to make the point that the transmission challenges for the Climate Act mandates and schedule were impossible goals without actually saying that.  I believe that all the technical people who really understand the electric grid in the DPS, NYISO and the electric companies are being held hostage to the political narrative that “All is well”.  That did not work out for Kevin Bacon in Animal House and it won’t work out here either.

The transmission challenges are different than the generation challenges.  While it may not be necessary to develop and deploy a not yet commercially available technology like the generation sector to make this all work there still are inverter-based resource integration issues that need to be resolved.  I have the utmost respect for the electric system engineers, but I fear that they will be hit by unanticipated combinations of conditions that they could not foresee.  The result will be blackouts.

In my opinion the bigger problem is the scale of the transmission upgrades and additions needed.  New York has already committed $6 billion to start “unbottling” renewable resources which is code in New York for Upstate utilities paying for support for New York City access to renewables.  New York also has plans for three major bulk transmission projects to get hydroelectric power from Quebec, another to collect the energy from part of Upstate to New York City, and the third to start the process of connecting the expected 9 GW of offshore wind into the grid.  Nobody has admitted to the total costs.

The other New York problem that I suspect is common elsewhere is that the politicians who enacted these net-zero laws were more concerned with the optics of aspirational timelines and not the feasibility of those schedules.  A question about longer planning processes planning and deployment timing made the point that the NYISO resource adequacy process that identifies specific need for transmission development, New York’s de-regulated market process to propose, bid, and choose the development, and the project planning, permitting, and construction plans development which all need to  be completed before construction can begin takes a lot of time.  Reading between the lines all the speakers are highly skeptical that the artificial deadlines of the Climate Act can be achieved.

One final point not addressed in the webinar but certainly affecting the viability of New York’s energy transition goal is the decarbonization of heating and transportation.  That is going to require a complete rewiring of the distribution network.

Conclusion

The magnitude, costs, and technical challenges of the generation and transmission electric grid transition ensure that that there is no question that New York will hit the Green Energy Wall.  The Hochul Administration has not provided a feasibility analysis that includes the expected costs, ensures that current reliability standards can be maintained, and documents the cumulative environmental impacts of the generation resources and the transmission and distribution deployments for the electric system to meet the 2030 70% renewable energy mandate.  The fact that no jurisdiction anywhere has developed a system that depends on wind and solar as in the proposed New York system suggests that a proof-of-concept demonstration is appropriate.

New York Assembly Cap and Dividend Bill Naiveté

In order to meet the Climate Leadership & Community Protection Act (Climate Act) the Hochul Administration has proposed the New York Cap-and-Invest (NYCI) program.  The regulatory process to set up this market-based emissions trading program is underway.  Not content to let the that process play out Assemblyperson Anna Kelles has introduced a bill to “amend the environmental conservation law and the public authorities law, in relation to establishing an economy-wide cap and invest program to support greenhouse gas emissions reductions in the state”.  Unfortunately, the basis for this legislation is flawed because its authors do not understand what makes market-based emission reduction programs work.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. I have worked on every emissions trading program affecting electric generating facilities in New York since 1990 including the Acid Rain Program, Regional Greenhouse Gas Initiative (RGGI), and several Nitrogen Oxide programs since the inception of those programs. I also participated in RGGI Auction 41 and successfully won allowances which I held for several years.  I follow and write about the RGGI cap and invest CO2 pollution control program and New York carbon pricing initiatives so my background is particularly suited for evaluating the NYCI proposal and this proposed legislation. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions 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 (CAC) was responsible for preparing the Scoping Plan that outlined 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  NYCI is an example of a program that is taking longer to develop than is consistent with the mandates.

Capital Tonight Interview with Kelles

Susan Arbetter interviewed Kelles about her legislation on Capital Tonight.  The description of the interview stated:

New York state Assemblymember Anna Kelles has introduced legislation that serves as an alternative to the state’s emerging cap and trade system.

Cap and trade is a program used to help meet climate goals by capping pollution and then authorizing tradable allowances between companies, creating a new market.

New York is currently creating a cap and trade system under its 2019 climate law.

Assemblymember Kelles is carrying legislation that would transform this system into what she’s calling a “cap and invest” system. She joined Capital Tonight’s Susan Arbetter to discuss her bill.

The video for the interview is embedded in the description.  Arbetter introduced the interview with a slide “Cap and Trade” that made the following points:

  • Caps emissions in New York
  • Emissions credits for sale
  • Companies can sell emissions credits for profit
  • Proposal would reinvest revenues of credit sales in climate projects

Arbetter claims that the Kelles legislative proposal would make the market-based system a cap and invest program.  There is disconnect here.  The NYCI proposal is a cap-and-invest program as I have described previously.  The program will cap emissions in New York.  The permits to emit a ton of GHG emissions, known as allowances, will be distributed primarily though auctions.  The proceeds will be used to invest in projects that reduce GHG emissions and prioritize investments in “frontline disadvantaged communities”.  Arbetter’ s statement that companies can sell the allowances for profit is technically true, but the reality is that the affected companies buy what they need for their own compliance and do not purchase allowances at the auctions to play the market for profit.  On the other hand, there are no limits to participation in the proposed NYCI design so traders can purchase allowances and try to make profits.

Arbetter asked Kelles what she was not happy with in the proposed NYCI design. The first reason she gave was that “instead of what we agreed to in last year’s budget to create a cap-and-invest program this is instead a cap-and-trade program”.  As noted previously, the state plan is a cap-and-invest program.  I think her mis-conception is that NYCI allows trading of the allowances, so it is “cap-and-trade”.  NYCI also allows entities to bank or carry over unused allowances between compliance periods. 

The Kelles legislation includes the following that upends the approach used in all previous market-based emission reduction systems:

§ 75-0123. Use of allowances.

1. Allowances must be submitted to the department for the full  amount of greenhouse gas emissions emitted during a given compliance period. If greenhouse gas emissions emitted during a given compliance period exceed allowances submitted for such compliance period, such shortfall shall be penalized pursuant to section 75-0129 of this article.

2. Any allowances not submitted at the end of the compliance period in which  they  are  issued by the authority shall automatically expire one hundred eighty days after the end  of  such  compliance  period  if  not submitted prior to such date of expiration.

3. Allowances shall not be tradable, sellable, exchangeable, or otherwise transferable.

In addition to these limitations in NYCI there is a three-year compliance period and in the Kelles legislation there is a one-year compliance period.  These differences destroy the flexibility that has made market-based emissions control program successful.  All programs include penalties if an affected source is unable to surrender an allowance for each ton emitted.  The limitations that allowances not used expire and that allowances “shall not be tradable, sellable, exchangeable, or otherwise transferable” are incompatible with previous programs and would be unfair to market participants.

The NYCI proposal builds on the experience of RGGI which New York State claims has been successful and has worked for market participants.  NYCI offers the allowances in quarterly auctions and compliance is for a three-year period.   Participants in the program will develop a bidding strategy to purchase the number of allowances that they expect to use during the compliance period.  Experience in the RGGI cap-and-invest program showed that a three-year compliance period enabled affected sources to effectively match their allowance needs with their emissions.  Because GHG emissions are closely tied to energy use, emissions vary with weather conditions with more emissions and allowances needed in hot or cold years and less in average conditions.  The ability to bank and trade allowances enables entities to correct their projections and account for inter-annual variation.

In the Kelles proposal if each individual source did not match their allowances purchases based on projected operations to their actual emissions, then they would be stuck with excess allowances that they cannot sell or trade and will expire.  That is an unfair approach.  In the first place, allowances are purchased in lots of 1,000.  The odds of any source emissions being in multiples of 1,000 is nearly zero and many sources total emissions are less than 1,000.  As it stands now, a company with multiple sources purchases allowances for them all and allocates them to individual accounts for compliance.  This practice would be outlawed by the prohibition on trading. Many participants rely on emission marketers who purchase allowances at auction for resale or facilitate trades between those companies that have excess allowances and those that need them.  Small companies rely on these marketers for their allowances because they don’t have the expertise to participate in the auctions.  The RGGI cap-and-invest approach enables flexibility that makes compliance cost-effective.

Another issue that Kelles said she was not happy with is that NYCI “creates an extensive secondary market”.  One example she gave was that the limit on the number of allowances purchased is 25% so you “could have a situation potentially where only four entities own all the allowances” and they could exert market control and sell them for profit.  This has been an on-going concern with RGGI, but they included a market monitoring component expressly to address the concern.  RGGI started in 2009 and the problem has not come up.  NYCI proposes to use the same mechanism.

Kelles also said that her legislation would shift the emphasis to investments rather than profits which she wants to see.  When you look at a market-based emissions system from the outside, the activist community that is providing information to Kelles only see dollar signs and believe that somehow industry is profiting from the program at the expense of consumers.  I also think that academics have contributed to this perception because they believe that the allowances are treated as marketable commodities by the compliance entities.  In reality, entities affected by these emissions trading programs prioritize compliance above all and rarely treat the allowances as a source of profit.  It is simply wrong to think of these programs as evil because there are some profits involved.  Those profits incentivize the flexibility that in the big picture reduces overall costs.

The activists who are influencing Kelles rank protections to disadvantaged communities very high.  There are very few examples where emissions market programs have adversely affected those communities and most studies disagree.  The bigger problem with this concern is that market-based emissions programs are not designed to address local issues.  Kelles said that emitters are predominantly in disadvantaged communities, and it is “necessary to reduce the GHG emissions that are negatively impacting those communities”.  Greenhouse gases do not have direct health-based air quality impacts so activists use co-pollutants for the adverse impacts claims.  That ignores the fact that there are programs in place designed to address co-pollutants emitted by sources in disadvantaged communities.  Clearly the reason we are reducing GHG emissions is to influence global climate change so claiming negative local impacts is a stretch.  Moreover, it is necessary to put what we can do to affect climate change impacts in context.  In 2021 CO2 emissions in the Chinese energy sector increased by 400 million tons. Total New York GHG emissions for all greenhouse gases and all sectors in 2021 were 268 million tons so eliminating New York emissions  Anything we do will be completely replace by emissions elsewhere in less than a year.

Kelles also stated that she was not happy that NYCI is considering not obligating the electricity sector to participate in NYCI.  She suggested that because there are power plants in disadvantaged communities that not including them eliminates the ability to protect residents there.  I believe that the decision to exclude the electricity sector at the start is a practicality issue.  They already are covered in RGGI and the agencies do not have sufficient resources to include them and everything else at the same time.  My impression was that the electricity sector will be added later.  With respect to her concern about the power plants in disadvantaged communities that whole issue is a contrived artifact of environmental justice activists.  The presumption of egregious harm from power plants in disadvantaged communities is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends.

There also was a discussion of the emissions intensive and trade exposed industries provisions.  These are industries that will be put to disadvantage when they try to compete against companies outside New York that do not have the NYCI costs.  Kelles claims that her plan is to encourage them to transition to renewable energy infrastructure without acknowledging the competitive implications of that transition.  I frankly have not followed the particulars of this aspect because I think it is hopeless.  There will be inevitable increased costs and, at some point, industries will not be able to compete.  The Business Council of New York memo in opposition to the legislation addresses these concerns.

Discussion

I am going to limit this article to the issues raised in the Arbetter interview.  There are some other examples where the poor understanding of components of these programs that led to the success of previous programs will be hampered or destroyed by this legislation.  The examples included are sufficient to show the legislation is flawed because its authors do not understand what makes market-based emission reduction programs work.

First, and foremost, market-based emission reduction programs are trading programs.  The ability to buy, sell, or trade allowances and bank them for later use enables the flexibility that makes these programs a cost-effective solution.  Eliminate them and there is no assurance that they will work like previous programs.

NYCI is called a cap-and-dividend program because the primary way that allowances will be distributed is through an auction.  The proceeds from the auction are the dividends that will be invested to reduce emissions and minimize impacts to disadvantaged communities of the inarguably regressive energy costs necessary to implement the zero-emissions by 2040 Climate Act mandate.

In my opinion, the guardrails around the allowance costs are so inflexible that NYCI is basically a carbon tax.  The Kelles legislation would remove any pretense that the program is anything but a tax.  There are some advantages to that and some disadvantages too but I think that if there is any legislation is passed it should be to set a carbon tax because that is the responsibility of the legislature.

There is no question that disadvantaged communities have had disproportionate historical impacts.  However, cap-and-invest programs are not the appropriate tool to protect them and reduce their environmental impacts because cap-and-invest programs are designed for regional and global pollutant reductions.  There are regulations in place that address local impacts and the Department of Environmental Conservation is implementing additional regulations to strengthen and enhance those safeguards.  The demands of environmental justice activists that have influenced this legislation unfortunately demand zero impacts without any consideration of pragmatic tradeoffs.  For example, the focus on peaking power plants ignores the vital role those facilities play to keep the lights on despite results that show that the alleged impacts are over-stated.

Conclusion

The fundamental flaw in the Climate Act is the presumption by its authors that getting to net-zero emissions was only a matter of political will.  There never has been an open and transparent feasibility analysis to clearly account for the necessary costs and threats to system reliability but all indications are that this cannot work as outlined in the Scoping Plan.

On the other hand, the NYCI proposal builds on the existing RGGI model.  That program has shown how a cap-and-invest program can ensure compliance and raise money for investments fairly.  The Kelles legislation ignores the factors that made RGGI work and eliminates them.  That will ensure that the program does not provide any pretense of cost-effective reductions.

The presumption of the Hochul Administration and the Kelles legislation is that a cap-and-dividend program will work as well as previous programs.  I think the real debate should be whether that is a justified position because I think the differences between the ambition of this program and previous programs is far greater.  When the results of previous programs are considered the odds that NYCI will work as hoped are not very good.

Roger Pilke, Jr – Bullish on Solar

I have great admiration for Roger Pielke, Jr and his work on addressing climate change.  However, his recent post explaining why he is bullish on solar does not stand up to his usual standards.  This post explains why I disagree with his optimism for solar in the context of New York’s net-zero transition.

I have followed the Climate Leadership & Community Protection Act (CLCPA) since it was first proposed, submitted comments on the CLCPA implementation plan, and have written over 400 articles about New York’s net-zero transition. I am convinced that the CLCPA will adversely affect affordability, reliability, and that the environmental impacts of the proposed transition are greater than the possible impacts of climate change.  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.

Overview

The CLCPA established a New York “Net Zero” target (85% reduction in GHG emissions 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 CLCPAion Council (CAC) was 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. 

I have documented issues with New York’s solar energy rollout and its issues.  The Scoping Plan uses unrealistic estimates of the energy that can be produced by solar in New York so the estimate that New York will need 18.9 GW in 2030 and 43.4 GW in 2040 of solar capacity are too low.  There is no policy in place to protect prime farmland from utility-scale solar development and over 8,000 acres of prime farmland have been lost.  The last cumulative environmental impact assessment did not address the total solar capacity that is now expected.

Bullish on Solar

Pielke’s blog post gave three reasons why he is “very bullish on solar energy technologies — solar is scalable, solar is cheap and getting cheaper, and solar is safe, simple, and popular.”  I am not bullish on solar for reasons that Pielke mentioned but did not follow through on.  Importantly my primary concern is New York’s Climate Act net-zero transition and some of his caveats are inapplicable to New York.  Pielke does not quality his bullishness relative to any geographical limitations. 

First, I want to explain my overarching concern.  My Climate Act issues are related reliability when the system depends on weather-related wind and solar for most of the electric power generation as outlined in the Scoping Plan.  Electric system resource adequacy planning must address the worst-case conditions and this challenge is made more difficult when intermittent wind and solar resources are used.  While Pielke recognizes the challenge of extended periods of low solar availability, I do not think Pielke’s enthusiasm for solar considers this challenge enough.

Scalable Solar

Pielke argues that solar can be installed incrementally from rooftops to massive utility-scale arrays.  He points out that “in the U.S., the Energy Information Agency (EIA) reports that about one third of solar generation comes from small-scale solar (defined as less than 1 MW capacity)”.   This gives unquestioned flexibility for the development of resource capacity but that comes at a system reliability cost.

The New York Independent System Operator (NYISO) is responsible for matching generation with load.  Small-scale solar is “behind the meter” and cannot be controlled by the electric system operator.  Instead, they analyze its capacity to reduce the load from those locations that have solar installations.  The problem is that this capability fluctuates and cannot be always relied on.  For example, roof top arrays can be affected by accumulated snow and the NYISO has no idea how much that will affect load in the winter.

The other scalability issue is that solar resource value is geographically limited.  What works in low-latitudes and “sunshine” states will not work as well in New York’s high latitudes and cloudy regions downwind of the Great Lakes.  In the worst case a solar array above the Arctic Circle may work well in the summer but is useless in the winter.  New York is not as bad but, in the winter, the solar resource is much reduced and the NYISO does not count on any solar for the diurnal peak.

Solar Affordability

I am a big fan of Pielke’s work and have included his Iron Law of Climate Policy as one of my pragmatic environmentalist principles.  He argues that it is appropriate relative to solar energy:

The Iron Law of climate policy means that it is difficult to motivate an energy transition by intentionally making types of energy appreciably more expensive. But is also means that when clean energy becomes cheaper, it readily gobbles up market share, eventually displacing dirtier and more expensive energy.

He includes a graph of the cost of solar modules with time that shows the module costs have declined 99.6% since 1976.  Not mentioned is that solar modules lose efficiency over time and that their expected lifetimes are half those of conventional fossil plants.  Pielke argues:

The low costs of solar energy, which are positioned to drop even further, has led some in the U.S. to question — quite fairly — why federal subsidies for wind energy are necessary today and far into the future. With or without U.S. subsidies, solar costs should be expected to continue to drop, motivating further deployment, which will lead to greater reductions in costs — a virtuous cycle.

I am worried about how solar energy can be used for the New York Climate Act net-zero transition, specifically the intermittency.   Pielke acknowledges the issue:

Even if solar were free, the technology will always have an intermittency problem when the sun doesn’t shine. The New York Times explained last week that massive battery storage can smooth over demand, but it cannot address intermittency with today’s technologies:

Today’s lithium-ion batteries typically only deliver power for two to four hours before needing to recharge. If costs keep falling, battery companies might be able to extend that to eight or ten hours (it’s a matter of adding more battery packs) but it may not be economical to go far beyond that, said Nate Blair, an energy storage expert at the National Renewable Energy Laboratory.

That means additional long-duration storage technologies could be needed. If California wants to rely largely on renewable energy, it will have to handle weeklong periods where there’s no wind and little sun. Another challenge: There’s far more solar power available in summer than in winter, and no battery today can store electricity for months to manage those seasonal disparities.

I have three problems with claiming that solar is cheap and getting cheaper while ignoring the storage costs.  Storage for solar is needed on different scales.  As noted, there is a difference between summer and winter but there is even a daily difference.  The expected annual output of solar is on the order of 25% of the total which means that a system to provide 100 MW of constant energy would need to overbuild solar to 400MW of capacity and roughly 300 MW of storage.  That is the average annual need and when the worst-case long duration solar drought is considered energy storage becomes impracticable so a new dispatchable emissions-free resource is needed. In the real world, it is even more complicated, and every complication adds more capacity requirements.  All these considerations add to the costs and are not considered by Pielke.

My second problem is that as Pielke notes today’s technology cannot address intermittency.  His solution is pragmatic but not applicable to the Climate Act transition to zero-emissions electricity:

As solar gets cheaper, it will see continued expansion, but accompanying that expansion will be the associated costs of reliable back-up generation, which today means natural gas. Even though natural gas is a fossil fuel, the expanded use of solar backed up by gas has considerable potential to reduce emissions, especially in places where that combo displaces coal generation. The low costs of solar mean that we should expect to see more such displacement.

The third problem is that solar and energy storage are inverter-based resources.  It turns out that solar, energy storage, and wind do not provide ancillary services needed to maintain the electric grid.  If you have no idea what I am talking about I recommend the Practical Engineering  You Tube channel video Connecting Solar to the Grid is Harder than You Think

New York’s aspirational goal is to eliminate fossil-fueled generation so natural gas backup is off the table.  Even if natural gas backup were a potential solution, cost projections should consider all the costs of solar plus energy storage versus just using natural gas and nuclear.  At some point a solar plus natural gas backup system will need new fossil generating units.  That approach would necessitate over-built solar, energy storage, ancillary support services, and backup natural gas resources.  If you just used natural gas you eliminate all those other components.  However, using natural gas for baseload electricity is a waste of this valuable resource.  Nuclear is a great zero-emissions baseload resource but has some deficiencies that are best resolved using natural gas units.  In my opinion, a full life cycle analysis that incorporates the life expectancies of the resources would show that renewables would be the more expensive option and also require development of new resources.

Solar is Safe, Simple, and Popular.

Pielke’s argument for safety relies on a review by Our World in Data that finds that the safest source of energy production, as measured by deaths per terawatt-hour of production is solar.  His arguments for simple and popular follow:

Searching Google Scholar, I have not been able to find a single paper addressing fears of solar energy. There are of course concerns about solar supply chains, solar waste, and risks to solar installations but these issues are common across all energy technologies.

A 2023 survey by Glocalities of 21,000+ people in 21 countries found solar energy to be the most favored energy technology, and overwhelmingly so, with 68% favoring solar over other technologies, as shown in the figure below.

The strong public support for solar and lack of public fears mean that among energy technologies, solar has strong political tailwinds that are unique in the energy space. Correspondingly, the ongoing expansion of solar generation will face much less opposition than proposed new wind and nuclear.  Of course, the fact that effective solar deployment also means more gas back-up may result in greater opposition in the future from those who believe that we can just stop fossil fuel use.

Compared to solar energy technologies, wind technologies appear like a convoluted series of Rube Goldberg devices. To be sure, modern wind turbines are a testament to human ingenuity and technological prowess. But they are also massive installations with many moving parts often exposed to harsh conditions — offshore wind in particular. Solar technologies are elegantly simple in comparison.

I cannot document anything different.  Anecdotally however, the “not in my backyard” folks are not enamored when a utility-scale solar development is built nearby.  Given the space requirements for solar energy that is no small consideration.  I do not disagree that in comparison to wind technologies solar is simpler but the additional technologies necessary to integrate solar to the grid are anything but simple and untested at commercial scale to boot.

Discussion

After years of research and study of the challenges of wind, solar, and energy storage I have evolved away from any support for those technologies in anything but niche applications.  Ultimately, relying upon weather-dependent resources necessitates unacceptable risk.  The weeklong periods where there’s no wind and little sun  mentioned earlier introduces tradeoffs not present in the existing electric system.  After decades of experience with the components of the existing electric system the electric planners at the NYISO and other regional operators have a very good understanding of resource availability.  The key point is that they do not have to worry about correlated outages across the electric system.  In the future, relying on wind and solar means that there will be correlated periods across vast areas when wind and solar resources are low.  Furthermore, those periods correspond to the highest load demands at the same time the Climate Act wants to electrify everything possible. 

The proposals for electric system resources in New York call for enormous additions of wind, solar, energy storage, and the as yet unidentified dispatchable emissions free resource.  Just building it is an enormous challenge.  The video Connecting Solar to the Grid is Harder than You Think notes that there are poorly understood aspects of the inverter-based resources on the grid.  Despite my admiration for the capabilities of the electric planning community, the fact is that they will be in a steep learning curve and the odds favor learning by experience.  That experience means blackouts.

That is not the worst of it.  It is well recognized now that the long duration wind and solar droughts is a massive problem.  However, what is not clear to many is the scale of the problem.  In my opinion, the most dangerous future period will be an immense polar vortex that covers most of the North American Interconnect.  In that case there will be no imports from where the wind is blowing, or the sun is shining.  The problem is that you cannot build an electric system based on a one in fifty-year return period because the resources can never be paid off.  But it will happen and when it does electricity will run out.  Inevitably there will be a massive blackout that endangers the health and safety of millions of people. 

I believe that the pursuit of zero-emissions electricity is a mirage.  To justify this transition imaginary benefits are conjured up but the immense costs of trying to do it will be real.  The conjured health benefits will be dwarfed by real deaths when there is no heat, no transportation, and no lights during the coldest period of the year.

Conclusion

Pielke’s optimism for solar neglects key considerations.  There are geographical areas and niche applications where it may make sense to rely on solar.  New York’s high latitude and cloudiness is one location where it does not.  I do not disagree that it is scalable and safe.  His arguments for solar cheapness ignore the expensive challenge to integrate solar energy into the electric grid when and where it is needed.  Full consideration of the ancillary services requirements suggests that it will not be simple either.  When enormous tracts of land are covered up with solar panels I think that its popularity will wane.  I am not a New York solar energy optimist.

NY HEAT is not so hot

According to New York climate activist non-governmental organizations New York is “failing to lead on climate.”   These organizations are lobbying very hard for the New York Home Energy Affordable Transition Act, or NY HEAT, legislation currently being considered.  I recently described Rich Ellenbogen’s response to Sane Energy Voice claims that NY HEAT Act should be enacted.  This post documents additional op-eds that argue this legislation not a good idea.

I have followed the Climate Leadership & Community Protection Act (CLCPA) since it was first proposed, submitted comments on the CLCPA implementation plan, and have written over 400 articles about New York’s net-zero transition. I am convinced that the CLCPA will adversely affect affordability, reliability, and that the environmental impacts of the proposed transition are greater than the possible impacts of climate change.  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.

Overview

The CLCPA established a New York “Net Zero” target (85% reduction in GHG emissions 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 CLCPAion Council (CAC) was 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 outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  NY HEAT is an example of Climate Act legislation.  Not surprisingly, implementation is falling behind as the difficult challenges are addressed.

NY HEAT

According to Environmental Advocates of New York:

The purpose of the bill is to give the Public Service Commission the authority and direction needed to align gas utility regulation and gas system planning with the Climate Leadership and Community Protection Act (CLCPA) mandates. Overall, the bill removes the legal basis and subsidies driving the expansion of gas systems and requires the commission to adopt rules and develop a statewide gas service transition plan that is consistent with decreasing gas reliance and, where appropriate, decommissioning gas systems.

Fossil fuels burned in buildings for heating, hot water, and cooking account for approximately one-third of greenhouse gas emissions in New York State. Additionally, heating and cooking with fossil fuels like natural gas quietly impact our indoor air quality, contributing to cases of asthma and heart disease.  The Public Service Law, as is, promotes gas system expansion in its stated obligation to serve customers and its business model. This undermines the important climate justice directives and binding emissions limits in the CLCPA. Instead of letting this incompatibility issue continue, this bill better aligns the rules and business practices of the Commission with reduced gas reliance, transition to more sustainable utilities, and prevents energy bill burden among low-income ratepayers.

The bill makes several amendments to the Public Service Law. One of which includes directing the Commission to integrate “the utility sector achievement of the CLCPA” as a core planning objective to its public service responsibilities. Notably, this bill codifies the state goal that low-to-moderate income customers must be protected from bearing energy burdens greater than 6% of their income, including those burdens imposed by the cost to purchase and operate electric equipment.

The overarching problem with NY HEAT is that it is another piece of energy legislation drafted by climate activist non-governmental organizations and pushed by gullible politicians.  The biases of these constituencies and their lack of technical expertise has led to the situation where New York is mandated to meet an aspirational schedule that can only be met by revoking the laws of physics.  Energy policy should not be dictated by politicians and NGOs that have no responsibilities for their actions.

Alternate Views from the Real World

This post provides three op-ed pieces that provide other reasons that NY HEAT is inappropriate.  On Sunday May 12, the New York Daily News published pieces by NY State Senator George Borrello and one co-authored by Richard Ellenbogen and myself.  Last week Dennis Higgins had another opinion piece published by All Otsego.

Senator Borrello’s paywalled opinion was titled: Don’t raise the N.Y. HEAT Act: We have to be honest about energy costs.  Borrello represents the 57th state Senate District which includes Cattaraugus, Chautauqua, Genesee and Wyoming counties, as well as a portion of Allegany County. He is also a member of the Senate Energy Committee.  He stated:

The failure of climate-related items to pass in the “Big Ugly” of the New York State budget was no accident. Reason prevailed among pragmatic lawmakers, and reality set in that the New York Home Energy Affordable Transition Act (NY HEAT) would have placed New Yorkers at risk and wreaked havoc with reliability and affordability.

However, advocates have regrouped and are waging a media campaign, arguing that NY HEAT is necessary to “save New Yorkers billions every year,” trying to confuse the public and pressure lawmakers into passing this horrendous piece of legislation. We cannot let ideology and a radical climate agenda override facts and real progress.

Unfortunately, false and misleading claims about the cost savings that New York ratepayers would realize under the NY HEAT Act are everywhere. Those perpetrating this narrative conveniently ignore the costs to New Yorkers that will come with a mandated conversion to an all-electric future for the state. These advocates also sell their drastic, one-size-fits-all solution as the only path forward.

The fact is, there is a more balanced approach that addresses pollution and environmental concerns without threatening safety, reliability, and affordability. The balanced approach clearly works: our state is already one of the greenest in the nation, ranking seventh in renewable-sourced electricity generation. Much of the credit goes to hydroelectric power, which supplies 21% of New York’s total in-state power generation.

While the HEAT Act would end the 100-foot rule requiring utilities to connect new customers within 100 feet of an existing gas pipeline, it should be noted that utilities are already taking steps in this direction. They are proposing provisions that would allow them to voluntarily make determinations on new service connections based on relevant factors.

While we all recognize the value in pursuing a cleaner energy future, we must acknowledge that utilities have a legal and moral obligation to replace aging pipe infrastructure to ensure safe, reliable service to all their customers and the communities they serve. Claims by advocates that the maintenance of natural gas infrastructure is a burden on ratepayers that would disappear under the HEAT Act are disingenuous, at best.

The reality is that ratepayers already subsidize the maintenance of all utilities — electric, water, and sewer. Utility maintenance costs will not disappear if the HEAT Act is enacted. Additionally, many of the cost estimates being cited for critical maintenance of gas infrastructure are grossly inflated, which only serves to further mislead the public.

The real factors fueling utility rate increases are largely driven by government. More than 70% of the bill for the average ratepayer is the result of the following: federal and state pipeline safety mandates, property tax increases, expanded energy efficiency programs, supports for low-income customers, state-mandated purchases of costly wind and solar energy, increases in the cost of capital, supply chain shortages and inflation.

The replacement of pipes, while a regulatory mandate, is not a major driver — and those costs are just a fraction of what’s to come once the impacts of renewables and new transmission lines hit customer bills later this decade.

Finally, NY HEAT Act advocates are conspicuously silent about the fact that electrifying homes is many times more expensive than pipe replacement, and residents often bear those costs on their own.

According to a recent analysis, electrifying just one co-op in Brooklyn took four years and cost nearly $1 million. Even with rebates, that comes out to $40,000 per apartment, and residents are now responsible for the full cost of heating their homes, rather than sharing costs with the entire building. The cost to operate those electrical systems to heat homes will cost more on a monthly basis than to heat that same home on natural gas.

The reality is that the most fervent advocates of New York’s aggressive climate agenda believe that no cost is too great to address the climate crisis. That is why they misrepresent the facts and mislead New Yorkers into believing a transition to all-electric will save them money. The truth is that New Yorkers are in for a far costlier and less reliable energy future if proposals like the HEAT Act are adopted.

Rich Ellenbogen and I had an op-ed published next to the Senator’s.  The title of our paywalled piece was “Don’t raise the N.Y. HEAT Act: It threatens the safety of all New Yorkers”.  We wrote:

The New York Home Energy Affordable Transition Act, or NY HEAT, is before the Legislature now. However, until questions regarding its feasibility, affordability, and reliability are answered, the HEAT Act should be allowed to lay dormant.

The Climate Leadership & Community Protection Act (NYS’s climate law) mandates that the electric grid be 100% zero emissions by 2040, and the law’s scoping plan projects that by 2040 more than 60% of the capacity and more than 69% of the energy will come from wind and solar.

This total transformation of New York’s energy production and use is being undertaken in spite of the fact that no jurisdiction anywhere in the world has yet succeeded in raising the percentage of the supply of electricity to its grid from wind and solar — beyond about 50% of total supply — on a consistent basis.

The reason for these limits is because both wind and solar are intermittent and therefore unreliable. As a result of these realities, the state Public Service Commission is considering what new technologies must be developed to address those coldest and hottest periods where there will be insufficient generation from existing wind, solar, and energy storage technologies.

Unfortunately, there is no commercially available technology that can be deployed in sufficient quantities today for this reliability requirement. As a consequence of these facts on the ground (and in the air), it is prudent for New York’s decisionmakers to determine the technological feasibility of the zero emissions transition before passing NY HEAT.

The Empire Center’s recent Green Guardrails describes why the Climate Law implementation plan is flawed. It notes that “The process that has played out in the five years since the law’s passage has been marred by a lack of transparency, with state officials failing to issue legally required cost estimates and crucial studies designed to guide state energy policy.” Before the state passes NY HEAT, a full, transparent accounting of all the costs, benefits, and emission reductions for the proposed control strategies is necessary.

It is premature — and unquestionably dangerous — to mandate the additional electrification requirements of NY HEAT. The mandate to deploy massive amounts of wind, solar, and energy storage resources, and simultaneously upgrade and expand the distribution and transmission systems, means that an enormous quantity of transformers, wires, and generating equipment will be required.

There already is a shortage of transformers which will inevitably get worse and spread to other infrastructure components. Even if the hardware is available, there is insufficient labor to execute the plan. There is also a shortage of both electricians and plumbers, and there are not enough people to train even if they could develop the training programs. Without these new resources, current reliability standards of the electric grid cannot be maintained.

NY HEAT removes the “obligation to serve,” a regulation that requires utilities to offer natural gas to any customer who requests it; and the bill also enables the network to be decommissioned in favor of neighborhood-scale electrification. In addition, it will codify a goal of protecting residential customers from paying more than 6% of their household income for energy bills.

When NY HEAT eliminates the obligation to serve, and enables the decommissioning of existing gas systems, it eliminates consumer choice and does not acknowledge — as the state’s scoping plan to implement the Climate Law does — that not all homes will be able to electrify home heating safely and affordably.

A political mandate to decommission a gas network is a drastic step that should only be undertaken until the full ramifications of New York’s total energy transformation is understood. Otherwise, we risk jeopardizing the safety of all New Yorkers.

Lastly, the HEAT bill’s proposal to limit energy bills to no more than 6% of a household’s income is an inadequate energy poverty safeguard. It does not cover household costs: to replace existing home heating equipment with the preferred heat pump alternatives; to upgrade building shells to eliminate or minimize the time that backup heating systems will be needed; to pay for backup heating systems if needed; or to pay for the upgrades to the electric service for the household to cover the increased electric load when the entire household is electrified.

The shortcomings of the HEAT bill are to some extent a product of its authors’ faulty assumptions, but they are exacerbated by the even more unrealistic and unachievable goals built into the larger Climate Law. Until these issues are properly addressed, we should set aside the HEAT bill because it will simply make a bad situation worse.

The Dennis Higgins article in the All Otsego Partial Observer was titled HEAT Act Nothing But a Hot Mess.  He wrote:

The proposed NY HEAT Act, which would mandate a rapid transition to air-source heat pumps, is yet another toxic plan, currently shunted to the back burner in Albany. Although it did not make it into the budget, with pressure from advocates it could be passed this session. NY HEAT, like its Climate Leadership and Community Protection Act launch pad, runs counter to sound engineering and responsible fiscal policy. What’s wrong with it? Let me count the ways.

A five-ton ASHP unit may cost $9,000.00. Installation in the New York City area would cost as much as the pump, assuming existing panel boxes could support the load. There is currently a shortage of plumbers and electricians to do that work. New panel boxes, wiring, and post-installation repair, combined with labor shortages, would serve to increase costs and undermine any timetable. Further, an ASHP may require 5,000 kilowatt-hours a year. Electric bills are already climbing, as rate-payers finance new transmission lines and utilities deal with gas shortages. For homes and apartments with new pumps, electric bills could double.

The independent system (grid) operator, the NYISO, is projecting a 450-megawatt capacity shortfall in the metro region as early as summer 2025, assuming normal weather conditions and without factoring in NY HEAT’s additional load. With building and vehicle electrification, the NYISO already expects demand to double in the next 25 years. But NY HEAT implementation would require a capacity-constrained grid to deliver lots more electricity in the very near term.

Increased electricity demand would in turn increase the load on every transformer in the state. Transformers would have to be replaced, but—as has been reported on National Public Radio and elsewhere—replacements do not exist. The increases to load would also require replacing transmission lines. This could take decades and would require lots of aluminum. Currently, there isn’t enough aluminum for beverage cans, let alone thousands of miles of wire.

Even ignoring the sluggish pace of buildout and lack of battery support, solar and onshore wind are intermittent and have low-energy density, rendering them unsuitable to support additional demand. Offshore wind will not help. Many of New York’s offshore wind projects were cancelled. Driving bid prices and cancellations, supply-chain and construction hurdles mean significant offshore installation may not happen this decade. The Jones Act prohibits foreign jack ships from installing turbines in U.S. waters. The U.S.’s first Jones-Act-compliant ship, Dominion’s Charybdis, may not be ready until early 2025 and is already booked for Virginia’s 2.6 gigawatt project.

Ultimately, increases in demand from ASHPs—a Micron factory, bitcoin mining, or AI hubs—will rely on our fleet of fossil-fuel power plants. The metro region is currently at capacity, so peaker plants will continue to be needed. Even before the NY HEAT proposal, NYISO indicated that deadlines for closing peakers will need to be extended. Gas supply constraints downstate mean Cricket Valley—a combined-cycle plant in Dover—can’t currently run at full capacity. Compression expansion projects on the Iroquois and Algonquin pipelines may be needed to fuel peakers and big plants at Ravenswood and Cricket Valley, as well as for private homes.

If California is a model for New York, it is also an admonition. California is 20 years ahead of us in solar and wind installations and has about 40 percent intermittent capacity. California can boast a solar capacity factor twice what New York gets and has deserts in which to put the panels. Nevertheless, it has extended deadlines for closing gas plants and, with an EPA waiver, has also built new ones. Even with the largest lithium-ion battery in the world, California can’t store summer solar and had to dump about three terawatt-hours of energy last year. Can New York do better? The state Energy Research and Development Authority’s storage projections would cost hundreds of billions of dollars for batteries that might last 10 years. And if all that storage were fully charged, we could not keep the lights on in New York City—let alone the rest of the state—for one day.

New York currently has only about eight percent renewable capacity. To meet a 70 percent-by-2030 renewable target, industrial solar and wind installed over the last 30 years would have to be multiplied six-fold in four years. There is no reason, beyond press releases, to believe this can happen. Rural opposition to solar and wind buildout has also grown. 2020 Executive Law 94-C established the Office of Renewable Energy Siting to speed up installation. ORES can ignore local legislation and even reasonable environmental safeguards in project permitting. Last year’s budget requires communities to use an assessment formula supplied by Albany, cutting tax revenue by up to 80 percent. As reported (4/30/2024 Times Union), a dozen towns in Schoharie are suing the state over the current assessment model. Combined with eminent domain authority for developers to run wire and poles—in this year’s budget—we can expect significantly more pushback from communities. Environmentalists concerned with preservation of farmland and forest, increasing eagle-and-bat deaths, as well as water supply threats from large wind installations, are also raising their voices.

Who will pay for NY HEAT? The cost of a $672-million bailout for a few of the hundreds of thousands of utility customers currently in arrears will be borne by other utility customers. Every New Yorker will help fund subsidies for industrial solar and wind projects which could gobble up a million acres and yet fail to provide reliable electricity.

It continues to be a mistake to let political appointees and Big Green organizers craft energy policy. CLCPA and NY HEAT do not meet the fiscal or engineering standards needed to shape a reliable, carbon-free grid.

Conclusion

This legislation was passed by both the Assembly and the Senate – remember that next November.  It currently awaits a decision by Governor Hochul.  I urge readers to call 518/ 474-8390 or email the Governor’s office urging her not to sign this legislation.