Global warming, climate change, all these things are just a dream come true for politicians. I deal with evidence and not with frightening computer models because the seeker after truth does not put his faith in any consensus. The road to the truth is long and hard, but this is the road we must follow. People who describe the unprecedented comfort and ease of modern life as a climate disaster, in my opinion have no idea what a real problem is.
Hell done froze. New York Governor Kathy Hochul, a leading contender for Greenest Governor in America, wants to redo their infamous Climate Act because New Yorkers cannot afford it. This is a sure sign that the rapidly rising cost of energy has become a big election issue.
Hell done froze. New York Governor Kathy Hochul, a leading contender for Greenest Governor in America, wants to redo their infamous Climate Act because New Yorkers cannot afford it. This is a sure sign that the rapidly rising cost of energy has become a big election issue.
Hochul’s position kicks off what promises to be a grand show over the next three months. New York State is between a rock and a green hard place. Change the law or do the impossible — their choice.
What set this all off is a court ruling that the Climate Act is in fact a law, not a political promise that can be ignored when convenient. The law calls for an impossible 40% cut in New York’s CO2 and other GHG emissions (from 1990 levels) by 2030.
The 2019 law, which remains one of the most ambitious in the country, gave the state Department of Environmental Conservation (DEC) until January 2024 to issue regulations that would ensure New York meets these binding greenhouse gas emissions targets.
DEC never issued those regs, so a bunch of Big Green groups sued. DEC explained in court that issuing the regulations was “infeasible” because it “would require imposing extraordinary and damaging costs upon New Yorkers.”
The judge simply ruled that the law is the law and gave New York State two choices: change the law or issue the regs. The deadline is February 6, 2026, which gives the legislature a mere month to change the law, since it only starts in early January. Changing a law this big that fast will be very hard.
If the law is not changed, then final regs are due on that date, so they must be working on them now. However, Hochul says they will appeal this decision which might (or might not) drag things out for more months. The confusion is huge.
In any case, the NYS Legislature has to already be looking hard at this. Especially given that rising energy cost is a hot election issue and 2026 is an election year for every legislator. Furious lobbying must already be going on. The holiday season will be very green indeed.
There is a hilarious back story on the electric power side of these fanciful emission cuts. There have been lots of seemingly serious planning documents prepared by New York State electric power offices that are actually fictional.
These so-called plans make extensive use of a fiction called “dispatchable emissions-free resources” or DEFRs. It is acknowledged that DEFRs do not exist — except nuclear, which is not considered. So, there is no actual plan for meeting the Climate Law’s 2030 deadline. It simply cannot be done.
Anyone interested in this electric power fiasco should check out the Pragmatic Environmentalist of New York run by Roger Caiazza here:
Roger has steadily tracked and analyzed the Climate Law electric power nonsense for a long time, including submitting a lot of official comments that have been ignored. Now his warnings are coming alive and out of the Governor’s mouth no less. Congratulations, Roger!
There is also a national version of this story that will play out in slower motion over the next few years. Hochul correctly points out that the end of federal subsidies will make renewables a lot more expensive. Almost all states have climate or renewable mandates requiring a steady shift to renewables. These mandates are about to become a lot more costly to voters, so a lot of laws may change.
In summary, the New York State Climate Law is finally hitting the wall. The Law is the rock, and the impossible regulations are the hard place. Something has to give.
Stay tuned to CFACT as this great green drama unfolds.
In the real world, the climate scam is rapidly falling apart, along with the related government-subsidized schemes for worldwide energy transformation. So how should New York react? After all, we claim to have the ultimate program of “climate leadership” for showing everyone else how easy it is to do this energy transformation thing. We’ve started with mandating under our Climate Act an electricity system having 70% of its generation from “renewables” by 2030 (a mandate known as “70 x 30”). The deadline for 70 x 30 is now just over four years away.
In the real world, the climate scam is rapidly falling apart, along with the related government-subsidized schemes for worldwide energy transformation. So how should New York react? After all, we claim to have the ultimate program of “climate leadership” for showing everyone else how easy it is to do this energy transformation thing. We’ve started with mandating under our Climate Act an electricity system having 70% of its generation from “renewables” by 2030 (a mandate known as “70 x 30”). The deadline for 70 x 30 is now just over four years away.
So, is this really happening? Fortunately, our Public Service Commission has just come out with a Report with the long title “NEW YORK STATE DEPARTMENT OF PUBLIC SERVICE SECOND CLCPA [Climate Act] INFORMATIONAL REPORT ON OVERALL IMPLEMENTATION OF THE CLIMATE LEADERSHIP AND COMMUNITY PROTECTION ACT, WITH CORRECTIONS,” bearing a date of September 23, 2025. Today, I will take a look at that to see what we can learn about New York’s progress toward its goals.
Separately, a different bureaucracy called the New York State Energy Planning Board a couple of months ago (July 25) issued something called the 2025 Draft Energy Plan for the state. I had a post discussing that document back on August 11 (“New York’s Official Energy Plan Is No Plan”). That Draft Energy Plan then became subject to a period for public comment, so I took the opportunity to submit my Comment on September 25.
Let’s say that the PSC’s Report and my Comment on the Energy Plan are two very different takes on the progress toward New York’s energy transformation.
I’ll start with the PSC’s Report. The Report came with a three-page press release announcing and summarizing it. Oddly, the press release does not contain any link to access the Report itself. Instead, if you want to review the Report, you are instructed to go to the Commission’s page for accessing its case documents, where you must then input the correct case number (22-M-0149) in a box provided, and then scroll through the docket entries until you find the Report. Why would they make finding this so difficult? I’ll bet you can guess.
A summary of both the press release and the Report itself is this: a lot of empty talk about all the wonderful plans, without any quantitative information on whether any progress is being made toward the 70 x 30 mandate, or toward any of the various other mandates (including 100% of electricity from zero-emissions sources by 2040, or “100 x 40.”). From the press release:
The New York State Public Service Commission (Commission) today received an update from Department of Public Service (DPS) staff regarding progress toward the clean energy goals of the 2019 Climate Leadership and Community Protection Act or Climate Act. The report details actions taken in pursuit of these ambitious clean energy goals while working to keep ratepayer costs manageable with benefits that are widely shared. . . . The Climate Act’s directives require the Commission to build on its existing efforts to deploy clean energy resources and energy storage technologies, implement energy efficiency and building electrification measures, and support electric vehicle charging infrastructure. This year’s update included: Progress on achieving the targets mandated within the renewable energy program.
OK, so the press release specifically says that the update includes “progress on achieving the targets mandated,” but what exactly does that progress consist of? There’s nothing about that in the press release, so we must go over to the Report itself. The Report is some 63 pages, including appendices. Most of it is about qualitative descriptions of the various schemes (e.g., “renewable energy and energy storage,” “transmission and distribution investment and development,” etc., etc.). Finally at page 37 we get to a section headed “Progress Toward CLCPA Green Energy Targets.” Surely, this is where we will get the quantitative information we are seeking on the progress toward New York’s plans? Here is the entire text of that section:
The subject of this subsection has been covered in depth in the Draft CES Biennial Review. 109
Wait a minute! I thought the press release had specifically said that the PSC Report itself contained an update on this progress. But in fact the update is completely missing. Following that footnote 109, we find out that this CES Biennial Review came out on July 1, 2024 — over a year ago — and must in turn be hunted down on another PSC docket, this one numbered 15-E-0302. This time the Report is some 98 pages long. If we make it to page 53, we find a section titled “The Path to the 70% Goal.”
This section of some 7 pages entirely discusses how many GWh of demand are in the state’s load forecast for 2030, and how many GWh of generation from renewables it will take to produce 70% of that. Excerpts:
Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh.
On page 56 in a Table 8, we find the amount of renewables “operational as of 2022” — 29,289 GWh. That’s barely one-quarter of the 115,437 needed by 2030, and by the way more than half of the 29,289 GWh comes from one source, Niagara Falls, that cannot be replicated. The same table on page 8 indicates that an additional approximately 36,000 GWh of renewable generation, consisting of onshore and offshore wind and solar, has been “contracted” by 2024. After substracting a few small miscellaneous items, they come up with a “gap to 70% (2030)” of 42,145 GWh. Then, after further assuming large additions to offshore wind and rooftop solar will provide about half of that, they get to this bottom line:
To achieve this pathway, just over 3,900 GWh of onshore large-scale renewables resources would need to be procured per year, or approximately 5,600 GWh per year with attrition.
Well, in the time since this CES document was issued in mid-2024, all of the off-shore wind has been shot down by the federal government, and all of the federal subsidies for additional wind and solar developments have disappeared. None of the 5,600 GWh per year of additional renewables procurements is in the works. All of this was known and obvious by the time the most recent PSC Report came out on September 23, and yet they don’t mention any of it. I guess they figure that nobody will take the time and effort to track through their references to figure out the problem.
And one more thing: There is not one word in these reports mentioning that wind and solar do not produce electricity at the same time that consumers use it, meaning that there must be storage or batteries or backup of some kind. The entire approach is to assume that if the amount of electricity generated is equal to the amount consumed, the two can be easily matched up somehow, without any issues or costs worth discussing.
In summary, New York’s PSC is entirely engaged in throwing up a smokescreen to obscure the fact that the state’s energy transformation is dead in the water.
Now let’s turn to my Comment on the Draft “Energy Plan.” Although I submitted it a couple of days ago, I can’t yet find it on the website, so I don’t have a link to provide. As an alternative, I’ll provide some extensive excerpts. The bulk of my Comment focused on a chart, Figure 19, appearing on page 22 of a portion of the Plan called the “Pathway Analysis,” purporting to show how the Climate Act mandates, like 70 x 30 and 100 x 40, would be achieved. Here is that Figure 19:
Here are some portions of my reactions to this chart:
Installed capacity of natural gas power plants declines from about 25 GW today to about 15 GW in 2035 – and then completely disappears by 2040. What will keep the lights on 24/7/365 when the natural gas generation is gone? There is no answer here.
In the same Figure, a new generation category called “Zero-Carbon Firm” suddenly appears in 2040, with 17.2 GW of capacity – about three-quarters as much as our entire current fleet of natural gas power plants. They have no idea what this “Zero-Carbon Firm” category might be. Text seems to indicate that they might be thinking about new nuclear or maybe so-called “renewable” gas from landfills. In fact nuclear is completely blocked in this state, although Governor Hochul has supposedly started a process to build one 1 GW nuclear plant starting now. That plant has not even yet gotten to the stage of site selection, and will not possibly be ready by 2040 even if construction started today. And it is also only 1 GW, when the “Energy Plan” is saying that 17.2 GW of “Zero-Carbon Firm” is needed by 2040. And landfills can produce only a tiny fraction of the gas they are talking about here, while meanwhile the Pathway Analysis admits elsewhere (see page 14) that this supposedly “renewable” gas does not count as zero-emissions under the Climate Act.
Professor Lindsay Anderson of Cornell did an analysis of the New York electricity system, which found that if natural gas generation was eliminated and demand increased as projected, the actual amount of firm emissions-free resources needed to meet the state Climate Act mandates would be about 37 GW of capacity. NYISO analysis of the same issue comes up with a requirement 35 GW of firm emissions-free generation. Where did the Energy Plan come up with the ridiculously low figure of 17.2 GW? I guess it doesn’t really matter, because the “firm emissions-free resource” is just magical thinking anyway, and does not exist in the real world.
The same Figure shows a massive increase in capacity of solar generation, from about 7 GW today to supposedly 35.4 GW by 2040. That capacity, if built (it won’t be), will be lucky to generate electricity at 15-20% of rated capacity over the course of a year in cloudy and snowy upstate New York, and will be next to useless to provide electric heat in the winter, when we have 15 hours of darkness per day.
My Comment goes on and on from there. Some concluding lines:
[T]he so-called “Energy Plan” is not an energy plan at all. It would more accurately be described as random musings and wishful thinking by some completely incompetent people who have no idea what they are doing. The so-called “Plan” envisions a future of a fully transformed energy system within the next 15-25 years. Yet it contains no meaningful feasibility analysis, nor any meaningful cost analysis. . . . It’s time to start over, with some people in charge who know what they are doing.
So I think the vision of New York’s politicians and bureaucrats is to put their heads in the sand until this all falls apart, and then try to blame somebody else. We are living at peak absurdity.
A recent article from the Daily Caller News Foundation explained that even New York Governor Hochul has realized that the state’s Climate Leadership & Community Protection Act (Climate Act) is too extreme. This is an update on my related net-zero transition battle to force the state to pause implementation. Hopefully it will inspire similar resistance in your jurisdictions.
A recent article from the Daily Caller News Foundation explained that even New York Governor Hochul has realized that the state’s Climate Leadership & Community Protection Act (Climate Act) is too extreme. This is an update on my related net-zero transition battle to force the state to pause implementation. Hopefully it will inspire similar resistance in your jurisdictions.
Even the most zealous climate activist must admit that there is a limit to how much any jurisdiction can afford to spend to implement an energy transition program to eliminate fossil fuels. Of course, as soon as costs come up, activists conjure cost estimates that claim that fossil-free nirvana will be cheaper and if negative externalities are considered then the cost of inaction is more than the cost of action. That baloney is not the topic of this post.
The fact is that net-zero transitions policies have always been about politics and money, not rational thought. New York’s implementation progress has reached the point where the costs of the transition are too large to ignore.
The Daily Caller article referenced a letter written by Donna DeCarolis and Dennis Elsenbeck, two members of the Climate Action Council that approved the implementation outline for the Climate Act. They requested a hearing with the Public Service Commission (PSC) to consider delaying the state’s climate goals citing several circumstances that warrant a hearing based on Public Service Law (PSL) 66-P that implements the renewable energy program mandated by the Climate Act.
The article also included extensive quotes by New York Gov. Kathy Hochul: “I was intent on becoming known as a strong environmental governor.” She made the remarks in early August, according to local news outlet Spectrum News. “I also cannot ignore the fact that the disruptions in our economy that have occurred since the laws went into place, but also since we even supported this, that need to be examined in terms of what is happening to people’s pocketbooks right now. … I also have to moderate and make sure that I’m not doing something that’s going to drive up costs for consumers, and the data shows at this time it would.” In my opinion, the political machine of the governor has realized they have a problem.
So far there has been no response from the Hochul Administration to the DeCarolis and Elsenbeck letter.
Personal War
My personal fight against the Climate Act consists primarily of articles on my blog and the occasional post here. I have followed the Climate Act since it was first proposed, submitted comments on Climate Act implementation plans, and have written over 550 articles about New York’s net-zero transition. I have also submitted comments in various Public Service Commission proceedings. The primary themes of my comments have been the affordability and reliability risks of a future electric system that relies only on wind, solar, and energy storage and the fact that there is a New York regulation that established boundary conditions for the transition. The PSL 66-P law and the circumstances that warrant consideration of a PSC hearing were referenced in the DeCarolis and Elsenbeck letter.
I have joined forces with Richard Ellenbogen, Constatine Kontogiannis, and Francis Menton to wage war on the Climate Act. Ellenbogen is an electrical engineer who is President of Allied Converters where he has pioneered how “green” manufacturing can work. Constantine Kontogiannis is an engineer who has decades of experience providing energy consulting services. Menton is a retired lawyer and now writes articles at his Manhattan Contrarian blog that are frequently featured here.
We intervened in the Niagara Mohawk Power Corporation (NMPC) dba National Grid and the Consolidated Edison Company of New York utility rate cases. In both cases, we included testimony arguing that PSL 66-p should be considered in the context of the rate case programs included to meet requirements of the Climate Act. The Department of Public Service (DPS) staff response to our arguments boils down to “rate cases are not the appropriate forum to consider limitations of the renewable energy program”.
In response we submitted a filing in a generic proceeding. My compatriots and I believe that when the net-zero transition claims are compared to reality they fail. To prove that is an enormous effort that I described in a post at my blog. In brief, our submittal includes the primary filing, two exhibits documenting the customers in arrears safety valve trigger, and five supporting exhibits. The primary filing argues that Public Service Law Section 66-p(4) contains the aforementioned safety valve provisions. Exhibit 1 – Trend in Company Customers in Arrears documents increasing trends in utility customer payment delinquencies, providing baseline data for the customers in arrears safety valve trigger. I did a separate post providing details of those calculations. Exhibit 2 – Customers in Arrears is a spreadsheet that contains the detailed analytical data on utility arrears across New York’s major distribution companies.
The remainder of the exhibits support the need for the filing, additional circumstances that demonstrate that the broad mandate to ensure access to safe, reliable utility service at just and reasonable rates has not been addressed in the current implementation process, a demonstration that the current approach is actually increasing Greenhouse Gas (GHG) emissions, and a recommendation for an alternative approach. Exhibit 3 – Affordability-Focused Recommendations outlines specific policy recommendations to address energy affordability concerns, including proposals for cost transparency, alternative funding mechanisms, and enhanced low-income programs. Exhibit 4 – Resource Gap Characterization analyzes gaps between CLCPA mandates and available resources, addressing both financial and infrastructure capacity constraints. Exhibit 5 – Dispatchable Emissions-Free Resources explains that the need for a resource that is not currently commercially available risks investments in false solutions. Exhibit 6 – Electrification Increases Emissions presents analysis demonstrating that certain electrification strategies may paradoxically increase emissions. Finally, Exhibit 7 – Alternative Approach proposes alternative implementation pathways that could achieve reasonable climate goals while maintaining affordability and reliability.
Conclusion
The Climate Act is and always will be political theater. New York has never done a feasibility analysis because the politicians and the activists who wrote the law naively believed that the net-zero transition was only a matter of political will. It has always been inevitable that New York’s net-zero transition would collapse because of physics and costs issues that would have been flagged in a proper feasibility analysis. Now that the consequences of ignoring the fundamentals are becoming so evident that they cannot be ignored, the search is on for an excuse to pause implementation. The filing we submitted argues that there are already provisions in place to reconsider the schedule that provides the excuse. When a hearing is held, the ambition of the transition will be exposed to reality as well.
Not surprisingly, there has been no response to our filing. My colleagues and I are plotting ways to get the PSC to respond and spreading the word is at the top of the list. New Yorkers reading this should contact their elected officials and ask them to demand that the PSC respond to our filing and the letter from DeCarolis and Elsenbeck.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.
This is an article primarily by Richard Ellenbogen that estimates projected annual operating costs and emission reductions for New York commercial facilities when the new building codes are implemented. It is also an example of how peer review should be done.
This is an article primarily by Richard Ellenbogen that estimates projected annual operating costs and emission reductions for New York commercial facilities when the new building codes are implemented. It is also an example of how peer review should be done.
Heat Pump Hype
I am a long-time critic of the New York State Energy Research & Development Authority’s (NYDSERDA) biased promotion of all green energy technologies. Their description of cold climate heat pumps is a good example: “Today’s cold-climate heat pumps are a smarter, more efficient option to keep your home comfortable all year long. These all-in-one heating and air conditioning systems are environmentally friendly, extremely efficient, and affordable to operate.” In another example, they breathlessly exclaim that heat pumps outsell gas furnaces for the second straight year. This claim uses national figures and could be solely the result of new building sales that are much stronger in southern states where heat pumps are a cost-effective choice. Ellenbogen addresses the affordability claims below.
Ellenbogen Heat Pump Experience
Ellenbogen installed geothermal heat pumps when his house was completed in 2004. He has 21 years of experience with them and has maintained a database of the performance and costs. His monitoring system includes temperature sensors on the inputs and the outputs of the wells and water flow. Because he uses a geothermal system, he can rely on it even during the coldest periods when air source heat pumps cannot extract enough energy from the air to keep the house warm. Furthermore, his system uses deeper wells than are currently allowed by law that were legal when the system was developed. They are also open loop which greatly increases their efficiency but that is also no longer allowed. In his configuration, his heat pumps can pull 7 tons of heat transfer per well where current geothermal wells are limited to about 2.5 tons per well. As a result, his system can achieve a Coefficient of Performance (COP) of about 5.5 whereas current Geo-thermal systems can achieve a COP of about 3.5 with the restrictions on well depth and having to be closed loop. During long periods of cold temperatures that force the heat pumps to run for extended periods, the well temperatures can drop, and the efficiency of the system decreases so it will use more energy.
One of the things I admire as a techno-weenie is Ellenbogen’s quantitative nature. He built his house “as a science project to satisfy his intellectual curiosity” and it has yielded an enormous amount of data. When the Indian Point nuclear station was operating, he ran a calculation and found his geo-thermal system was about 7% more carbon free than his 95% efficient modulating gas boilers that were originally installed as a backup in case of a power failure. After New York politicians shut down Indian Point the carbon emissions of local electricity increased and the GHG emissions advantage vanished. Given his concerns about GHG emissions he decided to figure out a cost and energy comparison. He turned the heat pumps off this winter and used the duplicate gas system to compare with multiple years of data with the heat pumps operating.
The results are notable. His gas bill went up less than the electric bill went down, and this is for an electric system with an efficiency 57% higher than what can be built now during a colder winter. The electric bill was about $8600 lower than it would have been with the heat pumps operating. The gas bill only went up by $6057 for a net savings of $2543 using the natural gas heating and the current winter has been 120-degree days colder than last year. That figure has been adjusted for the higher electricity prices this year. Note that the heating system is well designed with 14,500 square feet of high mass radiant floors that use 100-degree water in the system and 18 separate zones which makes it even more efficient. The large scale of the system removes measurement aberrations that might occur with a smaller system.
Table 1 shows the delivery of one therm (heat energy equal to 100,000 British thermal units) relationship between the of electric heating costs at different COP values. Even a highly efficient ground source heat pump with a COP of 3.5 is 16% more expensive than a 95% efficient gas system in the Downstate New York area which covers 60% of the state’s population. Also note that air source heat pumps on a very cold day can reach COPs of 1 – 1.5 and easily go below 2. As a result, they can be two to three times as expensive to operate.
Commercial Facility Projection
New York State legislators passed a prohibition on the installation of fossil fuel equipment and building systems starting in 2026 for small buildings and 2029 for larger ones. The prohibition starts in 2026 for new buildings up to 7 stories tall, except for commercial and industrial buildings larger than 100,000 square feet. There are exemptions for certain types of buildings including emergency backup power systems, manufacturing facilities, commercial food establishments, laboratories, hospitals and medical facilities, critical infrastructure (e.g., water treatment plants), agricultural buildings, crematoriums.
Ellenbogen applied the numbers derived from his house experiment to his business and extrapolated them to the 55,000 square foot factory which would fall under the less than 100,000 square foot rule for new construction after 2026. Admittedly, there is no law currently in place that would require a developer who wanted to replicate Ellenbogen’s manufacturing facility because of the exemptions. Eventually, however, the net-zero mandates will require all electric construction of all new facilities and for the replacement of existing equipment before the end of useful life. Therefore, it is a relevant example of Climate Leadership and Community Protection Act (Climate Act). costs.
Ellenbogen’s home has a backup gas boiler heating system, and his manufacturing plant has a combined heat and power system. In 2002 he installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area. This approach generates electricity by burning natural gas. Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.” This approach allows him to recover 70 to 75 percent of the energy content of the fuel and augments a solar array on the roof.
By doing a thermal analysis of his home’s gas usage he was able to determine what would be needed to heat the factory. The end result is that removing gas from his manufacturing facility would raise energy bills to about $147,000, more than doubling them, and raise his carbon footprint by about 15%. The key takeaway is that using the most efficient electric heating/cooling system available, it still means that this gas ban policy will cost businesses in NY state enormously while raising carbon emissions. When and if the Downstate New York electric system reaches zero GHG emissions the carbon emissions will be reduced.
Environmental Impacts
Ellenbogen calculated that because the Downstate electric system is CO2 rate is 950 pounds per MWh according to 2022 EPA data, that the CO2 emissions from using the CHP system are actually less than if heat pumps were used. He also pointed out he has replaced three compressors in his home’s ground source system over the past 21 years and each time the failure resulted in a full loss of refrigerant. He said that it is not preventable and that you only find out when the unit gives a fault code with no early warning.
Discussion
This post is based on three emails from Ellenbogen. I did not include all the calculation details he provided in the originals but will provide them if requested. The reason for the three versions is that the details provided enabled a reader to point out an issue that he corrected. Ellenbogen noted that:
Those damned Laws of Thermodynamics are getting in the way again, but this may be a teaching moment to show what a real peer review looks like and that we have to acknowledge errors to make sure that the best information is in the public space. It also is a clear example of how we can’t escape those Laws in our calculations. Miscalculations introduce errors and a failure to account for the Laws of Thermodynamics entirely when setting energy policy introduces huge errors.
This raises an issue with the implementation of the Climate Act. The agencies responsible for the implementation plans have not provided adequate documentation to enable detailed review of the plan. Even if it is possible to make a detailed comment on an obvious issue, there hasn’t been any acknowledgement of any problem, much less evidence of a revision to the plans. The appropriate peer review process exemplified by Ellenbogen’s analysis is not a feature of the Climate Act stakeholder process. As a result, Ellenbogen notes “errors are apparent across the entire spectrum of NY State’s Energy plan.”
Ellenbogen summarized his peer review concerns in this regard.
While I hate to beat on academia, it has a great deal of responsibility for NY State’s energy mess. A certain University Professor that sat on the Climate Action Council still refuses to acknowledge that all of the technologies for this transition do not exist despite a Public Service Commission conference determining that fact in 2023. Unfortunately, people in the legislature and certain environmental groups have adopted those ideas despite there being known large deficiencies in those theories as it applies to putting them into practice. Untested theories that can’t be put into practice in the “Real World” are dangerous for society. State residents shouldn’t be turned into a science project and that is what is happening.
I received the following response to my email from a retired professor that now works in industry. I have redacted portions to keep them anonymous. While on average, the refrigerant replacement is every 20 years as there are three heat pumps, their observations are profound and are critical to understanding a huge issue now facing the NY State. It follows in italics.
This is the most sobering analysis of a heating system I have ever read. I constantly hear about the miracles of heat pumps, but the carbon footprint is never honestly presented. Plus the replacement of freon every 7 years is never included. Thanks for providing a clear analysis of a day in the life of a NY business and resident.
I’m still enjoying life in XXXXXXXX, and in no longer being a professor. Academia lives in a bubble, and you can’t see that until you leave. Professors need to do a real sabbatical leave in industry and be forced to solve real problems, not problems they dream up. It’s tough out here! I thought I knew something about XXXXXX after XX years as an academic doing research, but XX years at XXXXXXX has shown me I have much to learn. It is stimulating, I’m glad to be here. They need to have a similar experience.
Regarding the statement above, one of the reasons that the carbon footprints of heat pumps is never honestly mentioned is that the loudest voices in the space are the people selling them and other people don’t have enough experience to question the results. I’ve been using them for 21 years. My house was built as a science project to satisfy my intellectual curiosity. It has yielded an enormous amount of data, some of which has been used by the state.
One of the major issues that I have with NY State policy is that many of the people that are hired to do the energy analyses for the government actually work for the manufacturers or other interested parties. The reports read more like advertisements paid for by the NY State taxpayers than a sound scientific document. I dealt with that in a 2020 paper on the Lansing Gas moratorium. The company hired to do the Tompkins County energy analysis sold heat pumps and the resulting report reflected that and had a huge error in its results. The paper is very relevant to the building electrification discussion.
Regarding the professor’s comments, when someone is forced to deal with the consequences of their decisions as occurs in industry, it greatly changes their perspective. There are no negative consequences for someone theorizing about policy on a University Campus and that is okay because it can move society forward. However, if they don’t really test those ideas before pushing them into society as a gospel, there will be huge problems and that is what we are now seeing in NY State.
Conclusion
The ramifications of New York’s Climate Act on business development are becoming evident. In 2026, certain new buildings in New York will no longer be able to install fossil fuel equipment and building systems. Richard Ellenbogen has performed a “science project” that proves that New York’s net-zero transition electrification plans for heating will be more expensive than using natural gas. It is also notable that the experiment was best on a geothermal heat pump system that is more efficient than legally possible today. Adding to the already large energy costs in New York is not a good way to attract and maintain manufacturing in the state.
This exercise also shows the importance of robust peer review. Ellenbogen’s first draft contained an error that was identified because he showed his work. He acknowledged the problem and corrected his analysis. New York’s Climate Act stakeholder process does not document analyses well enough for considered review and the Hochul Administration does not acknowledge any comments that do not comport with their narrative. As a result, the broken stakeholder process in New York will likely ignore Ellenbogen’s real-world results.
Ellenbogen is the President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”. He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies at both his home and business two decades ago.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.
In a post a couple of weeks ago on December 21, I observed that the country of Germany appeared to have won the race among all countries and states to be the first to hit the “Green Energy Wall.” Its pursuit of the “renewable” wind and solar electricity fantasy has put it in a spot where regular wind/sun droughts cause huge electricity price spikes, and major industries have become uncompetitive. It has no solution to its dead end and can go no farther.
In a post a couple of weeks ago on December 21, I observed that the country of Germany appeared to have won the race among all countries and states to be the first to hit the “Green Energy Wall.” Its pursuit of the “renewable” wind and solar electricity fantasy has put it in a spot where regular wind/sun droughts cause huge electricity price spikes, and major industries have become uncompetitive. It has no solution to its dead end and can go no farther.
If Germany has “hit the wall,” what is the appropriate analogy for New York? New York passed its Climate Act with great fanfare in 2019. The Act orders that we are to have a “net zero” energy system by 2050, with interim deadlines along the way. The first serious deadline arrives in 2030, where the official mandate is 70% of electricity generation from “renewables” (aka “70 x 30”). That deadline is now just five years away. Within the past year, all the efforts to move toward the 70 x 30 goal are falling apart, as anybody who had given the subject any critical thought knew that they inevitably would. But nobody in authority has yet been willing to acknowledge that this has turned into a farce.
Here’s my analogy: New York is like the cartoon character Wile E. Coyote, who has run off the cliff and is now suspended in mid-air, apparently not knowing what will happen next.
We know what’s next: shortly, he will crash to earth.
Consider a few data points:
Off-shore wind procurement
The Scoping Plan developed under the Climate Act calls for some 9000 MW of offshore wind by 2035. People with elementary-school-level arithmetic skills knew that this amount of intermittent generation would not be nearly enough to replace the amounts of dispatchable generation set to close; but maybe this would at least be a serious start. By early 2023, it was reported that some 4300 MW out of the 9000 MW were in “active development,” with wholesale prices having been agreed to with developers in the range of $100/MWh.
But then reality started to hit. In this post on October 15, 2023, I reported that “essentially all” of the developers of the 4300 MW of offshore wind in “active development” had backed out and demanded price increases in the range of 30 – 50% to proceed. New York rejected that maneuver but ultimately had no option other than to re-bid the contracts and get bids in the range that the developers were demanding.
On February 29, 2024, the State announced that it had accepted re-bids for two of the projects in question, for a total of only about 1700 MW and at a price of over $150 per MWh. (This level of price would require retail electricity prices in the range of at least $0.40 per kWh and would be completely uneconomic if it were to become the norm for New York electricity production.).
Meanwhile, the remainder of the offshore wind procurement appears to be in complete disarray. On April 19, E&E News reported that New York had canceled efforts on three of its big offshore wind development areas, Attentive Energy, Community Offshore Wind, and Excelsior Wind. These three, had they proceeded, would have totaled about 4000 MW out of the 9000 MW 2035 goal. Excerpt:
New York canceled power contracts for three offshore wind projects Friday, citing a turbine maker’s plans to scrap its biggest machines. The news is a heavy blow to the U.S. offshore wind industry and a major setback for the climate ambitions of New York — and President Joe Biden. The three projects would have delivered 4 gigawatts of offshore wind to the state, amounting to almost half of New York’s 2035 goal.
At this point nobody has any idea how to get large amounts of offshore wind developed around New York at a price anybody is willing to pay. And of course, nobody has a solution to the intermittency problem either.
Green hydrogen
The New York regulators have recognized that a de-carbonized and predominantly wind/solar electricity generation system will require something called the “dispatchable emissions-free resource,” or DEFR, to make it work. The best idea that anybody has for the DEFR is so-called “green” hydrogen, that is, hydrogen produced by some non-emitting system, like wind, solar, or hydro.
Currently, only negligible amounts of green hydrogen are produced in the world, and none in New York. But somehow, New York got the idea that it could make this work. Two green hydrogen facilities have been granted state subsidies and are supposedly under way. One is being developed by a company called Plug Power and is at an industrial park called STAMP west of Rochester; and the other is being developed by Air Products at Massena, on the St. Lawrence River. Both of these facitilities are almost comically small relative to the amounts of hydrogen that would be needed to fully back up New York’s electricity generation in a world of mostly wind and solar generation. But at least they would be something.
Chris Suozzi, VP for business and workforce development at the Genesee County Economic Development Center, reportedly told a Washington, D.C.-based commercial real estate firm that Plug Power’s STAMP project is on hold. . .. “They’re not ready to go,” Suozzi reportedly said. “They’re on pause. We don’t know what’s going to happen with them at this point.”
The pausing or cancellation of a green hydrogen project should surprise no one. The past year has seen major cancellations of much larger such projects by big players like Australia’s Fortescue and Origin. The fact is that the cost of producing green hydrogen is a large multiple of the cost of getting natural gas out of the ground for the same energy content, besides which natural gas is a much superior fuel in every way (higher energy density, easier to handle, less corrosive, less subject to leaks, far less dangerous and explosive, etc.). Meanwhile, the developer of the STAMP green hydrogen project, Plug Power, reported as its results for the third quarter of 2024 a loss of $211 million on revenues of $174 million. They are hoping for a loan from the federal Department of Energy to keep themselves going. I wonder what Chris Wright is going to think about that.
The Air Products facility in Massena plans to use hydro power from a dam on the St. Lawrence to produce its hydrogen. Excuse me? The hydro power is already dispatchable. How can it possibly make any sense to use dispatchable electricity to produce hydrogen whose purpose is to make dispatchable electricity? At least about 40% of the energy is going to get lost on the round trip from electricity to hydrogen and back to electricity. It simply has to be that there is a better use for the St. Lawrence River hydro power than turning it into hydrogen and then using the hydrogen. But nothing here makes any sense.
Clean Path Transmission Line
Another key facility to make renewable energy work for New York was supposed to be the Clean Path transmission line. This is a proposed 175-mile high-capacity (4 GW) transmission line to bring to New York City and the downstate region power generated at various new “renewable” (wind and solar) facilities being developed in the northern and western parts of the state. The stated cost of this major project was to be $11 billion.
I don’t find any discussion about the reasons for the cancellation, but it has to be that the developers figured out the the economics did not work. Here’s the problem: because wind and solar generators only work about 20-40% of the time, this enormously expensive transmission line would not be operated at anywhere near its capacity. Likely, it would only average about one-third of capacity. That means, compared to a line that operates at or near 100% of capacity, its charges for transmission would be about triple.
The cancellation of this line has only occurred within the past month, and I haven’t seen anything about plans for a re-bid or an alternative strategy. So far, nobody is saying “this can’t possibly work.” But no matter how you approach the problem, the cost of transmitting intermittent wind and solar power from far upstate to New York City is going to be around triple the cost of transmitting power from a natural gas plant that runs nearly all the time.
So here we are, suspended up in the air, and nobody seems to realize that we will shortly crash to earth. Everybody involved is trying to milk the last dollars out of the taxpayers before the crash hits.
In brief, the New York State Energy Research and Development Agency (NYSERDA) are hiring a public relations outfit, using $500,000 per year of public money, to “maintain a positive narrative” and “respond to negative viewpoints” about the state’s Climate Act. This article shows the likely result of that effort – NYSERDA’s Think You Know Solar – Take the Solar Quiz.
I recently covered an article by Ken Girardin who broke the story of New York’s latest attempt to shore up public support for the Climate Leadership & Community Protection Act (Climate Act). In brief, the New York State Energy Research and Development Agency (NYSERDA) are hiring a public relations outfit, using $500,000 per year of public money, to “maintain a positive narrative” and “respond to negative viewpoints” about the state’s Climate Act. This article shows the likely result of that effort – NYSERDA’s Think You Know Solar – Take the Solar Quiz.
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 devoted a page to solar issues that describes my concerns with solar development in New York. 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.
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. Despite the enormous impacts to energy affordability, threats to electric system reliability, and mandates affecting personal energy choices I believe many New Yorkers are unaware of the law. In 2023 transition recommendations were supposed to be implemented through regulation, Public Service Commission orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.
Solar Quiz
On March 21, 2024 I received an email announcing the Solar Quiz. This link is the web view version. In the rest of this section, I respond to its contents.
The quiz opens with the obligatory picture of roof-mounted solar panels.
The cheerful opening introductory paragraph leads off with the narrative: “free and abundant light” gives us electricity” from this “incredible clean energy technology”.
You may already know that solar panels convert the sun’s free and abundant light into electricity. Pretty great, right?
So, we thought we’d give you a quick quiz to test your solar smarts. Let’s see how much you really know about this incredible clean energy technology.
Sunlight may be a “free” energy source but there are costs to collect and use that energy. That detail must be in the next quiz which will come out when the geothermal energy source from Hell freezes over.
The entire Climate Act legislation and narrative is characterized by black and white cartoon descriptions. Consider the first quiz question:
Q: Do solar panels work on cloudy days?
A: Yes!
Because the panels collect light, they still function on cloudy days even though efficiency is somewhat reduced.
“Somewhat reduced”? A negligible amount or a lot? Let’s take a look at the potential range.
Their illustration:
My illustrations of today’s views from the NYS Mesonet Buffalo meteorological station. This site is notable because it is surrounded by solar panels. I am not sure how much that affects whether the meteorological data collected are representative but it does let us address the question of solar variability on this worst case condition – cloudy and snow covered.
Buffalo March 23, 2024 14:15:28 UTC or 10:15:28 EDT
Buffalo March 23, 2024 17:20:27 UTC or 13:20:27 EDT
Here is a graph of the temperature (red, orange), dew point temperature (green), and solar insolation (yellow) over the last seven days ending 23 March 2024 at 16Z or Noon EDT. Regrettably the parameter of interest is in yellow.
Note that solar insolation is 170 watts per meter squared (W/m2) at 10:15 EDT in the first picture and 420 W/m2 at 13:20 EDT the time of the second picture. Reasons for the difference include the tine of day because the second picture is closer to solar noon and the clouds are darker which could mean they are thicker in the first picture. It would be interesting to see the effect of the snow on the panels if data from that solar facility could be obtained.
To guess the effect of clouds I looked at the last seven days of data from the same site. I have put arrows on the peak solar insolation for the last six days. Presumably there were three days without clouds because the solar insolation exceeded 800 W/m2. There were two days when the peak insolation was around 500 W/m2, one day when the peak was no more than 350 W/m2, and on the most recent day it appears that the data from the daily graph peaks a little over 400 W/m2. I guess the point is that even on a cloudy day solar power is “Somewhat reduced” to half and does not go to zero. I am sure that some power would be generated even when the panels are covered by snow but the reduction sure is more than “somewhat” reduced, closer to nearly zero is my guess.
Of course, solar is zero at night. Not to worry the solar quiz addresses this.
Q: If I have solar panels, will my house still have energy at night?
A: Yes.
Solar-powered homes collect excess energy and pass it to the grid for future use, and if you don’t have excess energy stored you pull energy from the grid at any time, like when it’s dark. Another option for night-time energy use is on-site battery storage, which collects excess energy and saves it for when it’s needed.
This is egregious misinformation. The electric system instantaneously balances load and generation. Any excess energy passed to the grid has to be used at that time or stored. In my opinion the worst subsidy for residential solar is the unacknowledged cost to provide grid energy when the sun does not shine. Somebody else is paying for the infrastructure (storage or alternative sources) necessary so that solar-equipped residences can “pull energy from the grid at any time”. Inevitably the “net-metering” rules will have to be changed so this subsidy is reduced or eliminated. The mention of on-site battery storage is a start, but the reality is that the largest reliability cost is associated with extreme conditions and providing enough solar panels and energy storage to start to address that problem is uneconomic for an individual. If this was not the case, then folks would be going off the grid entirely.
The next question has no interest to me:
Q: When was the first solar panel installed?
A: In 1883, by American inventor Charles Fritts in Manhattan.
Solar energy (the photovoltaic effect) was discovered in 1839 by Edmond Becquerel, a French physicist who studied light.
The next question is relevant. Consistent with the rest of the quiz the answer provides no nuances or specific information.
Q: How long do solar panels last?
A: About 25 years
The efficiency of solar panels decreases over time. However, a lot of factors contribute to lifespan, such as weather, installation, maintenance, and quality.
The narrative answer is that “most residential solar panels should operate for 25 years before degradation (or reduced energy production) is noticeable.” The National Renewable Energy Laboratory notes that “the rate of degradation is typically around 0.5% to 0.8 % per year but varies among different types and brands of solar panels.” If I define “noticeable” degradation as a 10% loss of efficiency, then at 0.5% per year the degradation is noticeable at 23 years and at 0.8% per year the degradation is noticeable at 15 years.
The next quiz question addresses solar panel land use.
Q: What is it called when land is used for both solar panels and agriculture?
A: Agrivoltaics
In some places, farmers are experimenting with grazing livestock (solar grazing), growing native grasses, and even fruits and vegetables around solar panel installations.
Sounds great. Note that they did not talk about agrivoltaics in New York. There is a reason. The State has set up the New York State Agricultural Technical Working Group to address this in New York but there has been no progress mandating this approach. As I will explain in the following discussion, I am unimpressed with that effort.
The last question in the quiz manages to get in a bit of bragging.
Q: Which U.S. state is the top community solar market in the country?
A: New York!
As of December 2023, more than two gigawatts of community solar have been installed in New York – enough to power nearly 400,000 homes.
Of course the point that they can power 400,000 homes only when the sun is shining is unmentioned.
New York’s Disgraceful Solar Implementation Record
So much for the quiz. How is New York’s solar implementation policy going?
I believe that the development of solar resources is considered above all other concerns which will not end well. I submitted comments on the Draft Scoping Plan two years ago calling for a moratorium of utility-scale solar development because the New York State Department of Agriculture and Markets (Ag & Market) policies on solar energy projects that protect prime farmland were being ignored and programs designed to protect prime farmland and reduce impacts were being developed but not implemented. Two years later the policies are still being developed and I estimate that 20 projects have permits to construct and only seven meet the Ag & Markets policy.
In their comments for solar project applications the Department of Ag and Markets prepared testimony has noted that “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.” The lack of a responsible solar implementation policy has meant that of the 20 projects with applications only seven meet this criterion as shown in my Solar Project Scorecard. These results show that it is possible to protect prime farmland, but that New York State has failed to mandate that all projects meet the reqirement. As far as I can tell, there are no provisions in any of the permitting requirements that mandate farmland protections consistent with Department of Ag & Markets recommendations.
If there are no specific requirements for protecting farmland then what about other mitigation strategies. One responsible solar siting mitigation strategy would be to combine agriculture and solar land use – agrivoltaics. Last October, the report Growing Agrivoltaics in New York was released.
The report outlines the results of a limited literature review to advance understanding of opportunities for agrivoltaics by reviewing New York State’s current agricultural landscape; the current situation of agrivoltaics pilots and programs; and solar design considerations related to integration of agricultural activities and solar power generation. In aggregation with additional State efforts to understand land-use implications of large-scale solar (LSS) development, results inform potential future actions to provide education on best practices for implementation of agrivoltaics projects in New York State.
The report provides good background information. It includes a good description of the permitting process. It mentions the New York State Farmland Protection Working Group which was formed in 2021 “to consider and recommend strategies to the State on the siting process of major renewable energy facilities and to minimize the impact of siting on productive agricultural soils on working farms”. It also notes that additional agrivoltaic research has been proposed. They managed to come up with a definition:
A simultaneous use of land for solar photovoltaic power generation and agricultural production of “crops, livestock, and livestock products” as that phrase is defined by Agriculture & Markets Law (AML) §301(2).
I am unimpressed because the report is long on research recommendations and short of any sign of urgency to implement anything.
The fact is that the drive to install as much as possible as quickly as possible is affecting agricultural lands across the state and local communities. One of the readers of my blog, Lenny Prezorski from the Cold Spring Farm in Schoharie County recently wrote me a note. The following is a lightly edited version.
Schoharie County like much of rural NY, is losing prime farmland to solar development. One project is under construction and another is seeking approval from ORES.
Last week our state and local officials held a news conference at the Salisbury dairy farm which adjoins the NextEra East Point solar project in the Town of Sharon. A number of impacts were discussed. This news article details those concerns. For example, the highway superintendent has been fighting with solar contractors since the project started. His efforts to correct the damage to town roads have fallen on deaf ears in Albany. Despite the claims from the developer, they continue to do as they may with no oversight.
On the same day as the news conference our local newspaper ran an article noting that the property for the project was up for sale. The article notes that the parcel has “1,100 acres on a working, income-producing farm, with a log cabin home, and “seeping vista views” stunning views of both the Mohawk Valley and Catskill Mountains.” However, There’s just one catch:
Three hundred thirty five of those acres, across eight parcels, are covered in solar panels as part of NextEra Energy’s 50-MW project mostly off Route 20 and Gilbert’s Corners Road, but also Pomella, Beech and Sakon Roads.
Coldwell Banker is listing the site at 485 Gilberts Corner Road for $15,350,000; the listing went up February 20.
The site, according to the description “is one of the largest working solar farms in all of New York State, secured by a 25-year lease with guaranteed lease payments totaling in excess of $20 million.
“This property portfolio consists of over 1,000 acres of farmland and solar arrays on eight separate tax parcels—including a working farm with barns and residences.
“The largest portion on this income-producing portfolio is from the 25-year lease on the solar panels, covering 355 acres.
Prezorski continues:
How deep are the pockets that these projects can be sold, I assume at a profit, before they are complete? I understand that Rock District Solar in the Town of Carlisle has been sold 2 or 3 times and it hasn’t even received approval.
It is too late for the Town of Sharon but it hopefully isn’t too late for the proposal in Carlisle.
Prezorski describes problems with the accelerated permitting process.
Rock District attempted to get local approval from the Carlisle Planning Board. During the public comment period I submitted a detailed report which exposed errors and omissions in the Environmental Assessment Form. Once appraised of these facts they immediately withdrew their application from the town and submitted it to Office of Renewable Energy Siting. I’ve prepared a report which primarily focuses on the loss the prime farmland and potential impact to groundwater resources in our karst landscape.
The EAF located the project in the wrong watershed. It neglected to document that runoff from the site flows directly into a sinkhole which feeds the longest cave system in NYS. The application submitted to ORES contains the same erroneous data. How do we ensure that NYS follows their own laws? This is the question I posed to our local leaders and to you too.
Unfortunately, I do not have any answer for the question how do we get the state to follow our own laws.
Concluding Remarks
The Think You Know Solar – Take the Solar Quiz is an example of mis-misplaced priorities of the Hochul Administration. The cute little public relations quiz demonstrably misinforms the public. Sunlight may be a “free” energy source but the costs to collect and use that energy are ignored. While it is encouraging that solar panels can generate electricity even on cloudy days the implications of reduced output are not addressed. Claiming that solar panels last for 25 years ignores that they are also expected to generate 10% less power in a shorter period. Finally, the answer to the question “will my house still have energy at night?” displays a lack of understanding of how the electric system works and downplays the enormous challenge and costs to provide that energy that are not covered by residential solar owners.
Meanwhile, back in reality the article describing the local stakeholder concerns with the state’s control over solar farm projects describes what is happening away from Albany. As noted previously, the developers are affecting roads and not fixing damage. The state is over-riding local code enforcement and safety issues are evident. In order to expedite renewable development, the State has implemented new permitting requirements that over-ride landowner rights and local government control.
I believe that this situation has led to a disgraceful solar siting process. Despite assurances prime farmland is not being protected. Proponents of “responsible solar siting” that includes things like agrivoltaics are long on talk and promises of more research but short on urgency to do anything to implement something. Prezorski explained that the expedited permitting process is enabling errors that could have significant consequences. Finally, the state has no requirements that the solar developments are constructed to meet the Scoping Plan performance expectations. As a result, even more solar development will be required to meet the generation and capacity requirements.
No amount of public relations investment to spin stories to be consistent with the Hochul Administration narrative are going to be able to hide the reality of the disgraceful utility-scale solar siting policies. Those policies are going to cause much more harm than acknowledged by the State.
The energy implosion set in motion by New York’s Climate Leadership and Community Protection Act of 2019 (Climate Act) continues to unfold slowly. This week we have gotten a few more new data points.
The energy implosion set in motion by New York’s Climate Leadership and Community Protection Act of 2019 (Climate Act) continues to unfold slowly. This week we have gotten a few more new data points. If you can read between the lines of wild spinning by the Governor and her team of bureaucrats, you will find that the scope of offshore wind projects moving forward with accepted bids has decreased by about two-thirds, while the price has just jumped by over 30%.
First, some background. The Climate Act sets several unachievable and impossible targets, the first of which is 70% of electricity from “renewables” by 2030. How to get there? The bureaucrats in charge of meeting the targets have no idea what they are doing, but they have established as a first goal to have some 9,000 MW of offshore wind turbines (nameplate capacity) up and running by some point in the 2030s. Does that sound like a lot? Current average demand in New York State is about 17,000 MW per this NYISO 2023 Report (at page 26), meaning that New York consumes about 150,000 [G]Wh of electricity in a year. (17 x 8760 (hours in a year) = 148,920). 9,000 MW of offshore wind turbines operating at a 30% annual capacity factor will generate 23,652 [G]Wh in a year (9 x 8760 x 0.3 = 23,652). That’s less than a sixth of current consumption. And did I mention that they are also planning to increase demand by 50% or more by forcing the electrification of all automobiles and home heating and cooking? So the 9,000 MW of offshore wind turbines will provide maybe 10% of our electricity needs in the 2030s, at random and often useless times — and that’s assuming that the turbines actually get built.
Forging ahead with its nonsensical and unworkable plan, in 2018-20 New York conducted a series of solicitations for bids from offshore wind developers to put up turbines in various sites off the coast of Long Island. Those solicitations resulted in accepted bids for close to half of the 9,000 MW goal. The big projects were named Sunrise Wind, Beacon Wind, and Empire Wind 1 and 2. Here is a map of where the turbine farms are to be located:
As I reported in this post from October 5, 2023, the prices that the State agreed to pay the developers after the auction were $110.37 per MWh for Sunrise Wind, and $118.38 per MWh for Empire Wind 1.
But then in July 2023 essentially all the developers with accepted offshore wind development contracts backed out of the deals, and demanded price increases averaging about 50%. The Chair of the New York Public Service Commission, Rory Christian, reacted with outrage. My post of October 15, 2023 covered a report of Mr. Christian’s reaction that had appeared in the New York Times. Excerpt:
Mr. Christian added that the state’s ratepayers, who would have borne the cost, could not serve as an “unlimited piggy bank” for companies to tap. “We have a deal,” he said to the developers, calling on them to stand by the terms they agreed to.
Sure. Here was my reaction to Mr. Christian:
Well, Rory, I’ve got news for you: the developers aren’t going to honor the deal. You’re going to have to hold a new auction. And the prices that will be bid will be as high or higher than those just demanded by these developers.
And, as I predicted, they proceeded to hold a new auction. By January, there was word that new bids had been received, but there was no information as to bidders or prices or awards.
Governor Kathy Hochul today announced the State has conditionally awarded two offshore wind projects from its fourth offshore wind solicitation – a planned 810-megawatt project, Empire Wind 1, (developed by Equinor) and Sunrise Wind, a planned 924-megawatt project (developed by Orsted and Eversource). The competitively selected projects will create more than 800 near-term family-sustaining construction jobs and invest $2 billion in near-term enhanced economic development statewide, including developer-committed investments to support disadvantaged communities. The projects, totaling over 1,700 megawatts of clean energy, will be the largest power generation projects in New York State in over 35 years once they enter operation in 2026, and will continue progress towards achievement of the State’s Climate Leadership and Community Protection Act (Climate Act) goal to develop 9,000 megawatts of offshore wind energy by 2035.
Yes, it’s all happy talk about how great this is. Here’s some more:
“I promised to make New York a place for the renewable energy industry to do business, and we are delivering on that promise,” Governor Hochul said. “Offshore wind is foundational to our fight against climate change, and these awards demonstrate our national leadership to advance a zero-emissions electric grid at the best value to New Yorkers.”
And how about getting President Biden in on the credit:
“Today’s announcement is the latest step forward as President Biden continues to deliver historic progress on growing the American offshore wind industry, creating good-paying union jobs, and advancing our ambitious climate and clean energy goals,” said White House Deputy National Climate Advisor Mary Frances Repko.
Dare we ask how much is actually getting built and at what cost? If you can get past the introductory happy talk, you will finally come to this:
The weighted average all-in development cost of the awarded offshore wind projects over the life of the contracts is $150.15 per megawatt-hour which is on-par with the latest market prices.
And yet you will not find anywhere in this press release any mention of the prices of the previously accepted bids. But you read Manhattan Contrarian, so you know that the previously accepted prices were $110.37/MWh for Sunrise Wind and $118.38/MWh for Empire Wind 1. In other words, despite Mr. Christian’s outrage, the prices have gone up by in excess of 30%. And this is for only 1700 MW of capacity. Previously they had accepted bids for 4300 MW of capacity, and plans for 9000 MW. 1700 MW of offshore wind capacity operating at a 30% +/- capacity factor might provide 2% or so of New York’s electricity needs in the 2030s, and at mostly uselessly intermittent times. What’s happening with the rest of their big plans? No word here.
And what does the cost here mean for consumer utility bills? You can divide the $150/MWh by 1000 and quickly figure out that they are planning to pay $0.15 per kWh as a wholesale price for intermittent electricity at the source. Nothing is included in that for transmission upgrades, backup, or storage to make for a reliable 24/7/365 grid. By the time you add in those extra costs, as the percent of electricity from the wind turbines gets to around 50% it would be amazing if you could get electricity to the consumer for less than $0.50/kWh. And if the percentage of electricity from the wind turbines goes well above 50%, then all bets are off. $1.00/kWh? $2.00? Easily.
Meanwhile, the Energy Information Administration reports here in 2023 (page 6) that the “levelized cost” of electricity from a new combined cycle natural gas plant is under $50/MWh — for dispatchable power with no transmission upgrades, backup or storage needed. That translates into electricity to the consumer of well under $0.20/kWh.
Governor Hochul’s press release actually includes a line as to the costs to the consumer of the newly accepted offshore wind farm bids:
The average bill impact for customers over the life of these projects under these awards will be approximately two percent, or about $2.09 per month.
Talk about deceptive. They give no methodology or assumptions as to how they came up with the cost figure. But it is obvious that it includes just the cost of blending into the grid the new power from these particular turbines, and otherwise using existing transmission lines and existing fossil fuel plants for the backup role. There is no effort whatsoever here or anywhere else in New York’s propaganda to figure out how much it will cost the consumer for electricity when the grid has been converted to all renewables plus massive amounts of some kind of backup or storage that hasn’t even been invented yet.
Memo to Attorney General James: If you have any real interest in prosecuting people who lie about plans to supposedly achieve “net zero” carbon emissions, here is the worst offender of all right under your nose.
As a meteorologist I find it frustrating that every extreme weather event is considered a reflection of “a “new normal” due to the effects of climate change”. As a pragmatic environmentalist, it is even more frustrating when a report comes out criticizing New York’s infrastructure resiliency to minimize the effects of extreme weather but fails to pick up the tradeoffs between resiliency infrastructure investments versus reducing greenhouse gas emissions that will supposedly prevent extreme weather. This article describes an example of this dynamic: the New York City Metropolitan Transit Authority (MTA) extreme weather resiliency plan and recent flooding in New York City.
“Friday’s deluge dropped 8.05 inches of rain at JFK Airport, making it the wettest day on record, beating Hurricane Irene’s daily record set back on Aug. 14, 2011, the National Weather Service said. Widespread rain totals of 4 to 6 inches were New York City, Long Island and Hudson Valley, with locally higher amounts in excess of 7 inches of rain.
Tony Heller does a great job documenting historical accounts of extreme weather events. He found that on October 8, 1903 New York received 10.04 inches of rain.
Ryan Maue checked out the Central Park precipitation data and found that on September 23, 1882 the site measured the highest daily value of 8.28” and that this recent event was the 9th wettest day at that site.
Nonetheless, it did not prevent the usual suspects, including Governor Hochul from blaming climate change: “This is unfortunately what we have to expect as the new normal”. She also described the storm as “Mother Nature at her most powerful.” “This was the kind of rain that was once unimaginable — we called them once-in-a- century storms,” Hochul said Saturday. “But this is the third time since I was sworn in two years ago, I’ve had a once-in-a-century storm.”
Of course, this storm will also be used as more justification by the same crowd to justify implementation of New Yorks Climate Leadership & Community Protection Act (Climate Act) net-zero transition. Because it is generally accepted that climate change caused by GHG emissions did not kick in until after 1950, the higher historical precipitation in 1882 and 1903 conclusively falsify the Governor’s “new normal” and the idea that GHG emission reductions can prevent further similar storms.
MTA Climate Resilience Upgrades
Flooding caused major disruptions to New York’s subway system, according to the Metropolitan Transportation Agency. The flash flood caused “full or partial suspension of service on half the lines in the system, with MTA officials saying full service was restored by 8:30 p.m after 20 million gallons of water were pumped out of the subway”. On a personal note, the subway closures forced my grand-daughter to stay with a classmate in Manhattan rather than going home to Brooklyn that day.
A couple of days earlier, the MTA published a 20-year needs assessment report that said “Some 400 miles of subway tracks, half of Metro-North’s Hudson Line and several Long Island Rail Road stations are in dire need of upgrades to stave off flooding and other extreme weather exacerbated by climate change.” The Resilience Improvement weblink states:
Climate change is here—and we must prepare. Over the next two decades, climate change projections indicate that the New York region will experience more frequent and intense coastal storms, more than twice the current number of torrential rainfall events, and triple the current number of extreme heat days over 90 degrees. Meanwhile, sea levels will rise approximately 2.5 feet by the 2050s and almost 5 feet by the 2080s.
Our infrastructure was not built to withstand future climate conditions. We’ve made significant progress retrofitting, renovating, and rebuilding infrastructure in anticipation of future climate conditions, but climate change won’t wait for us to finish. For our systems to keep running as lifelines through the coming climate-induced crises, we must move faster.
To determine whether the Metropolitan Transportation Authority (MTA) – New York City Transit (Transit) identified potential damage to its system and developed plans to mitigate the effect of extreme weather conditions and flooding. We also determined whether the MTA tested/updated the plans and inspected and maintained the equipment to ensure they can be deployed when needed. Our audit covered the period from April 2009 to August 2022.
The key findings of the report include the following:
To date, the MTA has not implemented one of the most important recommendations of the 2009 Report – the development of the climate change adaptation master plan. Since Superstorm Sandy, Transit has assessed and identified areas of its system that are at risk of flooding from extreme weather events and developed and carried out capital projects to both correct damage caused by Superstorm Sandy and mitigate potential flooding conditions in the Transit system. Further:
Our review of a sample of 23 of 221 capital projects intended to correct or prevent damage found that projects were often incomplete in scope of work, not finished on time or within budget, or insufficiently documented. Just two of six critical stations that Transit indicated should have been made more watertight and resistant to potential flooding were completed in one project we reviewed. Another project was initiated to prevent flood water from entering 14 fan plants; however, only 11 fan plants were mitigated. Transit officials stated the three remaining fan plants were completed but did not provide documentation to support their statements. (Fan plants are facilities with large vent gratings and fans located atop shafts connected to the Transit tunnels.)
Transit did not sufficiently document inspections of individual pieces of equipment. Instead, it reported more broadly by subway stations or by rooms in off-site facilities that were inspected. In one instance, because not all rooms were inspected at a facility, we were able to determine that 51 of 72 pieces of equipment in our sample were not inspected between January 2021 and August 2022.
While Transit has developed winter, hurricane, rain, and extreme heat plans, we found that these plans were inconsistently activated, with no documentation explaining the rationale for decision making. In our sample of 18 weather events, plans were not activated for six events that included tropical storms, hurricanes, or coastal flooding.
I support the concept to identify and address potential flooding conditions. My problem with this report is that it does not recognize the differences between weather and climate, namely weather is going to cause flooding conditions whether or not climate change exacerbates the impacts. It seems that climate change must be included as part of the marketing to get support for the audit.
Discussion
Response to the 20-year plan included the concern by advocates that no costs were attached to the plans for the improvements that MTA says is necessary. For example:
“While the MTA’s needs assessment is thorough and shows that our transit system is in dire need of investment, it lacks dollar figures showing exactly how much money will be needed to fix the subways, buses, and commuter railroads,” wrote Rachael Fauss with the good government group Reinvent Albany in an email. “The needs of everyday riders must come first. In an environment of limited resources, it is essential that we prioritize capital projects based on objective measures of need, not politics, to repair the subways, buses and commuter railroads and ensure that they continue to best serve New Yorkers in this era of climate change.”
I think it is important to consider whether the net-zero transition GHG emission reduction measures in New York State will have any material effect on the extreme weather events that caused the problems observed during the latest flash flood. The answer to that question is no. As noted previously, the fact that there were days with greater rainfall before GHG emissions allegedly became the driver of observed global warming suggests that GHG emissions reductions would have to go to pre-industrial levels to just keep rainfall rates at the same level as 1882. That is clearly an ambitious target even if you believe that GHG concentrations are a driver of extreme weather and I don’t believe that. It gets worse. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. Even if GHG emissions in New York were to get to zero, that reduction will be supplanted by increases elsewhere in less than a year.
Conclusion
One of my pragmatic principles is Russel Schussler’s observation that “We can do almost anything we want, but we can’t do everything”. In this instance the costs of the Climate Act’s net-zero transition should be considered relative to the MTA plan. The upgrades necessary to prevent extreme rainfall events and storm surge from flooding New York’s subway system will be enormous but at the end of the day those investments would have a measurable effect. In order to get to net-zero, the costs will be an order of magnitude greater than “enormous” with no hope for a measurable effect on severe weather. I agree with Rachel Fauss: “it is essential that we prioritize capital projects based on objective measures of need, not politics”.
The disconnect between MTA, the media, and even Fauss in this example is frustrating. For example, Rachael Fauss noted that the investments are necessary “in this era of climate change” misses the point that climate is what you expect and weather is what you get. Climate change had very little effect on this event and certainly not enough to cause the storm or materially change its impacts. Ultimately, throwing away money on a pointless virtue-signaling net-zero transition will likely forestall the investments needed to maintain and strengthen the resiliency of the subway system. Reducing New York GHG emissions in a quest to minimize extreme weather issues in New York is not going to work and will be counter-productive for real solutions.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. He blogs about the RGGI program because he has been involved with it since its inception and nobody else apparently wants to review it. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.
You must be logged in to post a comment.