{"id":337139,"date":"2024-07-21T08:28:05","date_gmt":"2024-07-21T06:28:05","guid":{"rendered":"https:\/\/climatescience.press\/?p=337139"},"modified":"2024-07-21T08:28:07","modified_gmt":"2024-07-21T06:28:07","slug":"cracks-in-the-ny-climate-act-facade","status":"publish","type":"post","link":"https:\/\/climatescience.press\/?p=337139","title":{"rendered":"Cracks in the NY Climate Act Facade"},"content":{"rendered":"\n
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From Watts Up With That?<\/a><\/p>\n\n\n\n

Roger Caiazza<\/p>\n\n\n\n

After five years of hype a couple of recent reports show that New York\u2019s Climate Leadership & Community Protection Act<\/a> (Climate Act) is not going as planned.  Maybe there is hope that the ill-considered net-zero transition plan can be halted before it does irreparable harm to the state.<\/p>\n\n\n\n

Clean Energy Standard Biennial Report<\/strong><\/p>\n\n\n\n

The Climate Leadership & Community Protection Act<\/a> (Climate Act) requires that the Public Service Commission (PSC) issue a review for notice and comment that considers \u201c(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.\u201d  The recently released Clean Energy Standard Biennial Review Report<\/a> (\u201cBiennial Report\u201d) fulfills some aspects of that requirement.<\/p>\n\n\n\n

The Biennial Report compares the renewable energy deployment progress relative to the Climate Act goals to obtain 70% of New York\u2019s electricity from renewable sources by 2030 (the 70% goal). <\/p>\n\n\n\n

Section 5 summarizes the \u201cPath to the 70% goal\u201d.  The description of the Table 8 \u201cSummary of progress\u201d states:<\/p>\n\n\n\n

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Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh. Table 8 below summarizes the contributions towards the goal from currently operational and contracted renewables, as set out above in Section 2 and Section 4 of this Report. In addition, it projects 10 GW of distributed generation by 2030 secured outside the CES framework.<\/p>\n<\/blockquote>\n\n\n\n

It describes Table 8, (my highlights added):<\/p>\n\n\n\n

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With these conservative assumptions, the expected amount of renewable generation from operational and awarded\/contracted sources in 2030 totals 73,292 GWh. Under the base case forecast for the 2030 statewide electric load, there is a renewable energy supply deficit of 42,145 GWh <\/strong>that would have to be addressed through future procurements in order to reach the 70% goal amount of 115,437 GWh.<\/p>\n<\/blockquote>\n\n\n\n

Consider these numbers in context.  There is an admitted gap of 42,145 GWh which is greater than the sum of the operational renewable generation in 2022, 2022 imports of renewable energy, and generation from projects operational after 2022 (37.692 GWh).  Trying to cover that gap is an ambitious challenge.<\/p>\n\n\n\n

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Source:\u00a0Clean Energy Standard Biennial Review Report<\/a><\/figcaption><\/figure>\n\n\n\n

While it is encouraging that they admit there is a problem, the suggested solution maintains the fiction that it can be done.  The Biennial Report proposes to double down on building renewables to cover the gap and meet the target. <\/p>\n\n\n\n

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To fill the expected gap, three Tier 1 annual solicitations \u2013 those for 2024, 2025, and 2026 \u2013 are currently scheduled and will seek projects capable of deploying by 2030. However, the amounts procured in these solicitations would need to be adjusted to secure the needed quantity of 42,145 GWh. The analysis suggests NYSERDA would have to procure approximately 14,048 GWh per solicitation, assuming no project attrition, or, assuming a 30% attrition rate, an amount of 20,068 GWh per solicitation. This volume is significantly higher than the annual procurement quantity of 4,500 GWh per Tier 1 solicitation (before attrition) estimated in the 2020 CES White Paper and 2020 CES Order.<\/p>\n<\/blockquote>\n\n\n\n

The best efforts of the State to date for renewable solicitations are far lower than what is needed.  The report admits that \u201cthe maximum annual new project development rate would likely be in the range of 6,000-7,000 GWh per year at least in the near term\u201d and that is contingent on meeting a number of conditions.  Table 9 below describes what the report argues is feasible.<\/p>\n\n\n\n

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Source:\u00a0Clean Energy Standard Biennial Review Report<\/a><\/figcaption><\/figure>\n\n\n\n

Even under the revised assumptions the PSC projects that the 70% renewable energy goal will not be achieved until 2033 when the historic renewable resource deployments are considered.  They still cannot let go of the narrative that the renewable resources can be deployed on a schedule that is close to the Climate Act mandates.  I do not think this approach is feasible.<\/p>\n\n\n\n

Comptroller Report<\/strong><\/p>\n\n\n\n

On July 16, 2024 the New York State Comptroller Office released an audit<\/a> of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) of their implementation efforts for the Climate Act titled Climate Act Goals \u2013 Planning, Procurements, and Progress Tracking<\/a> (\u201cComptroller Report\u201d).  This report is particularly gratifying because it confirms my long-held argument that the Climate Act cost estimates are unsatisfactory.<\/p>\n\n\n\n

The Audit Highlights section of the Comptroller Report lists the key findings and key recommendations:<\/p>\n\n\n\n

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Key Findings<\/strong><\/p>\n\n\n\n

While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs. Specifically:<\/p>\n\n\n\n