The Latest from the Experts on New York’s Climate Act Implementation

Roger Caiazza

I have published two previous articles about New York Independent System Operator (NYISO) analyses related to New York’s Climate Leadership and Community Protection Act (Climate Act).  This post describes what I believe is an important new analysis of the future of New York’s electric system.


The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

Unfortunately, the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  This article describes the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  While there may be minor changes to the document itself, I am comfortable saying that the major findings will not change substantively.

System and Resource Outlook Summary

The Executive Summary makes the point that the Climate Act is driving changes to the generating system, the transmission grid and the demand landscape.  As a result, this “leads to re-thinking how and where electric supply and storage resources evolve, and how to efficiently enable their adoption to achieve energy policy targets”.  The summary goes on to note:

This 2021 – 2040 System & Resource Outlook (the Outlook), conducted by the New York Independent System Operator (NYISO) in collaboration with stakeholders and state agencies, provides a comprehensive overview of potential resource development over the next 20 years in New York and highlights opportunities for transmission investment driven by economics and public policy in New York State. The Outlook together with the NYISO’s 2021-2030 Comprehensive Reliability Plan (CRP) represent the marquee planning reports that provide a full New York power system outlook to stakeholders, developers, and policymakers.

The Outlook examines a wide range of potential future system conditions and enables comparisons between possible pathways to an increasingly greener resource mix. By simulating several different possible future system configurations and forecasting the transmission constraints for each, the NYISO:

  • Projected possible resource mixes that achieve New York’s public policy goals while maintaining grid reliability;
  • Identified regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
  • Quantified the extent to which these transmission constraints limit delivery of renewable energy to consumers, and;
  • Identified potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

There are many potential paths and combinations of resource and transmission builds to achieving New York’s climate change requirements. As the current power system continues to evolve, evaluating a multitude of expansion scenarios will facilitate identification of common and unique challenges to achieving the electric system mandates New York State has set for 2030 and 2040. A thorough understanding of these challenges will help build a path for investors and policymakers to achieve a greener and reliable future grid efficiently and cost effectively. Through this Outlook several key findings were brought to light:

Four potential futures are evaluated to best understand the challenges ahead. A Baseline Case evaluates a future with little change from today. A Contract Case includes approximately 9,500 MW of renewable capacity procured by the state and evaluates the impact of those projects. Finally, a Policy Case postulates and examines two separate future scenarios that meet New York policy mandates.

Energy planning analyses such as this work normally evaluate different scenarios of the future by comparing them to a business-as-usual scenario.  In this instance the business-as-usual scenario does not include any of New York’s climate initiatives.  On the other hand, Climate Act Draft Scoping Plan analyses were perverted to “prove” the desired conclusion that the benefits were greater than the costs by comparing future scenarios against a reference scenario.  The Integration Analysis used a semantic trick to claim that some de-carbonization costs (such as de-carbonizing transportation costs) necessary to meet Climate Act targets did not have to be included in the comparison scenario because the electric vehicle conversion legislation was already “implemented”.  That approach took legitimate implementation costs out of the projections.  Of course, this also makes comparison of the NYISO work relative to the Draft Scoping Plan problematic.

The second estimate of the future in the Resource Outlook considered only those projects currently under contract:

Through an annual request for proposals, NYSERDA solicits bids from eligible new large-scale renewable resources and procures Renewable Energy Certificates (RECs) and Offshore Renewable Energy Certificates (ORECs) from these facilities. This Outlook included approximately 9,500 MW of new contracted renewable resources, including 4,262 MW of solar, 899 MW of land-based wind, and 4,316 MW of offshore wind. The addition of these resources to the existing system representation provides insights regarding their impact on system performance in the future.

The Outlook report noted the following Key Takeaways for the contracted renewables scenario:

  • The pace of renewable project development is unprecedented and requires an increase in the pace of transmission development. Every incremental advancement towards policy achievement matters on the path to a greener and reliable grid in the future, not just at the critical deadline years such as 2030 and 2040. In general, resource and transmission expansion take many years from development to deployment.
  • Coordination of project additions and retirements is essential to maintaining reliability and achieving policy. Coordination of renewable energy additions, commercialization and development of dispatchable technologies, fossil fuel plant operation, and staged fossil fuel plant deactivations over the next 18 years will be essential to facilitate an orderly transition of the grid.

Many more renewable resources have to be developed to meet the overall Climate Act net-zero goal by 2050 and the interim 2040 goal of “zero-emissions” electricity generation.  The NYISO analysis looked at two Policy Case scenarios that meet those targets:

  • Scenario 1 utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.
  • Scenario 2 utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

Both scenarios project a blend of land-based wind, offshore wind, utility-scale solar, behind-the-meter solar, and energy storage will be needed to meet the CLCPA policy mandates through 2035. There are significant differences between these scenarios and the equivalent Draft Scoping Plan mitigation scenarios.  One of the big differences is the magnitude of a new generating resource called “dispatchable emission-free resources” (DEFRs):

These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors). As more wind, solar, and storage plants are added to the grid, dispatchable emission-free resources must be added to the system to meet the minimum statewide and locational resource requirements for serving system demand when intermittent generation is unavailable.

The report warns:

Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.

As part of the analysis the NYISO considered what would be needed if the DEFR capacity is not developed. They found that “The exclusion of DEFRs as a new technology option, while enforcing the retirement of fossil generators via the zero-emission by 2040 policy, exhausts the amount of land-based wind built and results in the replacement of 45 GW of DEFR capacity in Scenario 1 with 30 GW of offshore wind and 40 GW of energy storage.”  They also noted that the alternative did not address ancillary service requirements needed for the transmission system.

The Outlook report noted the following Key Takeaways for the Policy Case Scenarios:

  • Significant new resource development will be required to achieve CLCPA energy targets. The total installed generation capacity to meet policy objectives within New York is projected to range between 111 GW and 124 GW by 2040. At least 95 GW of this capacity will consist of new generation projects and/or modifications to existing plants. Even with these additions, New York still may not be sufficient to fully meet CLCPA compliance criteria and maintain the reliable electricity supply on which New York consumers rely. The sheer scale of resources needed to satisfy system reliability and policy requirements within the next 20 years is unprecedented.
  • To achieve an emission-free grid, dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York. DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.
  • As the energy policies in neighboring regions evolve, New York’s imports and exports of energy could vary significantly due to the resulting changes in neighboring grids. New York is fortunate to have strong interconnections with neighboring regions and has enjoyed reliability and economic benefits from such connections. The availability of energy for interchange is predicted to shift fundamentally as policy achievement progresses. Balancing the need to serve demand reliably while achieving New York’s emission-free target will require continuous monitoring and collaboration with our neighboring states.

The important findings in the report led to the following recommendations:

  • Future uncertainty is the only thing certain about the electric power industry. From policy advancements to new dispatchable emissions-free resource technology innovation and ultimate development, the system is set to change at a rapid pace. Situational awareness of system changes and continuous assessment are critical to ensure a reliable and lower-emissions grid for New York. The Economic Planning databases and models will be continually updated with new information and the Outlook study will be improved and performed on a biennial basis.
  • To meet the minimum capacity requirement in 2040, at least 95 GW of new emission-free resources, including approximately 9.5 GW of new renewable resources, will be required to come on-line. Furthermore, to fully achieve the emission-free grid target by 2040, even more resources will likely be needed along with transmission to deliver the clean power to consumers. The scope of the additional renewable resource need is both substantial and unprecedented. Compared to the 2.6 GW capacity entering service in the past five years while New York experienced a net loss of approximately 2.2 GW, the installation rate in the next 20 years must increase significantly to achieve state law climate change requirements. State agencies should consider releasing a more detailed procurement schedule for renewable resources to guide the long-term system planning and provide clarity to the market.


I noted earlier that I was comfortable saying that the major findings in this draft report will not change substantively when it is finalized.  I base that mostly on the fact that the NYISO Market Marketing Unit has reviewed the draft.  As part of their market monitoring responsibilities Potomac Electricreviewed the document relative to implications to New York’s de-regulated electric markets.  If you are interested in that particular aspect of electric system planning, I suggest checking out the memo.  For the rest of us, I only note that they state: “The 2021 Outlook is a major improvement to NYISO’s previous planning studies and provides important insights on the potential impacts of state policies on the NYISO system.”

More importantly, what about the Climate Action Council?  Unfortunately, as I pointed out before the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  In a series of meetings over the next couple of months the Council will have to address the Draft Scoping Plan comments made by the NYISO and the New York State Reliability Council that raised reliability concerns.  I hope. without any supporting evidence, that the Integration Analysis team is working with the NYISO planning staff to reconcile the differences between this analysis and theirs.

In the meantime, there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting Council members described their impressions of comments made at the public hearings.  I have prepared an overview summary of all the comments made during the Update on Public Hearings and Comments agenda item and wrote an article highlighting relevant comments.  In this regard, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University talked about mis-representation at 23:39 of the recording:

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

Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) picked up on that theme.  He said that fear and confusion is based on mis-information but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”.   Obviously, these views are at odds with this report.

There is one other point.  In addition to the reliability concerns of the net-zero transition I am very concerned about affordability.  The Draft Scoping Plan has avoided any mention of ratepayer impacts to date.  The NYISO projection methodology can has that information because it is inherent in the models It is a shame that it is not being reported.


This is an important report for New York but I also believe that there are ramifications for other net zero transition programs.  These findings must be reconciled with the Draft Scoping Plan projections for the future generating system.  The leadership of the Climate Action has repeatedly punted the responsibility for a feasibility study down the road as somebody else’s problem. This report highlights multiple feasibility concerns that must be addressed to have any hope of this working.  I believe that it shows that implementation on the schedule proposed will prove impossible.  The report also highlights the need for implementation planning.  Currently there is no plan for siting renewable resources where they are needed for the future system and this shows that it must be done.

With respect to other net-zero transition programs I think the discussion and implications of the dispatchable emissions-free resource are of interest.  The analysis shows that in order to minimize the storage and renewable over-build requirements this resource could be a better choice.   However, the report notes that DEFRs such as hydrogen, renewable natural gas, and small modular nuclear reactors are not commercially viable today. “DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources.”  There is that nasty planning and feasibility is necessary component again.


Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  More details on the Climate Leadership & Community Protection Act are available here. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

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John Garrett
September 8, 2022 6:06 am

Let the morons freeze in the dark.

That’s the only way the idiots are going to learn anything about mathematics, physics and economics.

Reply to  John Garrett
September 8, 2022 8:06 am

It won’t be the elite credentialed morons who will freeze in the dark; it will be us.

Reply to  tgasloli
September 8, 2022 11:35 am

It won’t be the elite credentialed morons who will freeze in the dark; it will be us.

Leave New York ASAP for a state that isn’t proposing/passing impossible to implement regulations.

Reply to  ih_fan
September 8, 2022 3:30 pm

Which states would that be?

Reply to  Retired_Engineer_Jim
September 8, 2022 6:19 pm

Almost any RED state.

Beware of PURPLE states or recent PURPLE to RED converts, like Virginia, that is stuck for a while yet with extreme “renewable: mandates required under laws passed under 100% Democrat control.

Joseph Zorzin
Reply to  Retired_Engineer_Jim
September 9, 2022 5:50 am

Certainly not MA which is even worse than NY.

Reply to  ih_fan
September 12, 2022 10:10 am

GOOD LUCK finding one!

jeffery P
Reply to  John Garrett
September 8, 2022 1:46 pm

But will they? Like socialism/communism/Marxism these schemes have failed everywhere.

Like Mike Myers of Halloween, you just can’t kill these bad ideas. If you think you’ve won, just wait for the sequel.

James B.
Reply to  John Garrett
September 8, 2022 6:03 pm

… and the limits of engineering.

Reply to  John Garrett
September 8, 2022 10:05 pm

Let the morons freeze in the dark.”

was certified by a research by the real estate consultancy Frank Knight, which estimates that 875,000 millionaires (i.e. with assets, including property, worth more than 1 million dollars) residing in the British capital against 820,000 in the American metropolis.”

As pointed out by tgasloli.

Elites will somehow stay warm, even if it requires a trip to suffer in the Caribbean or the Mediterranean.
As the governments are currently acting, only the elites of the elites will be able to afford vehicles. Elite² are those with many millions.

September 8, 2022 6:17 am

If any of this crap is implemented NY electricity production will collapse. What a bunch of morons.

jeffery P
Reply to  2hotel9
September 8, 2022 1:49 pm

Won’t this bring down the grid in the whole northeast?

My guess is other nearby states will mimic and put the national grid at risk.

Hmmm… Is our grid connected to Canada or are we isolated?

Reply to  jeffery P
September 8, 2022 6:22 pm

A LOT of NE power comes from Canadian hydro.

Leslie MacMillan
Reply to  jeffery P
September 8, 2022 8:06 pm

Ontario’s generators spin synchronously with New York State’s via the Eastern Interconnection. The large international hydroelectric developments at Niagara Falls and Cornwall/Massena are operated jointly. Ontario and New York can and do import/export electricity to each other, minute by minute, as well as to/from Michigan and Manitoba. Even though Quebec has a vast hydroelectric development up north near James Bay, we still sell electricity to them in the winter for space heating but that connection is asynchronous and has to be electronically manipulated to bring it into phase. (Quebec exports electricity to New England because they get a better price for it, even though they have to import some from us.)

Of course Ontario can’t supply New York with anywhere near enough electricity to replace a prolonged catastrophic shortfall. Our oldest nuclear reactor at Pickering is going out of service in 2025 and the slack will be taken up by our gas turbines for the medium term — a small modular nuclear reactor prototype is being built at Darlington but will not come close to replacing the old CANDU.

Our main concern is not electricity: the Premier has confirmed that gas, not windmills, will step in to take over from Pickering, citing a study by the Electricity System Operator that gas could not be eliminated from Ontario’s capacity even now without producing blackouts. What we worry about instead is that Michigan may succeed in shutting off the Enbridge Line 5 pipeline, a pipe that carries gas and refined petroleum products from Western Canada to Ontario and Quebec through Wisconsin and Michigan under the Straits of Mackinac, entirely in U.S. waters–it was shorter and easier terrain than staying in Canada north of Lake Superior. Several refineries in Ohio rely on it, too. Shutting it would be a most unfriendly act that would cause severe shortages of jet fuel at the airports, particularly. The Michigan governor is a Biden ally but we take some comfort that a Michigan court has ruled that this is a federal, international treaty matter that is out of her hands.

Mike Smith
September 8, 2022 6:43 am

95GW of additional zero emissions power by 2040? Good luck with that.

This week, the California grid is tottering on the brink at 50GW. Adding the generating capacity of two California’s in less that 20 years is gonna be one tough act.

Pat from Kerbob
Reply to  Mike Smith
September 8, 2022 12:14 pm

I think the east coast can do blackouts as easy as the west, give them credit.

Reply to  Mike Smith
September 8, 2022 5:39 pm

The top eight mice will work on it as soon as they’re done testing the new boosters.

Reply to  Mike Smith
September 8, 2022 8:05 pm

California imports 30% of it’s electrical power from other states, so it really only produces 35 GW, which makes it even worse.

Tom Halla
September 8, 2022 6:44 am

Dispatchable zero emissions sources are currently nuclear, only. And as long as the greens are involved, New York will search for unicorn farts.

Frank from NoVA
Reply to  Tom Halla
September 8, 2022 10:57 am

They should change the acronym to ‘DEFAR’, where the ‘A’ stands for ‘Allowed’. That way, we’ll know that nuclear, large-scale hydro or any thing else that works isn’t included.

Ed Reid
September 8, 2022 6:50 am


Reply to  Ed Reid
September 8, 2022 12:22 pm

Marty McFly:
So does it run on regular unleaded gasoline?
Dr. Emmett Brown:
Unfortunately no, it needs something with a little more kick – plutonium.
Marty McFly:
Plutonium… wait, are you telling me that this sucker is nuclear?
Dr. Emmett Brown:
No no no, this sucker’s electrical, but it requires a nuclear reaction to generate the 1.21 gigawatts of electricity I need.
Marty McFly:
Doc, you don’t just walk into a store and buy plutonium… did you rip that off?
Dr. Emmett Brown:
Shhhhhh. Of course. From a group of Libyan nationalists. They wanted me to build them a bomb, so I took their plutonium and in turn, gave them a shiny bomb-casing filled with used pinball machine parts.

Reply to  Rob_Dawg
September 8, 2022 1:53 pm

Used pinball parts is the most likely DEFR option

September 8, 2022 6:57 am

Most of the ISOs are warning about the transition risks, while not yet saying it is impossible for political reasons. A recent NE ISO report revealed something interesting. The existing grid modeling software cannot handle significant renewables penetration. We are flying blind into the wall.

PJM has called a two year moritorium on new grid scale solar connections, saying they are swamped with projects and cannot assess their impact.

But I suspect runaway capacity prices will hit before a lot of blackouts, or maybe not. This is the only real question, what does hitting the wall of impossibility look like?

Ed Reid
Reply to  David Wojick
September 8, 2022 7:07 am


Reply to  Ed Reid
September 8, 2022 7:33 am

Indeed. Any time you declare war on reality it ends badly.

Reply to  David Wojick
September 8, 2022 1:07 pm

The United States of America?

Dave Fair
Reply to  David Wojick
September 9, 2022 8:54 am

Socialism proves that every day. It takes a personal catastrophe for individuals to wake up to what is obvious to knowledgeable people. Don’t worry; the Leftist politicians and Deep State are working hard to deliver.

Pat from Kerbob
Reply to  David Wojick
September 8, 2022 12:17 pm

Grid control is extremely difficult with dozens or hundreds of generation sources, a renewable future means thousands or tens of thousands of sources.
Even with Synchophasors and extremely high speed networks eventually control will become impossible.

Reply to  Pat from Kerbob
September 9, 2022 7:17 am

Even with Synchophasors and extremely high speed networks eventually control will become impossible.”
But – surely – if it has been legislated for, ‘in the interests of the children’ or donors, or summat, then it is not only possible, but will come in on time and actually under budget.
Like any – every – other Big Government boondoggle project.


Dave Fair
Reply to  Pat from Kerbob
September 9, 2022 8:57 am

No, Pat: It is very easy for poly-sci graduates to ensure grid control in the future. For a hamburger today, I will be happy to pay you on Tuesday.

September 8, 2022 7:01 am

Gotta love it when the fantasy has a name — DEFR. In fact “defer” means put off til later.

Mind you nuclear DEFR already exists but is not on the list. Morons indeed.

Doug Proctor
Reply to  David Wojick
September 8, 2022 3:55 pm

DEFR. Scot Adams would say that’s the Simulation winking at us. A clue we’re in one.

Tom Abbott
September 8, 2022 7:08 am

All this based on the erroneous assumption that CO2 needs to be regulated.

Reply to  Tom Abbott
September 8, 2022 7:52 am

erroneous assumption, premise, theory, rationalization, imagined concept, outright lie, infantile ignorance, etc. …

At this point, assigning a view of ‘erroneous assumption’ to someone that is either lying, willfully ignorant, or outright stupid, is very generous.

Reply to  Tom Abbott
September 8, 2022 8:14 pm

CO2 can be regulated and already is. The erroneous assumption is that it will accomplish the purpose for regulating it to begin with. It’s going to be mighty embarrasing when people finally figure out that all efforts so far have accomplished absolutely nothing.

Robert of Ottawa
September 8, 2022 7:13 am

What a lot of bollocks. But politicos and ideologues are insensible to reality. Here in Ottawa, all 15 candidates for the position of Mayor of Ottawa have announced climate change plans.

Oh, and some of the candidates have announced plans to do good, spread wealth and build stupendously ridiculous bike networks (it gets cold for 6 months in Ottawa). How about just running the city?

The role of mayor is to ensure the city runs efficiently and smoothly, not to save the planet. I say to them, pot holes before bollocks.

Reply to  Robert of Ottawa
September 8, 2022 7:37 am

pot holes before bollocks.

Hmm, I don’t know about that:

“Cost of fixing roads with potholes soars to more than £12 billion”

…the Asphalt Industry Alliance (AIA) suggested it would cost £12.64 billion to return local roads to a condition from which cost-effective maintenance would be possible.
This is up from £10.24 billion just one year ago.”

It would be far cheaper to twin many towns and areas with areas on the Moon

“Town twinning, as an official relationship-builder, started in Europe after the second world war. The idea was simple: repair damaged relationships between France, Germany and the UK.”

Aachen on the Dutch-German border is twinned with Halifax in Yorkshire
Berlin – Charlottenburg-Wilmersdorf is twinned with Lewisham (London) No, I didn’t make that up.

Reply to  fretslider
September 8, 2022 1:11 pm

How much to fix the roads without pot holes?

Reply to  fretslider
September 8, 2022 8:39 pm

Without fossil fuels, where are they going to get the asphalt?

jeffery P
Reply to  Robert of Ottawa
September 8, 2022 1:52 pm

Politicians care about what the money men care about. Consideration of the people are secondary at best.

September 8, 2022 7:19 am

Maybe to save the western world places like California, New York and South Australia will have to be sacrificed.

Reply to  fretslider
September 8, 2022 8:01 am

Add the UK and Germany
All in competition for the treasured Golden Flashlight award
for the first state or nation with a major blackout caused by Nut Zero policies.
It’s a close race. Perhaps a winner this winter?

Reply to  Richard Greene
September 8, 2022 10:48 am

Maybe Truss can turn UK around?

Reply to  Richard Greene
September 8, 2022 3:35 pm

Didn’t Texas already win on Valentine’s Day, 2021?

Reply to  fretslider
September 8, 2022 8:54 am

Hey I resemble that! I’ll have you know here in SA we’re world leaders in the field of Imagineering. The only downside is with power interconnectors to Victoria and NSW they’re jumping onboard the field with a serious lack of qualifications and experience. This will bode ill for the discipline you mark my words.

September 8, 2022 7:59 am

Roger Calazza is an expert on this subject and everyone who wants to know more should read his other articles:

Pragmatic Environmentalist of New York – Balancing the risks and benefits of environmental initiatives

September 8, 2022 8:49 am

The biggest problem I see with all of these green energy plans is that by the time the pain is really felt, they will be too far down the path to fix it easily. The pain will last for years, and that’s assuming they even try to fix it.

Reply to  TonyG
September 8, 2022 10:49 am

I think we are going to see a lot of Detroits after this is done. I am surprised realtors are not raising the alarm. Lots of empty houses and apartments?

Reply to  Mason
September 8, 2022 6:28 pm

Not so.

With Texas shipping the illegals north, there will be plenty of illegals to squat in those houses.

Reply to  TonyG
September 8, 2022 11:38 am

The politicians pushing these regulations will have already reaped the financial benefits and retired long before it becomes apparent to the rest of the population that these grandiose schemes cannot possibly work.

September 8, 2022 9:05 am

It is not difficult to catch the en·thu·si·asm in this paper. They will work out problems as they go along keeping the lights on in NYC.

Rush Limbaugh said it, liberalism is a mental illness. It’s the wording that counts and not the actual facts dictated by the actual generation of electricity.

Reply to  Olen
September 8, 2022 10:37 am

Much of the social history of the Western world over the past three decades has involved replacing what worked with what sounded good.

economist Thomas Sowell

Reply to  Olen
September 8, 2022 3:36 pm

What about the rest of New York State?

September 8, 2022 9:45 am

Food, clothing, shelter. Remove any one and the temples are thrown down, the high priests and ministers slaughtered.

Homelessness awaits a charismatic leader to light the spark.

Reply to  ferdberple
September 8, 2022 6:29 pm

There are very few “homeless”, but a bunch of vagrants.

CD in Wisconsin
September 8, 2022 9:57 am

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


And they call climate skeptics deniers. Who are the deniers now? It looks as though the psychology of projection is at work here.

Old Man Winter
Reply to  CD in Wisconsin
September 8, 2022 10:26 am

Since NYC has had several blackouts in the past, reliability should be
one of the first things they’d think of concerning electrical power. Since AOC
is from NYC, maybe she’s rubbing off on them & they’re all
starting to think like her!

Reply to  Old Man Winter
September 8, 2022 1:38 pm

AOC was quite proud of herself the other day. She finished a puzzle in less than 3 hours. The box said 2 to 4 years.

Reply to  Old Man Winter
September 8, 2022 1:58 pm

That is a key point. The organizations are in place to keep the system reliable but no one has stepped up on the Council to call these academics out. I clutch to the hope that there are behind the scenes discussions going on but someday the adults in the room will have to speak out. Cynical me suspects that won’t be until after the election.

Old Man Winter
Reply to  Roger Caiazza
September 8, 2022 3:23 pm

cynical = wise

James B.
Reply to  CD in Wisconsin
September 8, 2022 6:13 pm

It seems more like an example of “mass formation” and the Psychology of Totalitarianism.

The Dark Lord
September 8, 2022 10:29 am

if they had a 1,000 years it would still be impossible to implement…

Kevin kilty
September 8, 2022 11:19 am

To meet the minimum capacity requirement in 2040, at least 95 GW of new emission-free resources, including approximately 9.5 GW of new renewable resources, will be required to come on-line. 

If I understand this correctly, they are saying something to this effect: To meet some policy we are determined to implement in too short a time and at unknown but likely ruinable cost, we will need 9.5 GW of new renewable resources like wind and solar, and another 85.5 GW of something that works somewhat like wind and solar in our imagination, but which is different by being dispatchable through something we see as a lot like science but a little more like magic. Someone else will figure out how to make it work.

Reply to  Kevin kilty
September 8, 2022 1:58 pm

Nailed it!

Beta Blocker
Reply to  Kevin kilty
September 8, 2022 3:54 pm

Last month, in a political campaign rally, New York’s governor offered a suggestion which could have the collateral impact of sharply reducing demand for electricity in her state. The gist of her remarks was that if the state’s 5.4 million Republicans don’t like how New York State is being run, they should all move to Florida.

Kevin kilty
Reply to  Beta Blocker
September 8, 2022 4:34 pm

Indeed. And take your flashlights to find your way out.

Reply to  Kevin kilty
September 8, 2022 8:46 pm

And the joke [that in the near future won’t be]:
“What did they use before candles, Grandpa?”

Steve Case
September 8, 2022 11:45 am

Not New York, but California, (what a shock) is having black outs:

California scrambles to avoid blackouts
as it pursues a green energy future

And we are told:

“Yet California is redoubling its commitment — arguing that the culprit of its energy woes is not the aggressive pace of its transition but the climate change that transition is designed to confront.”

Michael in Dublin
September 8, 2022 11:46 am

I may have missed it but has any first world country done a feasibility study of net zero and 100% renewables? I somehow think the word “feasibility” will not be found the the vocabulary of politicians. The other study that is absent is a cost-benefit analysis.

Reply to  Michael in Dublin
September 8, 2022 1:59 pm

I am not aware of the two studies any rational person would consider necessary before jumping off this cliff

Dave Andrews
Reply to  Michael in Dublin
September 9, 2022 8:04 am

A study was done in the Netherlands of the ‘Metal Demand for Remewable Electricity Generation in the Netherlands’

The Netherlands only has a population of about 17.5m but the study found that

“To reach renewable energy production targets the Netherlands requires a significant percentage of the annual production of FIVE specific critical metals. The case of the Netherlands is illustrative for other countries, both in and outside Europe.As future demand for these metals exceeds expected supply, the energy transition becomes a vulnerable process”

“The current global supply of several critical metals is insufficient to transition to a renewable energy system. Calculations for the Netherlands show that production of wind turbine and PV solar panels already requires a significant share of the annual global production of some critical metals”

“Looking at the global scale, scenarios in line with the goals of the Paris Agreement require global production of some metals to grow at least 12 fold towards 2050 compared to today’s output. Specifically demand for neodymium, terbium, indium, dysprosium and praseodymium stand out. This calculation does not include the demand for these specific metals in other applications such as EVs or consumer electronics”

“If the rest of the world would develop renewable electricity capability at a comparable pace with the Netherlands, a considerable shortage would arise.”

John Pickens
September 8, 2022 11:48 am

So, either build six or seven Indian Point-sized nuclear reactors or give up.
There is no other option.

Reply to  John Pickens
September 8, 2022 12:25 pm

Actually California’s surface transportation energy requirements are the equivalent of 43 typical nuclear power generation plants.

James B.
Reply to  John Pickens
September 8, 2022 6:21 pm

100 NuScale Power Modules (small Modular reactors) would do it.

John Hultquist
Reply to  James B.
September 8, 2022 8:13 pm

Maybe I missed the memo, but I haven’t heard that any of these have been built and connected to a grid.
How long will it take to get 100 built and connected in California?

Beta Blocker
Reply to  John Hultquist
September 8, 2022 11:09 pm

The first six-module NuScale plant (462 MW total) is scheduled to go online in eastern Idaho in 2029. I closely follow what their team is doing and believe they will be the first in the US to get an SMR design into commercial service. Years of exceptionally diligent work on their part has been necessary to get them to the place where they are today.

Reply to  John Hultquist
September 9, 2022 8:27 am

John H.
How long will it take to get 100 built and connected in California?”
I assume that if Kalifornia passes state legislation, they can mandate that that will be done before the 2024 elections.
I imagine that the details will be left to the ‘little people’.

Auto, without my usual cynicism . . .

September 8, 2022 1:12 pm

While I appreciate and value all of Roger’s work preparing and presenting these reports I must say this is some of the most painful reading I have experienced. Thanks Roger but I have to take a painkiller after reading your reports. These people have to be the most dishonest, disrespectful, heartless and most disgusting ragtag bunch of scoundrels ever. They are liars and cheats, they can take their green legal requirements and stick them where the sun don’t shine. The primary function of any public servant is to serve the public. What part of that don’t they understand? As for Paul Shepson Dean and Robert Howarth they both need a trip to the woodshed, preferably many trips. Liars and cheats both of them.

Reply to  Bob
September 8, 2022 2:27 pm

It really is a sad state of affairs isn’t it.

Doug Proctor
Reply to  Bob
September 8, 2022 2:47 pm

They’ve been given a mandate to make something happen. Unless they decide to quit in protest, they can’t tell their bosses the whole department is based on false assumptions and principles. They have to work AS IF the reliability issues are resolvable.

Ultimately, the bosses will be content with whatever progress they can assist in happening. Everyone who has worked in a large bureacracy has seen how this plays out: impossible targets given, minimal results with proposal for more later, accepted. With “bonuses for good work done under difficult circumstances “.

Reply to  Doug Proctor
September 8, 2022 5:11 pm

Doug you may be right but that is no excuse for lying and cheating. If this is business as usual it must stop, there is too much at stake. The people in charge need to be held to account, they are damn lucky I am not delegated to hand out the punishment. It would not be pretty.

Reply to  Bob
September 8, 2022 5:28 pm

Some CIA head once acknowledged that their mission is misinformation and that the enemy to believe the lies, our own people also have to be lied to.
“The primary function of any public servant is to serve the public” is one such lie.

Reply to  AndyHce
September 8, 2022 10:51 pm

I certainly wouldn’t look to the CIA for moral guidance, they can take their views somewhere else, I have little interest in what they have to say.

EdA the New Yorker
September 8, 2022 1:43 pm

Having plowed through some of the impenetrable reports pumped out by the ny authorities on this matter, I applaud Roger’s tenacity in delving deeper than I could manage.

The Delusional Emission-free Resources (DEFR’s) provide a treasure trove of test questions for 100-level Chemistry or Physics students, but little else. The Thermodynamics and E & M classes can also take their bite. So far, I have found little evidence of a serious engineering analysis being applied anywhere in the CLCPA publications.

The shutdown of Indian Point 2 was done reflexively by cuomo, and has provided a useful approximate metric of one GW as replacement power needs. For example, using the hydrogen DEFR, and generously assuming a 50% efficiency in power production, 1200 metric tons of hydrogen will be needed per day. Perhaps that power plant could be located in Central Park both to limit transmission losses, and as a monument to the green god.

The “extension cord down the Hudson” to bring “cheap, renewable hydropower from Quebec” has been in the works for 10 years, and should be available any day now. Friends have needled me for my involvement in Riverkeeper, but they are a well-meaning conservation group. They did a good job of discussing this project, named, “Champlain Hudson Power Express.” -enormous-stakes-for-the-hudson-indigenous-communities/

The CLCPA promoters also ignore potential legal delays, such as the restart of the Danskammer plant, after it was retrofitted for a much cleaner fuel mix. Once three-quarters of a billion dollars are stranded in legal limbo for one case, corporations are going to be highly circumspect regarding providing fossil-fueled spinning back-up for the green dreams.

A blocking high in the dead of winter will pretty much eliminate solar and wind for a week, and I can easily forsee a catastrophe in the making.

Reply to  EdA the New Yorker
September 8, 2022 2:29 pm

I agree with you 100%. I love delusional emissions-free resource and will use it in the future

Beta Blocker
Reply to  EdA the New Yorker
September 8, 2022 3:43 pm

See my related comment just posted here.

Doug Proctor
September 8, 2022 2:31 pm

“…. I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable. I don’t accept that will be the case. In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable. It cannot be.”

I think this comment, as absurd as it is practically, reflects the CLCPA’s mandate to make 100% clean energy happen. They cannot say at the same time “Yes, we’ll make it happen as instructed” and “No, it can’t be done”.

The CLCPA is in the same pickle as the IPCC regarding the primacy of CO2 for planetary temperature forcing. Their mandate says that. They can’t put out reports based on “Yes, CO2 is the primary cause and it’s from fossil fuels” and “No, it’s not THE primary cause and other factors we’ve dismissed are important”.

Same problem came up for Fauci and the CDC with vaccines. And Fauci for gain of function virology research.

September 8, 2022 2:42 pm

After all of this waffle not one mention of funding, who will pay, anything. I am gob smacked.

Beta Blocker
September 8, 2022 3:37 pm

I live in the US Northwest and have relatives who live in New York State and in the Bay Area of California. These relatives have no inkling of the energy train wreck which is quickly coming their way. That said, here is a repeat of a comment I made to a Francis Menton article posted on WUWT in early June 2022.


I want to explore some questions about how New York State’s Climate Leadership and Community Protection Act is being interpreted in practice by the state’s regulatory agencies.

In 2021, the New York State DEC denied regulatory approval for Danskammer’s application to construct and operate a new gas-fired power generation facility on its existing Newburgh site:

The basis for the 2021 decision from the DEC can be summarized as:

— Constructing and operating this new facility would add to the state’s greenhouse gas emissions in clear violation of the Climate Act.
— Danskammer has not demonstrated a need for this new 536 MW facility given that NYISO’s reliability strategy already includes 800 MW of power conservation by 2030.  

In its application, Danskammer had argued that power from the new facility would eventually displace power from other less efficient fossil-fueled generation sources which produce more carbon emissions per unit of power than the new plant would produce. The DEC rejected the argument saying that:

“The purported displacement of less efficient fossil fuel generators by the Project is based on electricity sector modeling performed for the Applicant by ICF. As with any such electricity sector modeling, its outputs are largely determined by chosen inputs and assumptions. The Department cannot address or evaluate all the methodological assumptions or analytical decisions made by Danskammer or ICF for purposes of their own estimates of GHG emissions associated with the Project. The Department will not rely exclusively on such electricity sector modeling for purposes of assessing compliance with Climate Act Section 7(2). Electricity sector Modeling, particularly to the extent it is utilized to project GHG emission from sources other than the Project at issue here, may not provide the level of precision necessary to serve as the primary basis for the Department to determine consistency with the Climate Act.

The fact that chosen assumptions used in electricity sector modeling can drastically change its results is illustrated by the fact that the Applicant itself initially projected the operation of the Project would result in Statewide GHG emission increases in 2030. The Applicant’s own analysis initially projected that, in 2030, the Project would result in 191,000 short tons of additional direct CO2 emissions in the State, along with 84,000 short tons of CO2e of additional upstream GHG emissions associated with the Project. Only after DEC’s Second NOIA did Danskammer update its modeling analysis such that the November 2020 GHG Supplement projected Statewide GHG emission decreases in 2030.”

TOPIC #1: Electricity sector modeling and long-range power planning

Those who control the project assumptions control the project decisions. Any outcome can be justified depending upon the assumptions made up front in the planning process. Here in the US Northwest, the regional power planning organization, the Northwest Power Planning and Conservation Council, uses extensive electricity sector modeling in making its recommendations to local and state governments. The council also uses modeling to forecast shortfalls in the region’s power supply. 

Within the last five years, the council has moved away from focusing on gas-fired generation towards wind and solar as the preferred replacement for coal-fired generation. The shift in focus reflects the priorities of the region’s politicians who are mostly all in for adoption of the renewables. IMHO, the council’s forecasts and recommendations are inherently suspect for many of the same reasons the New York State DEC gave in rejecting Danskammer’s model-based arguments for approving its new gas-fired power generation facility.

TOPIC #2: The transmission infrastructure of a regional power grid 

A wind and solar energy future requires extensive upgrades to the entire power transmission infrastructure of a regional power grid such as PJM, the regional grid which services New York State. However, that same upgraded infrastructure could also be employed for transmitting power into New York State from gas-fired generation resources located in other states willing to host them.

The Climate Leadership and Community Protection Act requires that compliance assessments of power projects for energy facilities constructed in New York State must include an assessment of upstream GHG emissions. A question … Should we conclude that upgrades and additions to power transmission facilities inside New York’s boundaries might be denied simply for the fact that other states might choose to host new-build gas-fired generation connected to the PJM grid?

TOPIC #3: Indirectly-enforced electricity conservation as a consequence of regulatory permitting decisions

As the reliability of the electricity supply in New York State begins to seriously degrade, it is possible that emergency authorization regulatory permits might be requested to install diesel-fired or gas-fired peakers inside the state boundaries.

Using the DEC’s denial of Danskammer’s application as a predictive template, it seems to me that the Climate Act ties the hands of New York State’s regulators in ways that would prevent them from approving permits for peaking-use diesel and gas-fired utility-scale gensets regardless of how dire the situation becomes over the next decade. Moreover, that the NYISO has a target of 800 MW of power conservation by 2030 can always be used as a further justification for denying permits for the peakers. 


The upshot is that for the next ten years or even longer, energy conservation is the only means New Yorkers will have for dealing with the serious shortages of electricity which are now developing. IMHO, the US Northwest will be facing a similar situation as the coal-fired capacity serving our region continues to be retired without adequate replacement either by natural gas generation or by wind and solar.

Reply to  Beta Blocker
September 8, 2022 6:57 pm

Good comment. One clarification New York has its own regional transmission operator who has its hands full with dealing with the New York City load pocket.

The planning outlook says that DEFR will be needed in New York City and hint that it might not be feasible. I cannot imagine that a hydrogen system (you know the gas that is colorless, orderless, explosive and hard to store) will ever get permitted in the City. If you cannot build it then the reliability standards for in-city generation cannot be met and a blackout is inevitable.

Unless someone gets to the administration and makes it clear that this charade is going to have catastrophic impacts I agree that tthe story will be we are doing energy convervation and other smart planning tricks for near term planning. I cannot see that ending well.

Beta Blocker
Reply to  Roger Caiazza
September 8, 2022 11:26 pm

The trend to watch out for is the premature closure of fossil-fueled and nuclear power plants without a clearly defined source of replacement power having been identified before the plant shutdowns. If the shutdowns begin to accelerate, then the schedule for the oncoming energy train wreck will move up.

Paul Stevens
September 9, 2022 4:41 am

Where in the implementation plan does the phrase “And then a miracle occurs” pop up”?

Dave Fair
September 9, 2022 8:45 am

Central big-government “planning” at its finest. Socialist politicians and out-of-touch bureaucrats decide what “must” happen. History teaches us that down the road the wheels will fall off this Leftist green vehicle to the utopian future. After untold damage to ordinary people the politicians, bureaucrats, NGOs and crony capitalists will simply walk away with full pockets and leave the clean-up to ordinary people and the free market.

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