DEFR Technoeconomic Assessment

Roger Caiazza

Readers may recall my articles (DEFR Concerns Update November 2024 and Compendium of DEFR analyses July 2024) last year about New York’s magical new Dispatchable Emissions-Free Resource (DEFR) technologies. New York agencies all agree that new resources are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability.  This article describes a recent report about DEFR technologies prepared for New York.

A New York Public Service Commission (PSC) May 2023 Order notes that the Climate Leadership & Community Protection Act (Climate Act) directs the PSC to establish a program to ensure that the electric sector targets are achieved and explains that “there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements.”  It concludes: “This Order initiates a process to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target.” 

All credible projections for New York electric resources include a substantial estimate for DEFR.  The New York Independent System Operator 2023-2042 System & Resource Outlook establishes a baseline requirement of 20 GW of DEFR capacity by 2040 to replace the current 25.3 GW of fossil generation.  There are other projections calling for much more.

The New York State Energy Research & Development Authority (NYSERDA) recently announced the completion of its Zero by 40 Technoeconomic Assessment (Zero by 40 Report).  The study was prepared by the Electric Power Research Institute (EPRI) under contract to NYSERDA.  It evaluates potential DEFR technologies needed for New York’s goal of a zero-emissions electric grid by 2040. ​

Technologies Evaluated in the Zero by 40 Technoeconomic Assessment

Section 1.4 in the Zero by 40 Report describes the technologies evaluated:

This report evaluates potential resources that can provide firm energy and capacity in a zero-emissions power sector. The study examines seven technology categories that could serve as DEFRs. These technologies are grouped into three resource groups based on their expected operational characteristics. While some resources can be configured to serve different roles, these groupings reflect constraints on costs, emissions, and availability in New York State, which are discussed later in the report.

Low-capacity factor resources can be deployed during periods of high demand and low renewable generation, offering reliability, fast-ramping capabilities, and no duration limitations, assuming fuel availability, but are not operated as baseload units due to plant economics. Low-capacity factor Resources include:

  • Hydrogen (H2)
  • Renewable natural gas (RNG) and renewable diesel (RD)

High-capacity factor resources operate the majority of the year and can provide reliable baseload power, including power during challenging events, but are less suitable for fast ramping or frequent starts and stops. High-capacity factor resources include:

  • Advanced nuclear including three types:
    • Large light water reactors (LLWRs) that are large reactors (>600 megawatts electric [MWe], pressurized water reactors and boiling water reactors, using low-enriched uranium fuel and water as the coolant and moderator. Advanced LLWRs incorporate evolutionary safety features and improved performance compared to earlier generations.
    • Light water small modular reactors (lwSMRs) that are small reactors (50–300 MWe) derived from LLWR designs, often with an integrated reactor and steam generator in a single containment vessel.
    • Non-water-cooled reactors: Reactors, both small and large, using a coolant and moderator other than water and often a high-assay low-enriched uranium (HALEU) fuel.
  • Carbon capture and storage (CCS) on thermal plants
  • Geothermal including four types:
    • Conventional geothermal or Hydrothermal
    • Enhanced Geothermal Systems (EGS) generates electricity from hot dry rock,
    • Closed-Loop Geothermal Systems (CLGS) refers to a new generation of systems in which no fluids are introduced to or extracted from the earth.
    • Superhot rock geothermal (SHR) targets deeper formations with temperatures exceeding 450⁰C,

Gap-rightsizing resources can help balance supply and demand to adjust the capacity gap. While they do not generate electricity directly, they enhance the utilization of other clean resources. Gap-rightsizing resources include:

  • Long duration energy storage (LDES) Note that this refers to interday storage (10-36 hours)
  • Virtual power plants (VPP)

Technology Assessment Summary

I am not going to include descriptions of the resources considered because of time and space considerations.  Instead, I will summarize the Chapter 9 explanations of the results for the three functional DEFR categories. The report uses the following comparison criteria: performance attributes, readiness by 2040, infrastructure and supply chain readiness dynamics, project lead times, emissions and other considerations, cost, and scalability for 2040.

The Low-Capacity resource summary of the evaluation of these resources states:

Low-capacity factor resources are expected to be critical in any future zero-emission grid, offering reliability and fast-ramping capabilities on days with the most extreme system needs. Each technology evaluated has advantages and challenges. Infrastructure constraints and high costs may limit the widespread availability of H2 in 2040, but low GHG emissions, especially for green H2, will likely provide value across various industries in 2040 and beyond, making investments in pilot projects and eventual strategic infrastructure deployment important from an economywide perspective.

RNG and RD may be the most viable low-capacity factor resources for 2040 deployment given their technology readiness, existing fuel transport infrastructure, and ability to serve as drop-in fuels in existing plants. However, the combination of feedstock limitations, competition for fuels from other sectors and states, and GHG considerations necessitates limiting their use to low-capacity factor applications.

The High-Capacity resource evaluation summary states:

High-capacity factor resources are valuable for meeting existing load and expected load growth. While renewables are projected to supply most of the energy demand in 2040, high-capacity factor resources can provide firm power and grid services that support reliability in a predominantly renewable grid. Their high energy density also helps mitigate potential land-use challenges associated with large-scale renewable deployment. High-capacity factor resources could also reduce the need for low-capacity factor resources, which are expensive and mostly idle. However, high-capacity factor resource technologies require long lead times, often 10 years or more. To ensure they are operational by 2040, stakeholders must take early action.

Each technology offers unique advantages and faces specific challenges. From a deployment-readiness perspective, LLWRs and CCS are the most prepared for near-term implementation. However, lwSMRs and non-water-cooled reactors could also become commercially viable by 2040. Geothermal, while promising, has lower readiness and limited scalability in New York State.

The Zero by 40 report does not summarize gap-rightsizing resources.  Both gap-rightsizing resources LDES and VPP are largely ready for deployment.  Costs for VPP are lower than other technologies but depend on costumer participation which makes availability uncertain.  Furthermore, there are limits to the energy potential of this technology.  LDES batteries will be more expensive, but “has the potential for longer discharge durations and higher operational certainty, but it is also a net load on the grid due to the need to recharge and round-trip efficiency losses.”

Implications

The Zero by 40 Report modifies the services provided by DEFR. The original DEFR concern focused only on low-resource episodes that would be served by the low-capacity DEFR category.  The report adds high-capacity factor DEFR which is best suited to operate most of the year providing reliable baseload power but can also provide power during challenging events, albeit these resources are “less suitable for fast ramping or frequent starts and stops.”  The gap-rightsizing resource category “help balance supply and demand to adjust the capacity gap”.  This is not the rare peak-load gap associated with low wind resource availability.  Instead, this gap is the more common inter-day gap when there is not enough short-term storage to adequately support load.

In my opinion, these changes reflect the need to address inconvenient issues.  The most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics. But there are two nuclear issues regarding the Climate Act mandate to use renewables.  It is not suitable as only backup for the short-term peak because it is best used as a high-capacity resource.   That means that logically it should be used as the primary electric resource instead of wind and solar if only because it eliminates the need for massive redundant DEFR backup. 

Another takeaway from these expanded DEFR categories is that it recognizes that New York is not well-suited for wind and solar resource availability.  As a result, there is the need for more kinds of DEFR.  The Zero by 40 Report also notes that there are even more required resources to support renewables including  “short-duration storage and grid-forming inverters” and “Other technologies, such as regional and in-state transmission and dynamic line ratings” that resolve transmission issues.

I admit that I was not familiar with the term “technoeconomic”.  When I looked it up, I found that there is another similar term “techno-economic analysis”.   The difference is relevant.  Technoeconomic assessment is an adjective that describes an analysis that includes both technical and economic factors.  A techno-economic analysis is a formal process that compares technical and economic performance that informs decision making.  This report is a technoeconomic assessment but what New York needs is a techno-economic analysis.

The Zero by 40 Report is like other New York energy policy documents because they all address technical and economic factors but do not include a feasibility analysis supporting a particular proposed pathway.  No state report provides comprehensive, technology-specific cost estimates that would allow direct comparison of technologies to each other and to conventional alternatives.  Technological considerations are noted but not resolved.  A techno-economic analysis would provide the details necessary to determine feasibility of a future system meeting the legal mandates of New York law.

Francis Menton recently described the New York Supreme Court decision that required the New York State Department of Environmental Conservation (DEC) to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or modify the Climate Act schedule.  Although the authors of the Zero by 40 Report did not explicitly say that the DEFR technologies needed to meet the 2040 Climate Act zero emissions target would not be available, they certainly did not say it would be ready either.   In my opinion, it is time for the Legislature to reconsider not only the schedule but the aspiration of the Climate Act because of the findings of this report.

Conclusion

This report provides multiple reasons that New York State needs to pause Climate Act implementation.  Future action should only proceed if reliability requirements are ensured and this report identifies issues that may make that impossible.


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.

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November 22, 2025 6:14 am

. Low-capacity factor Resources include:

Hydrogen (H2)

_________________________________

That’s where I stopped reading (scanning) it just isn’t practical.
There isn’t any available, it must be manufactured most efficiently
from natural gas (NG) so why not not use NG in the first place?

Reply to  Steve Case
November 22, 2025 6:57 am

Surely they refer to “Green Hydrogen”, which is potentially technically feasible and economically irrational.

Reply to  Ed Reid
November 24, 2025 7:57 am

Indeed, the worse-than-useless wind and solar can’t provide the electricity needed but somehow they are expected to produce enough “surplus” power to use for hydrogen production.

Presumably by (further) overbuilding of worse-than-useless wind and solar.

Absolutely moronic.

sherro01
Reply to  Steve Case
November 22, 2025 7:11 am

Steve,
In 1968 I helped establish Australia’s first urea fertilizer plant. It used natural gas, nitrogen from the air and elegant catalysts.
It has now closed, operators citing the too-high price for natural gas.
The natural gas price includes real costs like pipelines and social costs like royalties, taxes and various imposts from those who dislike using natural gas. These green imposts killed the productive urea plant.
The same fate would await gas used instead of horribly expensive, hard to handle hydrogen for New York. At the present time, green ideology is having unprecedented destructive results that the simple-minded are prepared to accept. Democracy at work?
Geoff S

Jeff Alberts
Reply to  sherro01
November 22, 2025 8:09 am

Wow, Geoff, I was 6 years old. That makes you…. 125? 🙂

sherro01
Reply to  Jeff Alberts
November 22, 2025 9:41 am

JA,
I’ll be 85 in June.
My comments try to show that older people can have had lots of exposure to events that sometimes become contentious. There is a current trendy wave for the younger set to invent what really happened and to paint it as green wisdom. It is a sham. We have no need to rewrite history.
Geoff S

Jeff Alberts
Reply to  sherro01
November 22, 2025 6:17 pm

I got it. I was just poking a little fun. I always appreciate your comments, and perspective.

Reply to  sherro01
November 22, 2025 6:44 pm

Years do not matter, but brains and reasoning ability.

Sparta Nova 4
Reply to  whsmith@wustl.edu
November 25, 2025 6:54 am

Years of hands on, real life experience most certainly matter.
It is fundamental to brain and reasoning ability development.

Why do we fall down? So we can learn to get back up.

Why do we make mistakes? So we can learn how to recover from the consequences and how to peer through the fog to prevent future mistakes.

Many years ago Orbital Sciences launched their first OrbCom satellite. It did not work. They called in the VP of my division. His first question: “Did you press the reset button.” They looked at him like he was speaking some extra-terrestrial language. We “old war horses” are needed to flow lessons learned to the bright but inexperienced newbies.

One can learn a lot from books. One can only learn how to solve problems by getting one’s hands dirty.

Dave Fair
Reply to  sherro01
November 22, 2025 9:40 am

 Democracy at work?” Yep, mob rule.

In a democracy people get what they want … and they get it good and hard. [Inspired by H.L. Mencken.]

Reply to  sherro01
November 22, 2025 6:42 pm

Australia is the world’s third-largest LNG exporter, but exploration has declined sharply. That is a purely political situation. Regulation and ‘environmental opposition’ are not permitting investment. One could surmise Australians are as gullible as Europeans when it comes to NG development and production. Is that correct?

William Howard
November 22, 2025 6:45 am

I say let them continue and repeat what UK and Germany are doing which produced industrialization and unaffordable energy – WSJ notes that in Germany electricity is now considered to be a luxury – perhaps that is the only thing that can get rid of left wing lunacy

Scissor
Reply to  William Howard
November 22, 2025 6:57 am

The final solution appears to be replacing the whiners, those who expect affordable electricity to be available at the flip of a switch, with third worlders, who are less discerning.

Jeff Alberts
Reply to  Scissor
November 22, 2025 8:40 am

Already happening. Just keep your pets locked up.

George Thompson
Reply to  Jeff Alberts
November 22, 2025 4:10 pm

And daughters.

Reply to  Scissor
November 22, 2025 6:45 pm

Get a 2nd Amendment and carry.

Reply to  William Howard
November 22, 2025 6:58 am

Deindustrialization?

Reply to  William Howard
November 24, 2025 8:00 am

Think you meant DEindustrialization.

November 22, 2025 6:54 am

DEFRs are only necessary because of the intermittency of wind and solar. DEFRs would be operated to “fill in the blanks” left by wind and solar unavailability. Wind and solar are redundant capacity and redundancy is expensive. Enough wind plus solar plus batteries might not need DEFRs, but would be far more expensive.

rogercaiazza
Reply to  Ed Reid
November 22, 2025 7:49 am

EXACTLY! I keep saying that in all my filings and the state keeps ignoring the point. The quesion is will they keep ignoring reality so long that it puts NYS in the death spiral observed in Germany and elsewhere.

Reply to  rogercaiazza
November 22, 2025 6:48 pm

Yes, they can and will.
NYS has VERY abundant shale gas. PA and other states will lateral drill to get it!
When those rigs line your borders, you’ll know why.

KevinM
Reply to  whsmith@wustl.edu
November 22, 2025 8:43 pm

“Upstate New York is approximately 330 miles long from north to south and 283 miles wide from east to west.”

KevinM
Reply to  KevinM
November 23, 2025 7:49 pm

Meaning of quoting NY size might be too cryptic…

I assume you can’t reach more than a mile under a state’s border to get at what’s under a state. I assume that though states are not rectangular, they may as well be at that scale. In that case I can reach (283+330=) 613 sq mi of NY from its borders but NY would have (280*330=) 92400 sq mi inside. So a sneaky side-digger would only get at (613/92400*100=) less than 1 percent of underground resources.

Reply to  Ed Reid
November 24, 2025 8:06 am

Wind and solar WILL ALWAYS BE REDUNDANT.

And they can’t replace dispatchable sources of generation. Neither can the foolishness of battery storage which is completely unaffordable in any event, because there is no guarantee of sufficient “overproduction” by the worse-than-useless wind and solar installations to have the batteries “charged” when needed.

And none of this crap, the windmills, the solar panels, nor the batteries, have very long life spans. The cost of building it all ONCE is prohibitive; the cost of serially REBUILDING it every two decades is, dare I say it? UNSUSTAINABLE.

Sparta Nova 4
Reply to  AGW is Not Science
November 25, 2025 6:58 am

“But it’s got electrolytes.”
— Complements of Idiocracy

sherro01
November 22, 2025 7:00 am

In the 1970-80 era, my employer company discovered several new mines in remote parts of Australia. Such mines need electricity supply. We evaluated optimum supply and proceeded.
This is mentioned because we could have gone down the incompetent New York trail, but we were more interested in progress than in waffle. Half a dozen of us scientists and engineers and economists did in weeks what it is taking years for a large and expensive New York structure to prevaricate about.
New York, your energy future is being wrecked by con men.
Geoff S

Reply to  sherro01
November 22, 2025 7:09 am

…and politicians. (“…but I repeat myself.”, Mark Twain)

November 22, 2025 7:06 am

After EPA Administrator Lee Zeldin rescinds the Endangerment Finding (EF) of 2009 for CO2, whatever will Gov Kathy H. do? Will she eat humble pie and repeal the Climate Act?

The Federal Register is back on line, and I have been checking it for an announcement by the EPA rescinding the EF.

Beta Blocker
Reply to  Harold Pierce
November 22, 2025 1:21 pm

What will Governor Hochul do? She will tell her fellow New Yorker Lee Zeldin that she and the NYS legislature are in charge of her state and to go pound sand. In any case, a rescinded EF doesn’t deny a state its right to chase a Net Zero fantasy if it so chooses. The powers that be in NYS will not give up on their Net Zero dreams, and New York state as a whole doesn’t have enough sensible voters to counter those which occupy New York City and other down-state voting blocks.

Reply to  Beta Blocker
November 22, 2025 6:55 pm

Certainly. Energy decline sinks every boat, even NYS.
Hochul is an irresponsible, close-minded politician unable to understand what policy is in NYS’s best interests. Unfortunately, she has a LOT of company.

Sparta Nova 4
Reply to  Beta Blocker
November 25, 2025 7:00 am

It will be fun to watch a NYC blackout when the UN is in full session.
That could well be a “tipping point.”

November 22, 2025 7:10 am

‘In my opinion, it is time for the Legislature to reconsider not only the schedule but the aspiration of the Climate Act because of the findings of this report.’

The author is correct, but the Legislature will do no such thing. Please look at the photo at the head of this article and honestly ask yourself if there is a single technically trained or even a sane person therein:

https://www.nysenate.gov/newsroom/press-releases/2025/liz-krueger/senator-liz-krueger-announces-reintroduction-ny-heat-act

rogercaiazza
Reply to  Frank from NoVA
November 22, 2025 7:50 am

I wish I could argue with you but I can’t.

strativarius
November 22, 2025 7:18 am

There’s always a gap – a huge one in their understanding.

All credible projections 

There aren’t any. Fresh Tarot cards please…

rogercaiazza
Reply to  strativarius
November 22, 2025 7:52 am

When I said credible I was trying to differentiate between the Jacobsen acolytes who do not think that DEFR is needed and everybody else.

strativarius
Reply to  rogercaiazza
November 22, 2025 8:04 am

Well, in my defence I’m an ignorant Englishman, but the Technocrats had their opportunity with Covid, BSE etc

It’s always modelled and always terribly wrong.

strativarius
November 22, 2025 7:34 am

Story tip: BBC – Worse than we thought

The licence fee is ~£175/household/year. People have been cancelling in droves:

“…there are other channels through which the BBC receives taxpayers’ money – which Brits course get no say in (and have probably never heard of). These routes could give an indicator as to how the Government might keep the BBC going should significantly more people cancel their licence fee.”

Anyway, I expect taxpayers will be delighted to know they’re being charged £57 million (2020-24) to be entered into an alliance with everyone from Bill Gates to the World Wide Fund for Nature (WWF)
https://dailysceptic.org/2025/11/22/taxpayers-are-charged-for-the-bbc-whether-they-like-it-or-not/

Reply to  strativarius
November 22, 2025 8:01 am

Obviously the idea of state-directed media is anathema to a free society. As bad as the BBC seems in this respect, it would be hard to beat FDR’s strong arming of our regulated media that has continued to carry water for the Democrats to this day:

‘CBS Vice President Henry A. Bellows said that “no broadcast would be permitted over the Columbia Broadcasting System that in any way was critical of any policy of the Administration.” He elaborated “that the Columbia system was at the disposal of President Roosevelt and his administration and they would permit no broadcast that did not have his approval.”‘

https://reason.com/2017/04/05/roosevelts-war-against-the-pre/

strativarius
Reply to  Frank from NoVA
November 22, 2025 8:11 am

People would prefer a subscription service, the elites don’t.

Scarecrow Repair
Reply to  Frank from NoVA
November 22, 2025 4:23 pm

It began with Commerce Secretary Hoover’s FCC in 1927, expressly created to put spectrum allocation in the hands of bureaucrats, overriding the common law courts which had begun substantiating a property interest. Memory says some 500 stations lost their licenses to the new mandated and unconstitutional “public interest” censorship. There’s a recent book by Thomas Hazlett, Political Spectrum, with a nice review here https://www.hoover.org/research/how-electromagnetic-spectrum-became-politicized. The FCC delayed FM radio, color TV, cell phones, and more by 10-20-30 years, all at the behest of the entrenched cronies. The only complaint I have about the book is that there are so many example of nefarious cronies that it gets tiring.

Reply to  Scarecrow Repair
November 22, 2025 5:25 pm

‘The only complaint I have about the book is that there are so many example of nefarious cronies that it gets tiring.’

What’s more tiring is that if you were to poll the relative handful of Americans who’ve even heard of Herbert Hoover, I bet the vast majority of them would consider him to be an advocate of laissez-faire capitalism. Btw, nice link!

Scarecrow Repair
Reply to  Frank from NoVA
November 22, 2025 5:52 pm

It was really hard struggling through the last half of the book, reading the same corruption plot over and over, just a different scene and different players.

George Thompson
Reply to  strativarius
November 22, 2025 8:01 am

And PBS in the US; no license fee perhaps, but Gov funding to continue to fund the crybabies and lefties there…the courts have already stated that the Gov can’t cut the funding; why I have no clue-no rational clue, that is.

strativarius
Reply to  George Thompson
November 22, 2025 8:12 am

It’s entitlement that counts.

Sparta Nova 4
Reply to  George Thompson
November 25, 2025 7:04 am

Part of it is the PBS funding is part of a Congressional Appropriations bill and really only Congress can change that.

However, there is a little discussed principle that when the President is supposed to outlay funding, if there is not enough funds in the government coffers to pay for everything, the President is allowed to pick and choose.

KevinM
Reply to  strativarius
November 22, 2025 8:54 pm

In USA, Netflix fans love Great British Baking Show. Is that a potential revenue stream?

Rick C
November 22, 2025 7:37 am

Even if some suitable DEFRs are found and implemented, they would essentially be capable of replacing all the renewable’s output. Undoubtedly as wind turbines and solar panels age and fail it will become obvious that it will be far cheaper to just run the DEFRs full time than to pay repair/replacement costs for the wind/solar gear. So why bother, just build nukes and keep the gas turbine peakers and operate an adequate cost effective and reliable grid.

Of course they could also figure out that CO2 is not a threat to the climate or anything else and go back to beautiful clean coal which would be faster and cheaper than nukes.

rogercaiazza
Reply to  Rick C
November 22, 2025 7:55 am

If they are serious about decarbonization eventually they will realize that nuclear is the way to go. Sadly the politicians, charlatans, and grifters do not care as much about reducing carbon as furthering their ambitions and pocketbooks

Derg
Reply to  Rick C
November 22, 2025 9:30 am

Trump will slow pay 🙂

mleskovarsocalrrcom
November 22, 2025 7:58 am

“there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements.” Nothing new. They were told this over and over by rational and knowledgeable people yet they failed to listen and instead resorted to name calling.

November 22, 2025 8:42 am

it proves that surveys prepared by incompetents should not be used/permitted since they provide incompetent and incomplete analyses.

KevinM
November 22, 2025 9:55 am

Quoted section shows another example of writers not knowing how to use bullet points. Som of the bullets are complete sentences. Some are phrases.

Sparta Nova 4
Reply to  KevinM
November 25, 2025 7:08 am

I was raised on the original Power Point rules (bullets), but those rules have evolved as has presentation standards, formats, etc.

Punctuation is now commonplace.

Where once and Power Point presentation was merely bullets to remind the speaker of sub-topics (think Toastmasters), now they are MSWord documents in landscape. I disagree, but I only have one shovel and the tide has risen quickly.

Beta Blocker
November 22, 2025 1:01 pm

As it concerns the need for both DEFR and for large-volume battery storage capacity, RE visionary Mark Jacobsen asserts that wind, solar, hydro, and pumped hydro can do it all. 

Jacobsen asserts that no DEFR and only limited volumes of four-hour battery storage will be needed, assuming enough transmission capacity is installed nationwide to bring in renewable-sourced power from wherever it is produced to wherever it is needed.

Here in Washington state, it will become illegal within the next twenty years to operate a fossil-fueled power plant inside the state’s borders. It will also become illegal for a power utility to sell electricity to a Washington state power consumer sourced from a fossil-fueled power plant located in another state. 

However, the state is attached to the Western Interconnection, which has a variety of generation types serving it. Since a power consuming device doesn’t know where the energy it consumes comes from, the mechanism by which the law will be enforced becomes a cost accounting problem. 

The practical effect is that the power utilities serving Washington state customers will not be allowed to use that portion of their total customer base located in Washington state as a source of revenue for fossil fuel power plant construction and operation in other states.

A question for Roger Caiazza: Is there a similar situation with New York’s 2019 Climate Act? 

For one prominent example, will there come a point in the future where it becomes illegal for a power utility serving New York City customers to buy electricity from gas-fired power plants located in New Jersey — fossil-fueled plants which were built to cover the shortfall of electricity caused by the forced premature closure of the Indian Point nuclear reactors?

rogercaiazza
Reply to  Beta Blocker
November 22, 2025 7:23 pm

The Climate Act does account for import emissions. Theory is the same as Washington. In practise I am not sure there will be much appetite to say no to imports needed to keep the lights on.

Also note that Climate Act emission accounting includes upstream emissions for fossil fuels so it is not just the dirct emissions but some “sciency” adder that raises the emissions. I think I saw somewhere that the agencies have calculated that they could come close to meeting the 2030 mandate if they used the GHG emissions accounting everyone else uses. Thank Jacobson acolyte Howarth for that abomination.

Beta Blocker
Reply to  rogercaiazza
November 22, 2025 9:59 pm

As long as NYS remains attached to the multi-state regional grid, New York can’t physically prevent a kilowatt-hour of electrical energy produced by a fossil-fueled power plant in New Jersey or in Pennsylvania from being consumed in New York state.

What the New York state government might attempt to do is to prevent the flow of revenue from New York power consumers to out-of-state power generators.

Which is a sticky wicket in and of itself, at least from a legal perspective. Would such an attempt on New York state’s part be a violation of federal interstate commerce law?

rogercaiazza
Reply to  Beta Blocker
November 23, 2025 4:39 pm

If you are saving the world little details about laws are not an issue. Seriously, there is no way that they can do anything about the emissions from another state when they import power other than to track it and then try to fiine the NY utiltiies who use it.

Reply to  Beta Blocker
November 24, 2025 6:17 pm

Just cut off the connections and let NY illustrate the utter stupidity of it all. And “upstate/western NY should cut off NYC which holds the idiots there that overrule the sanity of the rest of the state.

Next they’ll try to outlaw propane generators for people trying to de with the moronic decisions of the stupid government.

Bob
November 22, 2025 1:54 pm

This issue can be solved easily with one requirement. New York must stop using all the techno gibberish they are currently using. If they were forced to communicate in plain English their report would say wind, solar and storage can’t support the grid or New York. There are no alternatives to prop up wind and solar other than fossil fuel and nuclear. Since fossil fuel and nuclear are capable of producing their own backup and can sustain the grid and New York there is no longer a need for wind, solar or storage. It is that simple, nothing more needs to be said other than trash all previous renewable/net zero legislation.

rogercaiazza
Reply to  Bob
November 22, 2025 7:24 pm

Bob – you are being too logical.

BigE
Reply to  Bob
November 23, 2025 6:26 am

My reaction to reading the NY program statements is that the majority is just a bunch of BS. There will a parade of excuses to follow.

Sparta Nova 4
Reply to  Bob
November 25, 2025 7:13 am

You want politicians to do what?
/sarc

November 22, 2025 6:28 pm

H2, the energy carrier of the future!

An optimum assumption for the H2 Energy Chain is the following product:
(electrolyze H2O)(liquefy H2)(transfer)(ship)(gasify and pressurize)(transfer)(H2 fuel cell electricity),

IF a dispatchable source of electricity is used, i.e. a base power plant.
(0.7)(0.75)(0.9)(0.75)(0.9)(0.6) ≈ 0.2 (energy yield fraction) ≈ 20% of the input energy is returned as electricity at the end of the chain.This is acceptable if one is willing lose 80% of the input energy.

IF intermittent, non-dispatchable renewable electricity is used, as in the 1$B Ordos Plant in China then the natural capacity factor of the energy resource must multiply the above 20%.
The Ordos plant achieved 30% of its name plate capacity, consistent with the natural capacity factors of its wind and PV IRE, dropping the energy chain result to 6%.
This is also perfectly acceptable if one can afford to waste 94% of the input energy.
It is easy to understand why H2 is still usually produced and used LOCALLY.

Reply to  whsmith@wustl.edu
November 24, 2025 6:38 pm

Hydrogen is an energy SINK, not an energy SOURCE.

But the eco morons are too stupid to figure that out.

Reply to  AGW is Not Science
November 24, 2025 7:43 pm

H2 is considered an energy carrier, but a very lossy one to produce, as described. You are correct that it is not an energy resource. At present, there is one site producing H2 at a few thousand liters per day, but for how long, no one knows. The Russian Kolya project found H2 – at a depth of nearly 12 km – again no one knows how much.
A large natural resource of H2 would still require shipment with the same large losses.
Therefore, ONLY IF those large losses are acceptable, can H2 be a useful energy carrier.
OR, if a recyclable H2 sponge, 5 to ten times better than Fe-Ti is developed, then it can compete with hydrocarbons, maybe.
Fe-Ti has twice the energy storage density of a Li-ion battery and is far simpler and safer. Without a broad availability of the H2 energy carrier, however, batteries are winning that battle, for now. H2 may also be used in turbines, if high energy density storage is available.
There are a LOT of ‘IFs’ for H2. Even if all problems are solved, the GW people will still scream bloody murder because H2 has a very large GWP, an illogical metric, but fitting the GW people well..
There is ALWAYS something, isn’t there?
Obviously, we should prepare to recycle HCs. There is a very good case and chemistry for that.

Keitho
Editor
November 23, 2025 1:43 am

Just use gas and all these problems vanish along with the non jobs these folk have. Of course that is the stimulus not to use gas.

November 24, 2025 5:07 am

The only “DEFRs” that NY had are the nuclear power plants the idiots running the state already shut down.

Indian point, anyone?

Do they have any that are still open, or have they shut those down too? I believe Shoreham was shut down many years ago probably in the exaggerated panic over the Three Mile Island incident, but I’m not sure about what others exist(ed) in NY.

The climate deluded need to understand that “no emissions + no nukes” = NO LIGHTS (or anything else powered by electricity).

rogercaiazza
Reply to  AGW is Not Science
November 24, 2025 9:58 am

Shoreham was shut down because they claimed that no one could evacuale Long Island,
Indian Point’s two reactors were shut down several years ago – emissions went up because not enough wind and wolar was avaiable.
There still are four others operating and there are plans to build new.

Reply to  rogercaiazza
November 24, 2025 6:42 pm

Yes I recall that. That desperate need to evacuate Long Island if the plant experienced an “incident” because of all those people that died in the Three Mile Island accident, the worst nuclear power disaster the US ever experienced.

Oh wait!

*Nobody died* when TMI happened.

Sparta Nova 4
November 25, 2025 6:46 am

But an assessment is an analysis.

Just ask the assessor.

Everything on the Internet is true. Proof? It says so on the Internet.