An Urgent Plea for Comments on the Plan to Create A New York State Energy Plan

Roger Caiazza needs your help in commenting on a "Draft Scope" a/k/a plan, for preparing a New York State Energy Plan. Only in the Empire State, of course, but Roger needs help!

Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.

I dropped the ball on this topic. On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan. Comments are due on December 16. I should have suggested to my readers that they need to submit comments earlier. This post includes instructions to submit comments and some topics and language.

Overview

Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan with a defined planning horizon of 2040. This makes the New York State Climate Act’s 2040 goal of carbon-free electricity particularly relevant. That plan is to rely on wind, solar, and energy storage. The Planning Board is requesting comments on the scope of work.

Background

The Energy Plan website states:

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

The current Plan was initially published in 2015, and updated in 2020, when it was amended to align with the objectives of the 2019 Climate Leadership and Community Protection Act (Climate Act). Since the last update, the Climate Action Council produced its Scoping Plan, examining many of the energy issues that contribute to climate change and offering recommendations that are currently being implemented by the State.

In recognition of the State’s historic clean energy transition, the State Energy Planning Board will now convene, chaired by the New York State Energy Research and Development Authority (NYSERDA), to begin the process of developing a new Plan. Stakeholder engagement is an integral component in the development of the State Energy Plan, and the public will have the opportunity to provide comments on the draft scope and the draft plan throughout the process.

The final Plan will provide a 15-year outlook and will focus on strategies to meet future energy needs and advance economy-wide decarbonization, while balancing reliability, affordability, environmental and public health impacts and economic growth.

The Energy Planning Board released a Draft Scope [PDF] of the New York State Energy Plan for public comment. The public is invited to review and comment on the Draft Scope and other matters they believe the Energy Planning Board should consider and examine during this proceeding through December 16, 2024.

Comments can be submitted here.

I should have published an article suggesting comment submittals following up on two posts that I published describing the November 15 New Yorkers for Clean Power (NYCP) webinar titled “Get Charged Up for the New York Energy Plan.”

My first post on this webinar described the response to my question of “does New York need a Climate Act feasibility analysis.”

The second was a presentation by Janet Joseph who was deeply involved in the development of the Scoping Plan. Her presentation and the others in the webinar did not provide solid support for the listeners to address the reliability and affordability problems. Janet Joseph’s presentation argued that the energy plan should align with the Scoping Plan ignoring the fact that there hasn’t been a response to critical comments on that document.

Suggested Comments

I suggest comments that address the Energy Plan goals for “focus on strategies to meet future energy needs and advance economy-wide decarbonization, while balancing reliability, affordability, environmental and public health impacts and economic growth.”

I endorse the specific comment topics suggested by Stop Energy Sprawl:

• Scoping Plan has failed to demonstrate that proposed strategies can work

• Energy Plan must provide an economic feasibility analysis

• Energy Plan must provide a grid feasibility analysis

• Energy Plan should pursue a diverse set of solutions

• Energy Plan process should promote transparency by publishing all comments and providing responses.

I added two more topics to address a couple of other issues. My suggestions for the other topics eliminates the need for a comment on a diverse set of options. In the following sections I will suggest some comment language for the other topics.

Feasibility

The Climate Act mandates a net-zero emissions energy system for all sectors. However, the Scoping Plan was only an outline of strategies for the electric system, building, transportation, and industrial sectors that were supposed to provide the energy needed and meet the emissions mandates of the Climate Act. There never has been a feasibility analysis proving that the strategies will work as assumed.

Suggested comment:

Because reliable, abundant, affordable energy is a prerequisite of our society, the Energy Plan needs to provide details and proof that the Scoping strategies affecting the electric, building, transportation, commercial and industrial sectors will work as proposed. The Energy Plan Scope must emphasize the need for analyses that demonstrate that the proposed transition can meet present standards of reliability and affordability for each sector.

Affordability

One of the more disingenuous aspects of the Scoping Plan is the treatment of the costs. The Scoping Plan affordability analysis only considered the costs of the Climate Act mandates and not costs associated with “already implemented policies” including Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030) and the Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030).

As a result, they did not address the total costs to reach the Climate Act mandates and coincidently could claim that “the costs of inaction are more than the costs of action”.

Suggested comment:

The Scoping Plan consumer affordability analysis only considered the costs of the Climate Act mandates and not costs associated with “already implemented policies”. The Scope for the Energy Plan should make it clear that affordability analyses will include all costs associated with the Climate Act net-zero transition no matter the legislative or regulatory mandate.

Electric System Feasibility

The Climate Act requires a zero-emissions electric grid by 2040 and includes targets for renewable capacity. I have argued for a long time that the State should prove that an electric system that relies on wind, solar, and energy storage will work. No jurisdiction anywhere no matter the size has managed to do that without relying on backup from other sources precluded by the Climate Act or other zero emissions resources unavailable in New York to the extent required.

Suggested comment:

The fact that no jurisdiction anywhere has successfully developed an electric system that relies on wind, solar, and energy storage resources to the extent proposed by the Climate Act should be an overriding concern. The Scope notes that “The 2019 Climate Leadership and Community Protection Act guided the preparation of the Scoping Plan.”

It is concerning that the Energy Plan Scope “will be informed by recommendations made” and “will incorporate and assess energy policy and program recommendations” of the 2022 New York State Climate Action Council Scoping Plan.

The Scoping Plan failed to demonstrate that its proposed strategies can feasibly maintain current levels of reliability, affordability, environmental and public health impacts, and economic growth. The Scope for the Energy Plan should emphasize the need to prove the Scoping Plan strategies will work.

Dispatchable Emissions-Free Resources

In my first article on the NYCP webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability. During periods of extended low wind and solar resource availability, the responsible agencies agree that a new dispatchable emissions-free resource (DEFR) is needed.

The presumption that a DEFR technology can be deployed that will improve reliability and resilience and still be affordable is no sure thing. There are technological hurdles that must be overcome which are uncertain because of limitations imposed by the Second Law of Thermodynamics and even if those physical constraints can be overcome the costs are still a challenge.

In addition, the most likely DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready. However, nuclear power is better suited as the backbone of the electric system than simply as backup. Using nuclear instead of relying on wind, solar, and energy storage resources has significant advantages. The Scope should highlight these concerns and emphasize resolving the DEFR is a priority because it may make the current path a dead end.

Suggested comment:

The agencies and organizations responsible for electric system reliability agree that during periods of extended low wind and solar resource availability, a new dispatchable emissions-free resource (DEFR) is needed. Because there are technological hurdles that must be overcome, resolving the feasibility of DEFR while maintaining reliability and affordability standards must be a stated priority for the Energy Plan Scope.

Section VII Nuclear Energy

Dave Dibbell sent me the comment that he submitted. It is too good not to include.

Suggested comment:

Consideration of reliable, non-emitting nuclear power generation raises an important point about the timing and order of decisions. An early choice to pursue a menu of nuclear options as a primary element of the plan obviates the need to promote intermittent wind and solar sources.

Minimizing the adoption of new intermittent wind and solar sources (for grid supply) also minimizes the need for costly storage systems. A future nuclear-focused system could end up as the lowest-overall-cost, highest-reliability configuration to support the multiple end-goals of the Plan.

Therefore, it is important to address this strategy choice early, supported by comprehensive cost and feasibility studies for the system as a whole. Otherwise, the pressure to reduce emissions will drive a proliferation of current-technology intermittent sources and storage systems to the detriment of overall cost and reliability. This would be a most regrettable outcome.

Response Transparency

The stakeholder comment process for the Scoping Plan did not incorporate a response to comments component. Given the complexity and impacts of the proposed changes to the Energy Plan public reconciliation of comments received must be included. For example, the electric system resource (including DEFR) projections in the Scoping Plan are significantly different than the projections made by the New York Independent System Operator and independent analysts.

The Energy Planning Board needs to understand potential controversies regarding all the components of the energy system. In my personal comments on this topic, I suggested that important issues be reconciled at a public meeting.

Suggested comment:

The Climate Act mandated transition of the New York energy system is an extraordinarily complicated experiment because of its scope, magnitude, and technological challenges. To ensure that all aspects of the issues associated with this experiment are addressed it is appropriate to publish all comments received and the disposition of the comments.

It is important that the Energy Planning Board be aware of all topics raised by the commenters. In fact, it is so important that controversial topics and inconsistencies between independent analyses should be reconciled through a public process. The Energy Plan Scope should acknowledge this requirement.

Conclusion

The New York Energy Plan will affect the lives of everyone in New York. The Hochul Administration has not been forthcoming about the costs and potential reliability impacts of all the mandates. Homeowners should consider that the costs to convert to an all-electric home and upgrade the building shell as needed have never been documented. It is also not clear how homeowners are supposed to cope with an extended electric outage when their home and transportation is electrified. I think skeptical comments suggesting that New York State provide proof that their plans will work is appropriate.

Clean energy advocates and idealogues are swamping the comments with form letters.

Please consider submitting a comment to the following site so that there are at least some comments that ask for a reality-based approach.

When you click on the link it will ask some questions and then you can copy and paste the following. If you have time I encourage you to modify the following to include your specific concerns.

Copy and paste comments:

Thank you for the opportunity to comment on Energy Plan Draft Scope. I am concerned that the Draft Scope relies too much on the 2022 Climate Action Council Scoping Plan. The Scoping Plan provides no proof that the strategies in the plan can feasibly meet the energy needs of New York society while maintaining current standards of reliability and affordability. The Energy Plan must prove those standards can be met. I offer the following specific comments.

Feasibility: Because reliable, abundant, affordable energy is a prerequisite of our society, the Energy Plan needs to provide details and proof that the Scoping strategies affecting the electric, building, transportation, commercial and industrial sectors will work as proposed. The Energy Plan Scope must emphasize the need for analyses that demonstrate that the proposed transition can meet present standards of reliability and affordability for each sector.

Affordability: The Scoping Plan consumer affordability analysis only considered the costs of the Climate Act mandates and not costs associated with “already implemented policies”. The Scope for the Energy Plan should make it clear that affordability analyses will include all costs associated with the Climate Act net-zero transition no matter the legislative or regulatory mandate.

Electric System Feasibility: The fact that no jurisdiction anywhere has successfully developed an electric system that relies on wind, solar, and energy storage resources to the extent proposed by the Climate Act should be an overriding concern. The Scope notes that “The 2019 Climate Leadership and Community Protection Act guided the preparation of the Scoping Plan.”

It is concerning that the Energy Plan Scope “will be informed by recommendations made” and “will incorporate and assess energy policy and program recommendations” of the 2022 New York State Climate Action Council Scoping Plan. The Scoping Plan failed to demonstrate that its proposed strategies can feasibly maintain current levels of reliability, affordability, environmental and public health impacts, and economic growth. The Scope for the Energy Plan should emphasize the need to prove the Scoping Plan strategies will work.

DEFR: The agencies and organizations responsible for electric system reliability agree that during periods of extended low wind and solar resource availability, a new dispatchable emissions-free resource (DEFR) is needed. Because there are technological hurdles that must be overcome, resolving the feasibility of DEFR while maintaining reliability and affordability standards must be a stated priority for the Energy Plan Scope.

Section VII Nuclear Energy: Consideration of reliable, non-emitting nuclear power generation raises an important point about the timing and order of decisions. An early choice to pursue a menu of nuclear options as a primary element of the plan obviates the need to promote intermittent wind and solar sources. Minimizing the adoption of new intermittent wind and solar sources (for grid supply) also minimizes the need for costly storage systems.

A future nuclear-focused system could end up as the lowest-overall-cost, highest-reliability configuration to support the multiple end-goals of the Plan. Therefore, it is important to address this strategy choice early, supported by comprehensive cost and feasibility studies for the system as a whole. Otherwise, the pressure to reduce emissions will drive a proliferation of current-technology intermittent sources and storage systems to the detriment of overall cost and reliability. This would be a most regrettable outcome.

Transparency: The Climate Act mandated transition of the New York energy system is an extraordinarily complicated experiment because of its scope, magnitude, and technological challenges. To ensure that all aspects of the issues associated with this experiment are addressed it is appropriate to publish all comments received and the disposition of the comments. It is important that the Energy Planning Board be aware of all topics raised by the commenters. In fact, it is so important that controversial topics and inconsistencies between independent analyses should be reconciled through a public process. The Energy Plan Scope should acknowledge this requirement.

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This post represents his opinion alone and not the opinion of his previous employers or any other company with which he has been associated. Roger has followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and has written over 480 articles about New York’s net-zero transition.

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