New York Is Going Nowhere with Its Climate Act as Far as Things That Matter Are Concerned
The following is a brief condensed version of a lengthy post from Roger Caiazza regarding implementation of the Empire State's Climate Leadership & Community Protection Act (Climate Act) and may be read in full at his excellent Pragmatic Environmentalist of New York site:
On November 4, 2024, the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p was released. I described my impression of the draft definitions earlier. The DPS Staff Proposal also included a section titled “Reviewing Progress Towards Achieving the 2040 Target” that is the subject of this post.
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.
The Staff Proposal acknowledges my fundamental concern that there is no real plan for implementation. The Scoping Plan is an outline of strategies that NYSERDA’s Integration Analysis claims will reduce emissions consistent with the Climate Act mandates but there never has been a feasibility analysis of the strategies. DPS Staff “believes that it is timely to interpret provisions of PSL §66-p that authorize the Commission to consider impacts of the zero emissions by 2040 target on safe, reliable, and affordable electric service in the state.” Unfortunately, the Staff Proposal focused on timeliness and short-changed discussion of safe, reliable, and affordable electric service.
The Hochul Administration and all the state agencies involved with the Climate Act transition have ignored the fact that no jurisdiction has demonstrated that an electric system relying on wind, solar, and energy storage is viable. Francis Menton, Rich Ellenbogen and I have argued that a demonstration project that proves that the proposed transition will work is necessary before implementation proceeds. This is a fundamental safety, reliability, and affordability constraint that is not addressed in the Staff Proposal. At the very least, I believe a feasibility analysis should be the next step.
The implementation planning for the zero-emission electric grid of 2040 is inadequate to protect the mandated provisions for “safe and adequate” electric service. The Commission acknowledges that a new dispatchable and emissions free resource is needed for the projected gap between wind, solar, and energy storage resource production and expected load during periods of extended low renewable resource availability. However, the Commission has not done a comprehensive analysis to determine the magnitude and duration of the expected gap or the feasibility of potential gap backup resources.
Staff also recommends that “the Commission direct Staff to develop a review process consistent with the provisions of PSL §66-p that tracks progress toward the power sector energy transition targets. While the Staff Proposal acknowledges that the acceptability criteria for safe and adequate electric service resources must be defined, it does not fully address this issue. These are fundamental planning requirements that remain unresolved 22 months after the completion of the Scoping Plan. This should be a priority.
I am convinced that the proposed wind, solar, and energy storage approach will not be able to meet any reasonable acceptability criteria. The longer the delay in developing the criteria and comparing them to the wind, solar, and energy storage strategy, the more investments will be made in an approach that has never worked in any jurisdiction. There is no reason to expect it to work in New York. The Hochul Administration must prove it is possible with a feasibility study or better a demonstration project before continuing with this approach.
The Commission acknowledges that a new DEFR technology is needed to provide backup to wind and solar resources during extended periods of low availability. I believe that nuclear power is the only viable DEFR technology. However, using nuclear only as backup to wind and solar is inefficient and not cost effective. Given the inherent advantages of nuclear over wind and solar the obvious conclusion is that we should stop supporting wind and solar and embrace nuclear as the future backbone of the grid.
#ClimateAct #Caiazza #NewYork #Climate #Implementation #Progress
Irresponsibility at its finest. Let the lights go out and see an a giant group of apathetic people become very caring.
Oh! This will work fine after major depopulation!