REV and the Cuomo Administration

One of my biggest concerns about Reforming the Energy Vision (REV) is that the Cuomo Administration is so invested in it that they consider any criticism as heresy and respond accordingly. As evidence consider the Richard Kaufmann letter to the New York Independent System Operator (NYISO) regarding the NYISO Comments on Clean Energy Standard July 2016.

Richard Kaufman is Governor Cuomo’s energy czar. According to his New York State Energy and Research Development Authority (NYSERDA) biography: “Mr. Kauffman oversees and manages New York State’s entire energy portfolio, including the New York State Department of Public Service, the New York Power Authority, the Long Island Power Authority, and the New York State Energy Research and Development Authority.” He also “leads” the REV initiative. While his work history includes impressive positions at the U.S. Department of Energy and big businesses, his education (Bachelor’s degree in African History from Stanford University, a master’s degree in international relations from Yale University, and a master’s degree in public and private management from the Yale School of Management.) does not include any background in science and technology.

The Kaufmann letter to NYISO July 2016 states that the filing “reveals an alarming lack of developed analysis and understanding of the imperative to address climate change by transitioning to a clean electric system, and how a modern grid can be developed and operated.” He goes on to chastise the NYISO because they don’t understand that their “paradigm of analysis is outdated”.

So what did the “engineers, operators, analysts, economists, and technologists” of the independent source of “factual information to policymakers, stakeholders, and investors in the power system” at the NYISO say to earn this response? They dared to suggest that adding the amount of solar panels and wind turbines to the grid needed to achieve the Clean Energy Standard could overload the transmission system. They also explained that meeting the goal would require the state to dramatically increase the amount of reserve capacity it sets aside.   Even though NYISO was careful to point out that it supports Cuomo’s vision, they said New York would have to add a large amount of new transmission lines and would have to study more how to manage the added renewable electricity generation, which is naturally intermittent, that would be added to the grid. Ultimately they estimated that the Clean Energy Study could require “nearly 1,000 miles of new bulk power transmission.”

Clearly, Kaufmann has no technical background for his criticism of the NYISO. So he must rely on the staff of the Department of the Public Service whose mission is to “ensure affordable, safe, secure, and reliable access to electric, gas, steam, telecommunications, and water services for New York State’s residential and business consumers, while protecting the natural environment.” Unfortunately, Cuomo has refashioned the Public Service Commission “into an organ of executive power in ways that critics find unprecedented and potentially troubling”. In particular, Cuomo has filled the Commission mostly with allies who rarely if ever defy his wishes on energy policy and I believe that attitude has filtered down to the agency staff. Any staff professional in the DPS, or for that matter any agency in Albany, who has doubts about any aspect of Cuomo’s energy plans need only look at the response of Kaufmann to a well-qualified independent organization and decide that discretion is a better career path than to object to the language in the letter.

Cuomo State of the State 2018: Climate Agenda

Governor Cuomo unveiled a comprehensive agenda to combat climate change by reducing greenhouse gas emissions and growing the clean energy economy in the 2018 State of the State. This is directly related to Reforming the Energy Vision (REV), his plan to “rebuild, strengthen and modernize New York’s energy system. The ultimate goal of REV is to change the energy system of New York to reduce greenhouse gas (GHG) emissions 80% from 1990 levels by 2050 (“80 by 50”). In order to achieve that goal specific programs have to be implemented and this agenda lists another round. I will address each of the seven items in the aptly named agenda.

 Expand Regional Greenhouse Gas Initiative (RGGI) and Reduce Emissions Equitably From the Highest-Polluting, High Demand “Peaker” Power Plants

According to the announcement: “In 2013, Governor Cuomo led the nine RGGI states in reducing the cap on greenhouse gas emissions from power plants 50 percent by 2020. Since that time, RGGI has continued to exceed expectations, providing over $2 billion in regional economic benefits and public health benefits of $5.7 billion while reducing emissions more than required by the declining cap. In August 2017, the other RGGI states agreed to Governor Cuomo’s 2017 State of the State call to reduce the cap another 30 percent by 2030.”

RGGI is a pollution control program that auctions authorizations to emit each ton of CO2 from power plants. New York took the lead in recent revisions to the operating rules of RGGI that include an additional 30% reduction in emissions from 2021 to 2030. In my other blog I have posted technical evaluations of various aspects of RGGI. In late 2017 the Department of Environmental Conservation (DEC) and the New York State Energy Research and Development Authority (NYSERDA) released and asked for comment on documents that I used to determine the potential effectiveness of programs that use auction revenues to, in Cuomo’s words, “fight climate change and protect our environment, while supporting and growing 21st century jobs in these cutting-edge renewable industries.” I found that the program investments will only provide 10% of the reductions that Cuomo agreed to. Fuel switching from coal and residual oil to natural gas was the primary reason emissions dropped since 2005 and the problem is that there are limited opportunities for further reductions. Given that simply using their own numbers to determine the effectiveness of their investments does not portend well for this aspect of the State of the State climate agenda.

The agenda also includes a component to include peaker units in RGGI. Currently, RGGI only covers power plants with a capacity of 25 megawatts or greater, leaving out many smaller but “highly-polluting, high demand ‘peaking’ units, which operate intermittently during periods of high electricity demand”. There are approximately 100 of these peaking turbines in New York City and on Long Island. My initial estimate is that those turbines emit about 1.4% of the total CO2 emissions from units already covered by RGGI. The term much ado about nothing springs to mind.

Issue Solicitations in 2018 and 2019 to Develop at Least 800 MW of Offshore Wind Projects and Foster Offshore Wind Industry and Workforce in New York State

According to the announcement: “In the 2017 State of the State, Governor Cuomo took the bold step of establishing a target of up to 2.4 gigawatts of offshore wind by 2030, the largest commitment to offshore wind power in U.S. history. To position New York as the leading offshore wind market in the United States and to drive competition, reduce costs and create new well-paying jobs, this year Governor Cuomo is calling for a procurement of at least 800 megawatts of offshore wind power between two solicitations to be issued in 2018 and 2019, resulting in enough clean, renewable energy to power 400,000 New York households.”

Cuomo’s offshore wind proposals are pretty vague about the costs. Steve Gorham notes that “the Deepwater Wind Block Island project of Rhode Island takes first prize for outrageous renewable electricity cost. The five-turbine offshore system went into operation in 2016 at a contracted price of 23.6 cents per kW-hr, with an annual increase of 3.5 cents, placing the future price at over 40 cents per kW-hr.” According to the Energy Information Administration the October 2017 New York City wholesale electricity prices annual range was between 2.1 cents per kW-hr and 12.1 cents per kW-hr. Another analysis of offshore wind concluded as a rule of thumb “offshore wind capex wind costs to be about double onshore wind costs, and offshore maintenance costs to be somewhat unknown, but definitely higher than onshore wind costs.” The fact that the State has not provided costs is troubling but I fear these costs will significantly affect ratepayer costs.

 $200 Million Investment to Meet Unprecedented Energy Storage Target of 1,500 Megawatts by 2025 In Order to Increase Transmission of Clean and Renewable Energy

According to the announcement: “The Governor is also proposing a commitment of at least $200 million from NY Green Bank for storage-related investments to help drive down costs and to strategically deploy energy storage to where the grid needs it most. Finally, the Governor is directing NYSERDA to invest at least $60 million through storage pilots and activities to reduce barriers to deploying energy storage, including permitting, customer acquisition, interconnection, and financing costs.”

Under another related heading the announcement notes: “The Governor is also proposing a commitment of at least $200 million from NY Green Bank for storage-related investments to help drive down costs and to strategically deploy energy storage to where the grid needs it most. Finally, the Governor is directing NYSERDA to invest at least $60 million through storage pilots and activities to reduce barriers to deploying energy storage, including permitting, customer acquisition, interconnection, and financing costs. In addition to utility procurements and regulatory changes, these investments will be critical to jumpstart the market and support robust and cost-effective project development on the way to achieving the 1,500 megawatt goal.”

Because renewable energy is intermittent, storage is an absolute requirement to provide dispatchable power when the wind is not blowing and the sun is not shining. I suppose that the “plan” is to use renewables to replace the high demand peaker turbines. As noted there are about 100 of these turbines and they are at least 20 MW each for a total output of 2,000 MW. More importantly those turbines can run as long as needed to cover the peak generation requirements. If that is just four hours that means they produce 8,000 MWh. I have been unable to find out the equivalent output for the batteries but strongly suspect that it is short. For example the much acclaimed giant Tesla battery just installed in Australia has a capacity of 100 MW but only 129 MWh. So the question is just how much capacity will these investments get?

 Create the Zero Cost Solar for All Program for 10,000 Low-Income New Yorkers

According to the announcement: “Reducing the energy burden of low-income households and ensuring their participation in the clean energy economy are central goals in Governor Cuomo’s energy policies. The Governor’s REV strategy aims to ensure that the economic, environmental and health benefits of clean energy are accessible to New Yorkers who are most in need. In 2016, Governor Cuomo also unveiled the Energy Affordability Policy to limit energy prices and provide direct cost relief for low-income New Yorkers, and expanded it the following year to bring the total program benefits to $260 million.”

The testimony of William D. Yates, CPA for the Public Utility Law Project of New York, on August 25, 2017 in the Niagara Mohawk Power rate case listed the poverty rates of Upstate New York cities. For example the City of Albany has a poverty rate of 26.8%. The population of Albany is 97,856 so there are 26,255 low-income New Yorkers in Albany alone. As a result the 16,255 New Yorkers in Albany that don’t get the zero cost solar for all benefits will have to subsidize those that do. Raising energy prices is amounts to a regressive tax that is particularly harmful to those least able to pay. Claiming that “reducing the energy burden of low-income households” is clearly not going to happen overall.

 Reconvene Scientific Advisory Committee on Climate Change Disbanded by the Federal Government

According to the announcement: “In June 2017, Governor Cuomo formed the U.S. Climate Alliance with the Governors of California and Washington State to ensure that New York State and other willing partners continue to meet or exceed the targets of the Paris Agreement on climate change. After announcing its withdrawal from the Paris Agreement, the federal government took another misguided step by disbanding the Federal Advisory Committee for the Sustained National Climate Assessment, a group of leading scientists and stakeholders tasked with providing recommendations to the federal government on scientific information to support state and local governments, communities, and the private sector in planning for the effects of climate change. In the absence of guidance from the Advisory Committee, decision-makers will have limited ability to know how climate change will impact their organizations and communities, and what they can do to better plan for those impacts. Therefore, Governor Cuomo, as co-chair of the U.S. Climate Alliance and in collaboration with partners, will reconvene the Advisory Committee to develop recommendations to navigate the challenges of climate change. As a result, the Advisory Committee will continue its critical work without political interference and provide the guidance needed to adapt to a changing climate.”

The scientists on the scientific advisory committee have provided fodder for Cuomo’s agenda so it is not surprising that they have figured out a way to continue that work. Personally, because it was a political decision to stop funding the committee that existed only to fan the flame of catastrophe as a rationale for all the programs, claiming that it will continue its work “without political interference” is laughable.

 Governor Directs the Establishment of Energy Efficiency Target by Earth Day

According to the announcement: “Building on the progress made through utility programs and cutting-edge work to reduce energy use in state facilities, Governor Cuomo launched the $5 billion Clean Energy Fund in 2016 to support investment in energy efficient technologies. This initiative is already demonstrating significant progress across New York State, from Upstate farms and greenhouses to commercial buildings in Manhattan. These activities are expected to save New Yorkers a remarkable $39 billion in energy costs over the next 10 years while significantly reducing greenhouse gas emissions.”

 I support energy efficiency programs because it represents a “no regrets” policy and because it can be targeted for the low-income ratepayers most in need of reducing their energy bills from what I see as inevitable major increases with these renewable energy policies. Unfortunately, New York has been pushing energy efficiency for years so I suspect that most of the low-hanging fruit available for big reductions has already been picked. I also note that I understand that the weatherization assistance program has an over four year waiting list for services. Therefore, despite my reservation I believe this is the best of the options proposed by the governor.

 Regulations to Close all Coal Plants to be Adopted

According to the announcement: “Moreover, in order to immediately reduce emissions from New York’s highest-polluting power plants Governor Cuomo directs the DEC to adopt regulations ending the use of coal in the state’s power plants by 2020. At the same time, Governor Cuomo created the Electric Generation Facility Cessation Mitigation Fund to address the needs of the local communities affected by any closure.”

Normally a Governor asks the DEC to propose regulations but note that Cuomo has directed DEC to adopt the regulations. Needless to say even if Moses brought down an eleventh commandment saying ye shall not close the coal plants that or any other argument would sway DEC from its political directive to shut down coal. I have worked in New York for over 35 years and we used to be proud of the fuel mix of hydro, coal, natural gas, oil and nuclear. Those fuels enabled the power plants to provide dispatchable power (i.e., supply energy whenever needed whatever the weather) and play off one fuel against the other to give NY residents cheaper power. The shale gas revolution (despite the Governor’s ban on NY drilling) has flipped that approach completely upside down but I think it would be more appropriate to let the market dictate fuel use rather than the politicians. It also should be pointed out that now the state is very reliant on natural gas. Aside from the real threat of a supply disruption from some unforeseen event (an earthquake could affect pipelines) the Governor has also been blocking the development of natural gas infrastructure even to the point of blocking a pipeline to a nearly complete power plant.

Appendix A DPS REV Staff Report Wholesale Market Products

Reforming the Energy Vision (REV) is Governor Cuomo’s plan to “rebuild, strengthen and modernize New York’s energy system.  The REV DPS Staff Report and Proposal (available at DPS Staff Reports April 24, 2014) contains a very good description of the wholesale electric market in Appendix A (reproduced below). In order for REV to be successful the services described below must be maintained.

In order to understand the rationale of REV you have to understand how electricity generated at power plants gets to your home. Before the New York electric system was de-regulated, your power company was responsible for generating power, transmitting it over the big transmission lines to your neighborhood where the distribution power lines delivered it to your home. After de-regulation your power company is no longer responsible for generating[1] the power only delivering it.

In the de-regulated system the New York Independent System Operator regulates the generation of power to the system where it can be sent to your home. Appendix A (quoted below) describes the wholesale market products that are used to govern those transactions. Day to day power needs are met with a couple of products. Energy markets balance electrical power needs against the power generating plants capabilities to insure that the power needed is available. The Day Ahead Demand Response Program is an option where instead of turning on an additional generating unit a facility offers to use less power instead.

In addition to the day to day power variations there are seasonal variations with the main reliability issue being a peak load day. Capacity Markets guarantee that when the peak loads occur that there are enough generating plants available to provide the necessary power where and when it is needed.

The power generation, transmission and distribution system is connected and synchronized. In order to provide the requirements for the system to be connected and synchronized NYISO operates markets for “ancillary services.” There are five separate categories of ancillary services. Regulation services continuously balances load and power supply. Voltage support services maintain the system voltage. , Synchronous and non-synchronous reserves are used to address emergency contingencies during daily operations while black start services are used to startup the system when there is a blackout. Finally there are demand side ancillary services. These are analogous to the day ahead demand response program whereby they facilitate the use of demand side resources to meet the needs of the services described above.


In summary, in order for REV to be successful all these services have to be maintained. The inconvenient issue is that some of the proposed components of REV behave markedly different than components of the existing system. Consequently providing these services at lower costs while maintaining reliability is an ambitious goal and one that must be addressed in the plans.


April 24, 2014 — Reforming the Energy Vision DPS Staff Report and Proposal

Appendix A Wholesale Market Products

 Energy Markets

At present, the NYISO operates a number of wholesale competitive markets. There are two distinct markets for the electric energy, the Day-Ahead market, and the Real-Time market. Approximately 98% of the electric energy used in the State is scheduled in the Day-Ahead market with the remaining 2% accounted for in the Real-Time market.

In the Day-Ahead market, the NYISO co-optimizes the Energy, Operating Reserves and regulation markets by utilizing bid-based Security Constrained Economic Dispatch (SCED) and Security Constrained Unit Commitment (SCUC). Day-ahead bids are due by 5:00 a.m. on the day before the unit will run, and the NYISO posts the day-ahead schedules and the market clearing prices by 11:00 a.m. Clearing prices are based on LBMP (Locational Based Marginal Pricing), which is the cost to supply the next MW of load at a specific location in the grid. By so doing the NYISO ensures that resources are available to satisfy loads that are forecast for the day.

The NYISO also runs Real-Time markets to efficiently and economically balance actual system loads and a large number of changes continuously taking place on the system, such as unanticipated transmission and generation outages. Real-time bids are due 75 minutes prior to the hour of operation. Differences between day-ahead schedules and actual load and generation are priced at real-time LBMPs, which are calculated every 5 minutes.

 Day Ahead Demand Response Program (DADRP)

The DADRP allows end-users to participate in the day-ahead energy market by offering load reduction bids. DADRP participants are paid at the LBMP market price for the amount of their winning bid and have a performance obligation much like winning generators. Participation in the NYISO‟s DADRP is currently limited to curtailable load. A recent FERC Order, however, ruled that behind-the-meter generation must also be allowed to participate. Eligibility is limited to providers that can demonstrate an ability to curtail at least 1 MW of load, and at present, there is a $75/MWh minimum offer floor. However, in the NYISO‟s compliance filing in response to FERC‟s Order 745, the new monthly floor will be determined through the application of a “net benefits test.”

 Capacity Markets

The NYISO establishes Installed Capacity (ICAP) requirements to ensure sufficient resources are available to adequately serve the forecasted summer peak New York Control Area (NYCA) system load. ICAP suppliers must satisfy semiannual tests of maximum output, and must meet deliverability requirements (sufficient transmission to reach load in their respective capacity regions). The NYISO operates capacity markets to facilitate the purchase, by Load Serving Entities (LSEs), of the capacity they are required to procure. In this context, “capacity” is not the electricity itself, but instead the ability to produce electricity when necessary.

ICAP requirements are set based upon projected peak NYCA load, plus an additional reserve amount to ensure the system can reliably serve peak demand even in cases of unplanned outages (known as “contingencies”). This reserve amount is known in New York as the “Installed Reserve Margin” (IRM). In addition to the Statewide IRM, the NYISO imposes minimum Locational Capacity Requirements (LCRs) in areas of the State that have limits on their ability to import power from outside areas. Thus, there are LCRs established for New York City (Zone “J”), Long Island (Zone “K”), and the newly established Lower Hudson Valley capacity zone (Zones “G” through “J”). LSEs are subject to ICAP requirements based on their respective share of coincident system peak load for the State (i.e., the IRM). Where applicable, they must satisfy part of that requirement with resources which are electrically located within their Zone.

All ICAP supplies must “clear” in the mandatory, NYISO-administered, “spot” markets, which are held monthly. LSE bids in the spot auctions are determined by administratively-set “demand curves”. Supply offers in New York City (Zone “J”) and the Lower Hudson Valley (Zones “G” through “J”) are subject to bid caps (for incumbent suppliers) and bid floors (for new entrants), under market power mitigation rules established by FERC. ICAP suppliers within a zone subject to LCRs (i.e., Zones “J,” “K,” and “G” through “J”) receive the higher of the statewide capacity price or the applicable locational price for their respective zones. The NYISO also operates voluntary forward auctions, for the summer (May-October) and winter (November-April) capability periods. Supplies obtained in the forward auctions must also be offered into and clear the spot auctions in order to satisfy LSE ICAP requirements.

 Ancillary Services Markets

In addition to the energy and capacity markets, the NYISO operates markets for “ancillary services.” There are five separate categories of ancillary services at the wholesale/bulk power system level: regulation services, voltage support services, synchronous and non-synchronous reserves, black start services, and demand side ancillary services. These will each be briefly discussed in turn.

 Regulation Services

System “regulation” is the practice of continuously balancing power supply resources with load. Regulation service is accomplished through transparent day-ahead and real-time markets which receive bids from participating, qualified energy suppliers (having automatic generation control capability), demand-side resources (also see DSASP) and energy storage resources. A bid evaluation program selects specific resources and the amount of power to be delivered on the basis of each participant’s bid price, unit response rates, location and existing transmission constraints. Updates to the desired generation levels expected from each unit, occur every six seconds.

 Voltage Support Service

Voltage Support, more formally known as Reactive Supply and Voltage Control Service (“Voltage Support Service” or VSS), is necessary to maintain transmission voltages within acceptable limits. Facilities under the NYISO control are operated to produce or absorb reactive power, as necessary, to maintain transmission voltages within acceptable limits.

VSS facilities must meet a number of criteria to be eligible to participate. For example, they must have a demonstrated the ability to produce and absorb reactive power within specific limits, be able to maintain a specific voltage level under both steady-state and post-contingency operating conditions, and be capable of automatically responding to voltage control signals. In general, eligible VSS providers are generators with automatic voltage regulators, synchronous condensers, and qualified non-generator Voltage Support Resources.

Payments to eligible providers are based on an annual VSS rate established by the NYISO. Generators that are given energy delivery schedules may be eligible to receive lost opportunity costs under certain circumstances when dispatched for voltage support reasons. VSS providers can also be assessed penalties if they fail to provide VSS as directed or if they fail to maintain their automatic voltage regulators.

 Synchronized and Non-Synchronized Reserves

To ensure reliable operation of the bulk power system, the NYISO‟s “Operating Reserve Service” provides needed reserves in the form of generation or demand response if a real time power system contingency requires emergency corrective action. The NYISO provides markets for 10-minute spinning, 10-minute non-synchronized, and 30-minute non-spinning reserves with a NYCA-wide requirement as well as an Eastern and Long Island requirement and a Long Island requirement.

The minimum reserve requirements are based on the largest single “contingency” (in MW), as defined by the NYISO. Providers of Operating Reserves must be properly located electrically and geographically to ensure the ability to deliver energy reserves as necessary. The NYISO must procure sufficient Operating Reserves to comply with applicable Reliability Rules and standards. All suppliers of Operating Reserves must be located within the New York Control Area, and under NYISO Operational Control.

The NYISO administers two ancillary services markets (Day Ahead and Real-Time) through which LSEs can procure needed resources for required Operating Reserves. Each supplier that bids into these markets must be able to provide electric energy or reduce demand when called upon.

Black Start Services

In the event of a partial or system-wide blackout, Black Start Capability Service is provided by generators having the ability to re-start their facilities without the need for an external supplier of electricity. Such black start generators are either under the control of the NYISO or, in some cases, under the control of the local Transmission Owner. The NYISO selects the generating resources with black start capability by considering a number of design and operating characteristics, including electrical location, startup time in response to a NYISO order to start, response rate, and maximum power output.

Generation resources providing black start service must successfully conduct and pass annual black start capability testing. Payments for service, called Restoration Services payments, are provided under the NYISO‟s Open Access Transmission Tariff. Any Generator awarded Restoration Services payments that fails a Black Start Capability Test must forfeit all payments for such services since its last successful test.

 Demand Side Services

The NYISO also administers a Demand Side Ancillary Services Program (DSASP) intended to facilitate economic use of demand side resources to meet electricity needs. Participation is allowed for interruptible loads for Spinning Reserves or Regulation. Loads with qualified behind-the-meter generation may provide Non-Synchronous Reserves. The minimum resource size is 1 MW and there is a $75/ MWh minimum bid. The payment is the Regulation or Reserve clearing price.

 NYISO Demand Response Programs

The NYISO also administers several different demand response programs. These include the Special Case Resources Program (SCR), the Emergency Demand Response Program (EDRP), and the Day Ahead Demand Response Program (DADRP)

Special Case Resources

Participation in the NYISO‟s SCR Program is open to interruptible loads or loads with a qualified behind-the-meter Local Generator. There is a minimum of 100kW reduction, and participation is mandatory during reliability events. There is a mandatory test each capability period and capacity can be sold either in a bilateral contract or through the NYISO capacity auctions. Payments are in capacity and energy payments.

Emergency Demand Response

Participation in EDRP is open to interruptible loads or loads with a qualified behind-the-meter generator. Load reduction is voluntary and there is a minimum of 100 kW reduction for participation. Participants are compensated through an energy payment equal to the greater of $500/ MWh or the applicable real-time LBMP.

[1] There are exceptions to this rule but in general your power company no longer generates its own power.

New York GHG Emissions and Energy Use Trends

Reforming the Energy Vision (REV) is Governor Cuomo’s plan to “rebuild, strengthen and modernize New York’s energy system. The ultimate goal of REV is to change the energy system of New York to reduce greenhouse gas (GHG) emissions 80% from 1990 levels by 2050 (“80 by 50”). This post summarizes the status of NY emissions and energy use.

The New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends document provides both CO2 emissions and energy use data but I used the NYSERDA New York State Greenhouse Gas Inventory and Forecast report for Table 1 New York GHG Emissions, Historical and Targets. According to the Inventory report 1990 NY total GHG emissions were 235.8 million metric tons of Carbon Dioxide equivalent (CO2e). I assumed that was the total emissions used to calculate the reductions necessary to meet the 80 by 50 goal. However, note that fuel combustion accounts for 205.8 million metric tons. There is another category for “other” sources including CO2 from municipal waste combustion, cement production, limestone and soda ash use, and iron and steel production; methane, nitrous oxides, perfluorocarbons, hydrofluorocarbons and sulfur hexafluoride emissions. The report also mentions that energy-related emissions, a category calculated as part of New York’s State Energy Plan that includes fuel combustion, net electricity imports, power supply & delivery, and natural gas leakage were 212.87 million metric tons.

Figure 1 shows the trends in New York State CO2e emissions, energy (TBtu) and CO2e intensity which is the emissions divided by the energy. Note that the energy used in New York rose until 2005 and has since started to drop while the pattern of CO2e has ebbed and flowed more but has also dropped since 2005. In order to determine the viability of the 80 by 50 goals it is necessary to look at what drove those trends.

In order to reduce GHG emissions there are three direct approaches:

  1. Replace energy sources that generate GHGs with ones that don’t
  2. Energy efficiency – use energy more effectively
  3. Energy conservation – use less energy

In addition there are a couple of indirect ways: reduce the population and reduce the gross state product or economic growth. I mention those two methods to point out that neither approach is politically palatable as an approach to reduce GHG emissions and that historically the gross state product has increased and population has stayed relatively constant.

The NYSERDA Patterns and Trends document contains the energy and emissions data by sector needed to evaluate the causes of the observed reductions. Figures 2 and 3 show the trend of primary energy consumption by the residential, commercial, industrial, transportation and electric energy production sectors by total energy use (TBtu) and % of total. Residential has bounced around but is effectively the same since 1080 and the commercial sector trended up but has trended down to roughly the same levels as 1990. Given the growth in the economy it appears it appears to me that investments in conservation and efficiency have produced some results. The most notable decrease has been the industrial sector, down over 200 TBtu since 1980. While efficiency and conservation have helped with that it is more likely a result of the decline of the industrial sector in New York. Transportation energy use has grown consistently since the mid-80’s. The electricity sector grew until approximately 2005 and has since dropped. It does not appear on the basis of historic trends that energy conservation and energy efficiency will be major factors for compliance with the emissions goals.


That leaves carbon emission reductions to make the majority of the reductions necessary. Figures 4 and 5 show the trend of GHG emissions by the residential, commercial, industrial, transportation and electric energy production sectors and % of total. Note that these are emissions from fuel combustion only so the totals are not the same as shown before. The emissions trends for residential, commercial, industrial and transportation sectors are similar to the energy trends. Residential and commercial are roughly the same, industrial is down, and transportation is up. Electricity sector emissions are down more than the total energy.


Renewable wind and solar energy are supposed to make major contributions to the emissions reductions necessary for the 80 by 50 goal. As a result, we need to evaluate the sources of electricity generated in New York. Figure 6 shows the percentage of electricity provided by different sources: coal, natural gas, petroleum (residual oil and distillate), hydro, nuclear, imports, other (landfill gas & biomass), wind and solar. Coal and petroleum have gone down significantly since 1990. Natural gas has increased significantly as has imports. After Nine Mile Point unit 2 came on-line nuclear has stayed about the same as has hydro. In the past few years enough solar and wind have come on line to appear on the chart. Figure 7 shows the total energy provided by the same categories. Clearly the biggest changes have been the reduction of coal and petroleum fuel use and increase of natural gas and imports.


In order to determine how much carbon free renewable energy can directly affect CO2e emissions we need to look at the electric sector emissions relative to emissions from the rest of New York State. Figure 8 shows the trends and Table 2 NYS Combustion Source CO2 Emissions by Electric Sector and Rest of State shows the data. Statewide coal and electric sector oil have gone down 55 million metric tons but since 1990 natural gas has gone up. It can be argued that for the most part the major decreases in coal and oil were the result of changes in the relative cost of fuel and had nothing to do with New York State policy. Moreover, the State has drafted regulations to eliminate the use of coal so renewable energy deployment will not drive further emissions reductions from coal and there are only 3.9 million metric tons of reduction available anyway. With respect to electric sector emissions, no further oil use reductions are expected because the current levels represent the minimum emissions necessary to maintain oil as a backup and emergency use fuel. That leaves natural gas emissions.

Overall, the total emissions in 2015 are only down 18% from 1990 levels to 169.5 million metric tons and the 2030 target is 141.5 million metric tons so further reductions of 28 million metric tons are necessary in the next 15 years. If renewable energy sources completely replaced fossil emissions that would provide reductions of 29.2 million metric tons. There are significant technological hurdles to doing that so I believe that is an unrealistic goal. On the other hand the primary way to reduce emissions from the other sectors is to replace fuel combustion with electricity. The great challenge of REV is how to meet that additional expected demand without increasing CO2 emissions


How Much Will REV Affect Global Warming

Reforming the Energy Vision (REV) is Governor Cuomo’s plan to “rebuild, strengthen and modernize New York’s energy system. The ultimate goal of REV is to change the energy system of New York to reduce greenhouse gas (GHG) emissions 80% from 1990 levels by 2050 (“80 by 50”). The over-riding rationale for the need to do this is to mitigate the impacts of global warming. Inconveniently, the State has never quantified just how much the proposed plan will affect global warming.

In the absence of any official quantitative estimate of the impact on global warming from REV or any other New York State initiative related to climate change I did my own calculation. I simply adapted data for this emission reduction from the calculations in Analysis of US and State-By-State Carbon Dioxide Emissions and Potential “Savings” In Future Global Temperature and Global Sea Level Rise.  This analysis of U.S. and state by state carbon dioxide 2010 emissions relative to global emissions quantifies the relative numbers and the potential “savings” in future global temperature and global sea level rise.   These estimates are based on the MAGICC: Model for the Assessment of Greenhouse-gas Induced Climate Change) so they represent projected changes based on the Intergovernmental Panel on Climate Change estimates. All I did in my calculation was to pro-rate the United States impacts by the ratio of New York emissions divided by United States emissions to determine the effects of a complete cessation of all CO2 emissions in New York State as well as the REV plan for the 167.1 million metric ton reduction.

The first step is to quantify NY emissions. The New York State Energy Research and Development Authority Patterns and Trends document provides CO2 emissions data. In 1990 the NY total was 235.8 million metric tons so the reduction to the REV goal of 80% is 188.7 million metric tons. The New York impacts were calculated by the ratio of the NY emissions reductions to the US reductions in the report. For example, the NY % of global total emissions equals the % of US global total (17.88%) times the REV reduction emissions goal (188.7) divided by the US emissions (5,631.3).  Table 1 Analysis of Carbon Dioxide Emissions and Temperature Savings lists the results.

These calculations show current growth rate in CO2 emissions from other countries of the world will quickly subsume New York total emissions much less any reductions in New York CO2 emissions. According to data from the U.S. Energy Information Administration (EIA) and based on trends in CO2 emissions growth in 86 days. Furthermore, using assumptions based on the Intergovernmental Panel on Climate Change (IPCC) Assessment Reports we can estimate the actual impact to global warming for REV. The ultimate impact of the REV 80% reduction of 188.7 million metric tons on projected global temperature rise would be a reduction, or a “savings,” of approximately 0.0028°C by the year 2050 and 0.0058°C by the year 2100.

These small numbers have to be put in context. First consider temperature measuring guidance. The National Oceanic & Atmospheric Administration’s Requirements and Standards for NWS Climate Observations states that: “The observer will round the entered data to whole units Fahrenheit”. The nearest whole degree Fahrenheit (0.55°C) is over two hundred times greater than the projected change in temperature in 2050.

Although this change is too small to measure I am sure some will argue that there will nonetheless be some effect on the purported impacts. However if these numbers are put into perspective of temperatures we routinely feel then that argument seems hollow. For example, in Syracuse NY the record high temperature is 102°F and the record low temperature is -26°F so the difference is 128 °F which is nearly 29,000 times greater than the predicted change in temperature in 2050. The annual seasonal difference ranges from the highest daily average of 71.6°F to the lowest daily average of 23.2°F, or a difference of 48.4°F which is over 11,000 times greater than the predicted change in temperature in 2050. The average difference between the average daily high and average daily low temperature is 18.7°F or over 4,000 times greater than the predicted change in temperature in 2050. In order to give you an idea of how small this temperature change consider changes with elevation and latitude. Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000 foot increase in elevation above sea level. The projected temperature difference is the same as going down 18 inches. The general rule is that temperature changes three (3) degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level. The projected temperature change is the same as going south 0.4 miles.


I do not think that there is any question why the State has not provided a quantitative estimate of the impact on global warming from REV or any other New York State initiative related to climate change. Clearly we can expect no discernable impact. The calculated values provided in this post are based on the “consensus” estimates of the Intergovernmental Panel on Climate Change which I personally believe over-estimate the impact of temperature changes caused by greenhouse gas emissions but do represent the justification for the 80 by 50 goal. As shown claiming any observable impacts for the projected small change in temperature due to these emissions reductions is a stretch at best.

Recommended Renewable Energy Posts

I recommend that anyone who is interested in researching the story behind the complexities of the energy system and relying on renewable wind and solar energy read two series of posts at the Climate Etc and the Science of Doom blogs. In both cases the authors are trying to provoke thought and spur discussion.

The Science of Doom blog was written for “People interested in the science behind the climate stories we read about every day.” While there are a whole slew of articles that address the nitty gritty of climate science there also have been a series of posts on renewable energy. The author does a good job of not only distilling down the information but also providing links to original documents with the admonition that readers review the entire documents. The following list of links shows the topics available:

The other series of blog posts on renewable energy is at Climate Etc. Most of the posts at this blog are on climate science but guest bloggers have contributed relevant posts on this topic.  The blog posts on energy planning give a very good overview of current energy related issues. The posts were provided to provoke thought and spur discussion to provide valuable background information. They were not written to “be cited for homework, peer reviewed papers, master’s thesis or public testimony”. Unfortunately there isn’t a summary page at Climate Etc. that lists all the posts in this series so the following list will have to do: