Pragmatic Environmentalist of New York Summary Update May 19, 2025 – June 1, 2025
This post is a summary that I was not able to post earlier. Sorry for the delay.
This is a summary update of posts at Pragmatic Environmentalist of New York over the last two weeks. I have been writing about the pragmatic balance of the risks and benefits of environmental initiatives in New York since 2017 with a recent emphasis on New York’s Climate Leadership & Community Protection Act (Climate Act). A pdf copy of the following information and previous summaries are also available. The opinions expressed in these articles do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Status Update on New York Wind and Solar Generation Capacity Factors
The last couple of years I have described the New York Independent System Operator (NYISO) Load & Capacity Data Report (also known as the "Gold Book") and how I use it to evaluate progress of renewable energy deployments.
The capacity factor is a useful metric to understand electric generation resources. The annual capacity factor for a generator equals the actual observed generation (MWh) divided by maximum possible generation (capacity in MW times the hours in a year). I used observations to compare with projections of capacity factor used to project future energy development requirements. The 2030 land-based wind projected capacity is 34%. In 2024, Only one wind farm exceeded 34% and the overall capacity factor was up 23.4%. To achieve the assumed capacity factor for 2030 most of the existing onshore wind farms will have to be replaced and the Scoping Plan does not account for that.
Offshore wind and solar energy production was also disappointing. One of the oft-touted benefits of offshore wind is that it will have higher capacity factors. Projections by the New York Independent System Operator (NYISO) and the New York State Energy Research & Development Authority (NYSERDA) assume offshore wind capacity factors of at least 45% in 2030. The annual observed capacity factor was only 34.8%. In 2024 the capacity factor of the solar facilities in New York was 17.7%, the highest capacity factor was 22.6% and the lowest capacity factor was 12.8%. NYSERDA assumed a capacity factor of 18.2% in 2024.
The comparison of all the generating types shown in the following table shows the challenge for the transition to a wind and solar reliant energy system. For the same amount of power capacity (MW) it is necessary to build much more wind and solar to provide the same amount of energy as the existing sources. Every fuel type used fits a specific need within the system. The facilities that use number 6 fuel oil are not used much but can provide a large amount of capacity if there is an issue. Replacing that one component with wind, solar, and energy storage would be enormously expensive.
NYISO Gold Book Tables III - 2a NYISO Market Generators and Table III - 2b Non-Market Generators Capacity Factor
I recently had the opportunity to give a briefing on solar siting issues and think it is time to publish an update here to my solar siting issues page. NYSERDA is fixated on Climate Act implementation consistent with the political narrative. NYSERDA claims to “offer objective information and analysis, innovative programs, technical expertise, and support to help New Yorkers increase energy efficiency, save money, use renewable energy, and reduce reliance on fossil fuels”. In my opinion, the deployment of solar resources exemplifies NYSERRDA’s poor planning inherent in the Climate Act net-zero transition plan. I described three issues: farmland protection, agrivoltaics policy, and solar panel equipment requirements.
New York Department of Agriculture and Markets testimony for solar developments has noted that “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.” That seems reasonable to me because they are the Agency responsible for supporting New York agriculture. NYSERDA awards contracts for the Renewable Energy Standard but the fact that only 12 of the 25 solar facilities with available data at the Office of Renewable Energy Permit Applications site meet those guidelines shows that there hasn’t been a requirement for developers to meet this requirement.
Prime Farmland Scorecard Updated May 25, 2025
NYSERDA is coordinating the development of a Smart Siting Scorecard that addresses this concern. They have plenty of meetings but there is no apparent urgency to implement this protection. Worse it does not appear that a solar development can get a failing grade for not doing smart siting. In my opinion, this is lip service to the issue.
In my opinion, responsible solar siting policy would include agrivoltaics requirements that would mitigate impacts to agriculture. NYSERDA is in charge of agrivoltaics policy. Again, NYSERDA is working on it but there hasn’t been any move to require developers to incorporate agrivoltaics that support “crop production to livestock grazing and pollinator habitat”. I noted that the description of one of the related research projects demonstrates bias because the explanations of obvious negative consequences are discounted. The claim that NYSERDA offers “objective information and analysis” is not true when it comes to supporting renewable energy development.
The final issue described was based on the capacity factors analysis described previously. I compared the observed solar capacity to the projections made in analyses NYSERDA did for the Scoping Plan that outlines strategies to meet the Climate Act net-zero transition. I found that the observed solar capacity factors are lower than the NYSERDA projections. I believe that is likely because NYSERDA does not require solar developers to install tilting axis solar panels that increase energy output to obtain subsidies from the State.
NYSERDA has lost its way as a source of unbiased scientific information to guide energy policy in New York. Their Climate Act responsibilities are opaque, their work products are biased to support the political narrative, there is no sense of urgency to address obvious deficiencies in current policy, and they do not respond to stakeholder concerns. This has significant negative consequences for New York.
Champlain Hudson Power Express Payment in Lieu of Taxes Grift
It is remarkable how many ways that the costs of the Climate Act transition are hidden and applied inequitably. This article describes one example the Payment in Lieu of Taxes (PILOT) program.
One missing piece in the implementation of the Climate Act is an honest admission of costs. Not only has the State failed to provide required cost information, but there is no accounting of all the costs like the property tax exemption for renewable projects. Peter Carney explains the basis of the property tax subsidy:
New York State laws encourage projects that are aligned with specific public policies such as the development of renewable energy or infrastructure that supports the economy, in a variety of ways including Real Property Tax exemptions. The laws provide the local county, town, and schools with the option of negotiating Payment In Lieu of Tax (PILOT) agreements to compensate the local jurisdictions for some of the lost tax revenue.
There are three outcomes for these potentially tax-exempt projects:
1. The projects can be accepted as fully exempt (no tax revenues are collected) (TCSD has not done this).
2. The local entities can negotiate Payment In Lieu of Taxes (PILOT) agreements that compensate the local jurisdictions for some of the lost tax revenue. (TCSD has done this with the recent energy projects.)
3. The law also provides the affected governments with the several or joint ability to opt out of the tax exemptions provided by the state law, in which case the energy projects would be fully taxable. (The TCSD has not enacted such an opt-out provision and thus none of the energy projects will be taxed at their full value.)
New York State's Real Property Tax Law (RPTL) Section 487 provides a 15-year tax exemption for properties with renewable energy systems, including solar, wind, and other clean energy technologies. The costs of this tax forgiveness from PILOTs are not “hidden” rather the policy makers in Albany just don’t care about the costs imposed on local taxpayers. It is setup as an “opt-out” rule that requires local jurisdictions to jump through hoops if they decide not to participate. It automatically applies otherwise.
PILOT agreements are being used everywhere as jurisdictions try to entice economic development projects. My issue is that renewable energy development only provides meaningful value during the construction phase but once that flurry of activity is done, then there are very few jobs to offset the reduced taxes collected.
Peter Carney authored “A review of the Ticonderoga Central School District’s energy project PILOT agreements and impacts on taxpayers” (White Paper) that breaks down the effect of the PILOT agreements on local taxpayers. Carney prepared the white paper to “document missed opportunities for the TCSD Board of Education (BoE) to increase non-tax school revenues, estimated at more than $1 million annually, from seven new energy projects. Consequently, rather than the energy projects paying their fair share of taxes, the taxpayers of Hague and Ticonderoga will need to make up the difference.”
The White Paper included the following table that reports the level of PILOT tax exemptions reported in NY Champlain Hudson Power Express (CHPE) transmission project. The only jurisdiction that gets value for providing tax breaks is New York City and they are taxing CHPE at the full value. The opt-out provisions of New York’s Real Property Tax Law contributed to the sad state of affairs where a rural upstate school district unwittingly subsidizes a renewable energy project that provides no direct benefits to its taxpayers while the only entity that benefits charges the project as much as it can.
The PILOT CHPE is a perfect example of the many subsidies and programs set up to facilitate renewable energy development. The Department of Public Service is required to report annually on the status of the implementation of the Climate Act and include cost impacts. Not only is the 2024 report overdue, but it will not account for hidden in plain sight costs like those described here. Anyone who thinks that special interests are not taking advantage of these complexities at the expense of New Yorkers is naïve.
More Reasons to Pause Climate Act Implementation
This article describes more reasons that we need to pause implementation to the Climate Act to figure out how best to proceed.
David Turver writing at Eigen Values explains that as more energy dense sources of power were used in England that less time and effort to survive was needed. The problem is that shifting from energy-dense sources to diffuse sources like wind and solar is a challenging change of direction and could very well lead to limiting energy use which will have political impacts. He concludes that “If we continue down this Net Zero path, we will soon find that political change from energy austerity gets very ugly, very quickly.”
I relied on several resources to describe how the hydrogen fuel cell alternative option to battery-electric vehicles is having problems. Within days of laudatory articles about hydrogen fuel cell buses in Korea, Hydrogen Insight reported that:
Hyundai is recalling all units of its hydrogen-powered Elec City buses in South Korea after a faulty part was found to create a risk of hydrogen leakage, according to the country’s Ministry of Land, Infrastructure and Transport (Molit).
There is no evidence that this is a viable option for widespread displacement of internal combustion engine personal transportation.
The Energy Bad Boys recently described a partnership with the Arizona Free Enterprise Club to analyze the Integrated Resource Plan (IRP) of Arizona Public Service (APS). Their findings were published in a March report detailing how APS’s self-imposed Environmental and Social Governance (ESG) goals of reaching 100 percent Net Zero by 2050 are going to cost its ratepayers billions of dollars in unnecessary costs and undermine grid reliability. They also explained why utility companies can use the transition to improve their profits which probably explains why NY utilities are not acting in the best interests of their ratepayers.
The environ MENTAL blog had an article that described changes in the recent “One Big Beautiful Bill Act” (1BBB) passed by the U.S. House of Representatives last week. If this passes it will have an immediate and substantial impact to New York’s renewable energy development plans. I believe that many of the proposed wind and solar projects proposed for New York will not be viable without the subsidies. If New York cannot develop those resources, then it is clear that a pause in Climate Act implementation is necessary.
I’m afraid we’re not going to move back towards more rational energy policies until we have some horrible real world examples of where current obsessions with unreliable and intermittent energy sources are taking us. In the race to be a horrible example I think New York may well be in the lead.