The architects of New York’s clean energy transition predict the state will fall short of its 70%-by-2030 renewable energy target, perhaps far short, and suggest ways to catch up in the early 2030s. 

On July 1, the Department of Public Service (DPS) and the New York State Energy Research and Development Authority (NYSERDA) issued a draft of the 2024 Clean Energy Standard Biennial Review (Case 15-E-0302). 

It indicates that in the two years since the last review, the projected electric load growth is significantly greater and there are significantly fewer renewable energy projects contracted to meet that need. 

Considering how long it takes to develop and build a renewable energy generation facility and connect it to the grid, some revisions are in order, the review suggests: “The amounts of Tier 1 project deployment that would be needed … in order to achieve the 70% goal in 2030 may far exceed what the renewables industry could be expected to develop in this time frame.” 

The review suggests more than a dozen possible changes in New York’s approach to clean energy development in response, including allowing regulated utilities to own and operate renewable energy projects, awarding longer-term purchase contracts for renewable energy certificates and placing less emphasis on bid price when choosing proposals for contract awards. 

After a 60-day comment period, the Public Service Commission will consider actions in response. 

Alliance for Clean Energy New York Executive Director Marguerite Wells told NetZero Insider that the report did not contain a lot of new information for ACE NY and its members, many of whom have been working for years to build New York’s clean energy portfolio. 

She said focusing on 70-by-30 or other arbitrary numerical goals is misguided — everyone working on the clean energy transition, public sector or private, is working as hard as they can to make it happen as quickly as they can.  

Fixes largely are in place or in process for three of the largest hurdles for renewable development — procurement, permitting and interconnection — but there is no easy way to bring down costs, Wells said. “There are a lot of factors that make it expensive to build things in New York and I don’t think any of them can be swept away with a pen.” 

By the Numbers

The 70-by-30 target was mandated in July 2019 as part of New York’s landmark Climate Leadership and Community Protection Act (CLCPA), which also calls for 100% emissions-free power by 2040 and greenhouse gas emissions at least 85% lower than 1990 levels by 2050. 

The legislation was a collection of visions and directives, not a plan. The complicated and politically delicate task of making and implementing the plans fell to agencies such as NYSERDA and DPS, which typically work at a deliberate pace. 

In the following years, the world moved faster, with costs soaring for contracted renewable projects as they moved through one review after another. 

This culminated in the collapse of the state’s portfolio of contracted renewable projects in late 2023, when developers canceled more than 11 GW of contracts that had become economically untenable to advance to construction. 

So, in the draft review published July 1, 2024, there is a gaping hole in the numbers. 

The review projects a 2030 base load of 164,910 GWh, up from the 151,678 GWh estimated in 2020. (Most of this increase is due to increased demand anticipated from industrial users and electric vehicle charging.) 

To provide 70% of the 2030 base load, New York would need 115,437 GWh of renewables. Its current trajectory, assuming robust response to future contract solicitations and a 30% attrition rate for awarded contracts, yields 73,292 GWh from renewable sources in 2030. 

New York generated just 38,061 GWh of renewable power within its borders in 2022, 80% of it hydropower.  

The review lays out a potential scenario by which renewable energy generation could hit 70% of base load by 2033. That is 120,673 GWh, and reaching it would require procurement of 5,600 GWh of large-scale renewables per year, assuming 30% attrition. 

Progress has been tepid since 2022. In the 17 months from Jan. 1, 2023, to June 1, 2024, the renewables that have come online are estimated to total only about 2,250 GWh annual output. 

There also was 31,865 GWh of nuclear generation in New York in 2022, but that is classified as zero-emissions energy, not renewable energy. It would help the state reach its 2040 goal, but not its 2030 goal. 

Possible Solutions

The review suggests adjustments that could be made to improve the state’s procurement of renewable energy development.

The first suggestion is revising the methodology by which it awards contracts to buy renewable energy certificates and placing less emphasis on a proposed REC price, because recent history shows the cheapest proposals are not necessarily the best value, and perhaps more likely to be unable to proceed into development. 

Other options include: 

• • Create carve-outs for onshore wind in large-scale onshore solicitations (Tier 1) or create separate solicitations, so that wind proposals are not competing with less-expensive solar. 

• • Add strike price adjustment mechanisms for black swan events beyond a developer’s control. 

• • Increase maximum contract length to 25 years for Tier 1 projects and 30 years for offshore wind in recognition of the potential operating lives of these projects. 

• • Allow adjustments to commercial operation milestone deadlines and the consequences of missing them. 

• • Allow regulated utilities in New York to own and operate renewables. 

• • Divide the state into zones and align generation development in each zone with its planned transmission expansion and economic development. 

• • Help small-scale hydropower owners undertake needed maintenance and repairs. 

Headwinds and Tailwinds

Interest rates, inflation, supply chain constraints and black swan events — such as the COVID pandemic and war in Ukraine — are blamed in part for past shortfalls in New York’s renewable energy portfolio. 

The length and cost of the interconnection process continues to limit the pace of renewable development, the review states, despite efforts by NYISO at least as far back as 2019 to mitigate delays. The authors predict that even after NYISO integrates all the FERC Order 2023 requirements into its tariff, interconnection likely will remain a lengthy and costly process. 

The review predicts the already-complex generation siting process will become even more difficult in New York as the easy sites are exhausted and resource protection laws become more stringent. There are obstacles to placing renewables on farmland and forests, which constitute approximately 85% of New York’s total land area. 

Looking forward, the review sees shortages of key components potentially continuing and sees domestic manufacturing expansion as a possible counterweight.  

It also sees a need for large numbers of skilled workers trained to work in the clean energy sector, and details some of the efforts to build such a workforce. And it sees Biden-era financial incentives as a key boost to renewable energy development. 

Response to Report

That renewable energy development is slow, expensive and complicated in New York is news to no one, though state officials do not often say it in so many words or issue a hundred-page report about it. 

It also is frustratingly ironic. New York is among the bluest of states, firmly committed to climate protection in its policies, budget decisions and actions. 

But it is among the most expensive of states, and its home-rule tradition gives its many local governments outsized control over execution of state renewable energy policy. 

Clean-energy advocates have been frustrated at times at how slow and hard-fought progress has been in the five years since the CLCPA was signed into law and celebrated by its supporters as a nation-leading example. 

Environmental Advocates NY Executive Director Vanessa Fajans-Turner said via email: “New York must use every tool at its disposal to meet the 70% renewable electricity target by 2030. This is a legal mandate and a moral imperative for our future. The [Gov. Kathy] Hochul administration holds significant power to act. They should. Today.” 

The Independent Power Producers of New York said via email: 

“The lack of progress towards the state’s climate mandates is disappointing and this report further demonstrates how issues regarding reliability and affordability need to be taken seriously. While progress has certainly been affected by global concerns, such as supply chain issues, inflation, etc., the state has not moved quickly enough to determine the future technologies that are needed to help achieve these targets.” 

IPPNY added: “There can be opportunities for businesses to invest in New York, but the state needs to identify what will be considered a zero-emission source to create these opportunities. Appropriate market signals must be given so that the retirement of reliable generation stops outpacing new generation being added to the grid.” 

Wells of ACE NY said there are some problems beyond New York’s reach (war, the pandemic, inflation, interest rates) and there are problems New York is trying to solve. 

“The industry has known about the challenges and has been advocating for the fixes that are now largely in place for quite a while,” she said. 

Wells is particularly optimistic about interconnection process changes NYISO is making, including measures to discourage speculative requests from developers. 

“I think they have shown incredible willingness to work with the renewables side of the house to make a process that works for both them and will maintain the reliability of the grid,” she said, “so that things can speed up there, and I think that’s really exciting.” 

That began in advance of FERC Order 2023, Wells said, “because NYISO was sort of at the bleeding edge of this problem and they wanted to fix it … in part because of the size and speed at which New York is trying to change over to renewables.” 

Wells flagged an issue not raised in the report — state agencies working individually rather than together, or attaching a low priority to renewable energy if it is not among their traditional duties. 

“I think helping align those agencies to pull all in the same direction is something that that the governor can help direct, but I don’t think there’s any structural changes or new laws that are required at all.”