Climate Leadership and Community Protection Act State of Climate Science

In response to the Biden administration’s “World Climate Summit” there have been multiple summaries of the state of climate science, the alleged impacts and purported solutions. This post summarizes relative articles in the context of the Climate Leadership and Community Protection Act’s likely effect on the alleged effects of global warming.

I am a retired electric utility meteorologist with 40 years-experience analyzing the effects of meteorology and climate on electric operations in general and impacts on electric service in particular.  The opinions expressed in my comments do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

These comments consist of two parts.  In the first part I calculated the potential impact on global warming if New York were to achieve complete elimination of all greenhouse gas emissions.  In the second part I summarize information contradicting the notion of an on-going climate emergency that is the rationale for the Climate Leadership and Community Protection Act (CLCPA) emission reductions.  These comments show that New York’s potential effect on global warming is too small to measure and there is evidence that there is no climate emergency. 

Potential Impact on Global Warming

In this section I estimate how much CLCPA implementation might affect global warming itself.  This information has never been provided for any New York climate mitigation legislation or regulation.  For this analysis I adapted 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[1]  to estimate the potential effect.  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 MAGICC: Model for the Assessment of Greenhouse-gas Induced Climate Change[2] 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 inventory emissions divided by United States emissions to determine the effects of a complete cessation of all New York’s emissions.

There is a fundamental assumption in this approach.  The emissions in the primary reference are based on Intergovernmental Panel on Climate Change (IPCC) methodologies.  In order for these estimates to be correct the emission inventories used have to be calculated the same way.  New York’s CLCPA inventory only followed IPCC approaches when the results comported with the political narrative and differ when more “appropriate” that is to say higher numbers can be derived.  I am not sure how much of a difference New York’s mandated requirement to use a 20-year global warming potential for its emission inventory affects these results that use emissions with a 100-year global warming potential.

In light of that uncertainty, I developed results for multiple inventories.  The official CLCPA 1990 emission inventory was recently promulgated in New York’s Part 496 regulation.  As shown in the impacts table I estimated the benefits of getting 1990 emissions to zero for four inventories.  I evaluated the CLCPA Part 496 inventories for all the greenhouse gases (CO2, CH4, N2O, PFCs, HFCs and SF6) included in the law and just CO2.  In order to compare the potential effects the way the rest of the world prepares inventories, I evaluated the CO2 and GHG inventories from Table S-1 in the last New York State Energy Research and Development Authority inventory. The impact table shows that for the CLCPA Part 496 inventories there would be a reduction, or a “savings,” of between approximately 0.0097°C and 0.0081°C by the year 2100.  I compared those reductions to observed changes in the environment and relative to emissions in the rest of the world in an earlier post

State of Science of a Climate Emergency

I base this section primarily on an article by Willis Eschenbach that lists many supposed reasons that there is a climate emergency.  He shows data that contradict many of those allegations.  For example, one rationale for a climate emergency is that there are increasing numbers of deaths from weather extremes but global deaths due to climate and weather-related events are decreasing a lot.


His post includes many figures that illustrate data that contradicts the political narrative.  Storminess has not gone up, and there’s been no increase in hurricane strength or frequency.  The Intergovernmental Panel on Climate Change (IPCC) says there’s only one chance in five (“low confidence”) that global droughts are increasing.  Nor have the “wet areas been getting wetter and the dry areas getting drier” because the scatterplot of rainfall trend shows no trend as shown below.

Eschenbach uses National Oceanic and Atmospheric Administration 12-month averages of the Palmer Z-index for the contiguous US to show that droughts in the US have been decreasing, not increasing.  He quotes work by Pielke that shows that global weather disaster losses as a percentage of assets at risk (global GDP) are decreasing, not increasing. 

Eschenbach explains that alarmists keep posting scary-looking graphs of the loss of polar ice that show the total mass of ice loss but ignore the reality that those losses are tiny fractions of the total ice. He points out that tide gauges show no increase in the rate of sea-level rise, and the claimed acceleration in satellite-measured sea level is merely an artifact of changing satellites.

He uses Berkeley Earth land only temperature anomaly data to show that land temperatures have already risen more than the dreaded 2°C, with no cataclysmic consequences. 

Another useful metric is to consider that the average temperature difference over the last two centuries is very small relative to temperature changes people know how to handle.  Lindzen plots the observed global warming against average temperature changes between 8:00 AM and 10:00 AM, sunrise to afternoon, winter to summer average, winter morning to summer afternoon, average coldest to warmest daily extremes, and all time coldest to hottest to show that people deal with far greater temperature changes than the observed changes on the order of several degrees that occurred during the time that human welfare increased the most in history or that allegedly in the future will create an emergency.

Eschenbach shows that climate models have routinely predicted far greater warming than has actually occurred.  He notes that “This should not surprise anyone—the intractability of climate predictions has long been recognized even by the IPCC, viz:

“In sum, a strategy must recognise what is possible. In climate research and modelling, we should recognise that we are dealing with a coupled non-linear chaotic system, and therefore that the long-term prediction of future climate states is not possible”

IPCC Third Assessment Report, The Scientific Basis 14 2 2 2, p.774”

Rud Istavan recently described a series of failed climate predictions that further undermines any confidence in the climate models used to predict a climate emergency.  Climate models predict specific features in the tropics that are not observed.  Advocates claim that the ability of climate models to hindcast past anomalies proves that they can be used to predict the future.  However, he explains that the models are tuned to match the historical observations.  He explains that when looking at all the climate models used that in absolute temperature terms, the “models varied by ~4C in the year 2000 (early in their tuning period), from about the observed ~15.5C global average”.  Clearly that wide a range suggests poor model performance.  He also describes the model estimates of the amount of warming due to a doubling of CO2 concentrations in the atmosphere, the “equilibrium climate sensitivity”:

Models reliably predict an ‘Equilibrium Climate Sensitivity’ (ECS) of about 3C. Again half true. They all do, but not ‘reliably’. Observational ECS using energy budget (and other) methods consistently show about 1.6-1.7C, about half of modeled. This is a big deal, since all the alarmist doomstering depends on a high ECS (or its close cousin TCR). At 1.6, there is no climate problem at all. At 3, there might or might not be. The model/observation discrepancy is so great that AR5 declined to produce a central estimate of ECS, an embarrassing omission.

The climate emergency is supposed to be driven by changes to in downwelling radiation at the surface from the increase in CO2.  Downwelling radiation had a radiative forcing of 505.2 W/m2 for the pre-industrial (1750) atmospheric concentration of 278 ppmv of CO2. Currently the CO2 concentration is 413 ppmv and the forcing is 507.5 W/m2.  If CO2 is doubled from the 1750 value to 556 ppmv the total forcing will be 509 W/m2.  Doubling the atmospheric CO2 concentration results in just a 1-2% perturbation to the Earth’s energy budget. This doubled-CO2 effect has less than 1/5th of the impact that the net effect of clouds. And yet we are told there is a climate emergency because that change in one variable, CO2, is predominantly responsible for altering global temperatures.

Lindzen and Happer write that “No scientist familiar with radiation transfer denies that more carbon dioxide is likely to cause some surface warming”. However, they go on to argue that “the warming would be small and benign” and explain that civilizations have flourished when temperatures have been warm and declined when they have been cold.  Moreover, additional CO2 will increase the productivity of agriculture and forestry and those benefits are documented in many studies.

Advocates claim that climate models are somehow enough different than weather forecast models that our personal experience with failed weather forecasts beyond several days is inapplicable.  However, short-range climate models have poor forecasting abilities.  For example, The Weather Channel here not long ago issued it’s winter outlook up through March:

Obviously, there is an issue with this forecast given the Texas weather in February.  Even if the seasonal averages turned out to be similar to this forecast, the fact that so much damage occurred means that the expectation that average climate projections preclude extreme contrary weather is erroneous.

Dr William Briggs recently published “The Climate Blame Game: Are We Really Causing Extreme Weather?”  that looks at the claims of a climate emergency in a slightly different way.  In particular he analyzed whether we can trust climate-change event attribution studies.  His summary states:

Claims made in so-called climate change event attribution studies suffer from gross over-certainties and cannot be trusted. The techniques used in these studies are in their infancy and do not warrant the trust put into them. These studies assume either (a) perfect forecasting models, or (b) known, uncertainty-free causes of climate change. Neither condition holds. Because of this, attribution claims are far too certain or are wrong. They should not be used in any policy decisions.

Conclusion

New York climate change legislation and regulation invariably list a whole host of reasons why there is a climate emergency.  This summary of the state of the science shows that the basis for their attribution claims is not fit for purpose.  Eschenbach summarizes the climate emergency fallacy as follows:

Finally, an “emergency” is defined in the dictionary as “a serious, unexpected, and often dangerous situation requiring immediate action.” Alarmists have been warning us over and over about the purported impending “emergency” for 50 years, so it is hardly “unexpected”. None of their endless predictions of imminent tragedy have come true, and despite decades of warning, no significant “immediate action” has been taken … so by definition, it can’t be an emergency. For five decades, we’ve been told every year that we only have five, ten, or twenty years before disaster … I mean, seriously, how can people still believe these serial failed doomcasters?  So before we spend trillions of dollars on an unachievable plan to totally redo the entire global energy supply, how about we wait until someone can actually let us in on the big secret—just where is this mysterious “CLIMATE EMERGENCY!!!”, and when did it start?

I also showed that the global warming impacts projected with the climate models being used to claim a climate emergency are simply too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions.  In the context of global emissions New York’s efforts will be subsumed quickly by emissions increases in other countries that are morally obligated to provide the tangible benefits of affordable, abundant energy to their citizens. 

The actions necessary to implement New York’s climate agenda have to be compared to the likelihood of climate change effects and potential for New York to change the purported impacts.  The rationale to make the changes does not stand up to scrutiny and the fact is that New York’s contribution to the alleged problem even if they were substantiated is so small to have any effect.  Advocates for the New York CLCPA have to be held accountable to these findings.

[1] http://scienceandpublicpolicy.org/images/stories/papers/originals/state_by_state.pdf

[2] http://www.magicc.org/

Climate and Community Investment Act Legislative Findings

In the spring of 2021, the New York state Senate introduced the Climate and Community Investment Act (CCIA).  Coming on the heels of the Texas energy debacle one might think that politicians would not propose any changes to energy and environmental laws until the causes of that disaster were understood or would at least make implementation contingent upon feasibility studies to determine if the ambitious goals of this legislation don’t risk a similar outcome in New York. Such is not the case as shown by the legislative findings for this proposal.

I have written extensively about implementation of the Climate Leadership and Community Protection Act (CLCPA) because I believe it will adversely affect affordability and reliability as well as create more environmental harm than good. The CCIA will make those impacts worse.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The sponsor memo for this proposed regulation lists specific provisions in the proposed legislation.   I prepared an annotated version of the draft bill that includes internal links to the sections of the bill corresponding to those provisions.  The summary of Senate Bill S4264A states:

Enacts the climate and community investment act; prioritizes the allocation of public investments in disadvantaged communities; addresses climate change challenges through the expansion and growth of clean and renewable energy sources; adopts best value requirements for the solicitation, evaluation and award of renewable energy projects;  establishes a community just transition program; establishes a climate pollution fee and a household and small business energy rebate; and creates the climate and community investment authority.

This post evaluates Section § 2, legislative findings and declaration.  In the following section I list the findings and my indented and italicized comments.  I will confine my comments to technical findings and not comment on social justice findings that are personal value judgements.

Discussion

1. Climate change is adversely affecting economic well-being, public health, natural resources, and the environment of New York.

In general, the underlying premise in all the New York legislative and regulatory initiatives is that there is a climate crisis, that the effects of climate change are observable today, and that changes in greenhouse gas concentrations due to humans are responsible for the observed climate changes.  The politicians and regulators who prepare the rationales that climate change needs to be addressed frequently confuse weather and climate.  It happens so often that I have a page that references my evaluations of alleged climatic effects that turned out to be weather events and examples by other authors. 

 According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”  Also keep in mind that the standard climatological average is 30 years.  In order to think about a change in today’s climate averages you really should at least compare the current 30 years against the previous 30 years.  In order to get a trend, you need to look at as much data as possible.  On the face of it that might seem easy but the reality is that the conditions for a representative trend are difficult to achieve.  Ideally you need to use the same instruments, the same methodology, and keep the conditions around the observing location the same.  No recent New York legislative or regulatory description of climate change impacts has presented any claims that make the distinction between weather and climate so they all their claims are suspect.

Dr. William Briggs shows that attempts to blame extreme weather on human-caused global warming are “overconfident and probably wrong”.  He explains that the first problem is how to define natural because “some have the curious and false idea that earth’s climate never changed before mankind be­gan ‘interfering’ with it.”  Those people reason that the industrial revolution changed the environment due to man’s interference starting on the order of a hundred years ago. Briggs argues:

Now it is true that man, like every other creature, influences the climate and the environment to some extent. It is impossible for any creature, man included, not to have an effect. After all, every living thing is part of the environment. There is therefore no ‘natural’ state of the climate, defined as one operating without man’s influence.

 Briggs explains the problems trying to attribute human-caused effect to weather and climate.  No matter how you estimate that potential effect it is impossible to independently check that estimate.  The primary tool used today to estimate effects is a climate model.  In order to trust those models Briggs points out that “they first have to demonstrate forecast skill” and “if they can’t, or they are inaccurate, they can’t be trusted”.  Finally, he explains that “we might pick a date and say all observations before it are ‘natural’ and all after are tainted by ‘climate change’. But this is not proof man caused the dif­ferences. It is mere assumption.”  He concludes that “climate-change event attribution studies rely on all these kinds of guesses and claims. As such, they are either incorrect or are far too certain.”

The adverse impacts of climate change include:

  • an increase in the severity and frequency of extreme weather events, such as storms, flooding, and heat waves, which can cause direct injury or death, property damage, and ecological damage (e.g., through the release of hazardous substances into the environment);

This finding presumes that these events can be attributed to mankind’s impact on the climate.   Briggs explains that these claims are based either on a comparison of current observations to historical observations or using climate models with and without the alleged effect of GHG emissions.  He shows that it is not possible to verify what the “natural” atmosphere was in the past so these comparisons are highly uncertain.  The fact is that the human effect on weather events is at best a tweak and trying to tease out that effect with climate models that are very large scale is “dicey”.  He concludes that “the uncertainty in attribution claims is just too great and in ways not always recognized” to be relied upon to make decisions or, in this case, justify new legislation.  In addition an evaluation of extreme weather in 2020 notes that there is little evidence of extreme event worsening and most can be linked to natural climate cycles.

  • rising sea levels, which exacerbate damage from storm surges and flooding, contribute to coastal erosion and saltwater intrusion, and inundate low-lying areas, leading to the displacement of or damage to coastal habitat, property, and infrastructure;

Sea levels have been rising at the Battery in New York City since record keeping began and local changes in the height of land relative to the height of the continental land mass are a significant factor of that sea-level rise that no amount of change to the greenhouse effect will affect.

  • exacerbation of air pollution;

The only climate change impact that could affect air pollution is an increase in temperature that could change the rate of the reactions that convert precursor emissions s to ozone and inhalable particulates.  Note, however, that in both cases temperature is a minor actor in the conversion process and could only affect concentrations but several percent.

  • an increase in the incidences of infectious diseases, asthma attacks, heart attacks, and other negative health outcomes;

Absent supporting information for these health claims I cannot respond.

  • increased average temperatures, which increase the demand for air conditioning and refrigeration among residents and businesses; and

Recall that climate variability is over as long a period as possible.  The EPA high and low temperature climate change indicators page shows that the 1930’s were the worst period for heat waves with a heat wave index four times higher than recent data.  It is clear that temperatures are rising but it is not clear how much of the change is due to climate change and how much is due to land use changes like the urban heat island that are affecting temperature trends.

  • extensive environmental degradation with devastating impacts to wildlife and natural habitats, ecosystems and food supplies.

No examples of the devastating impacts are presented and there is no mention that in order to meet New York’s climate targets with wind and solar that thousands of wind turbines and square miles of solar panels will be required in the state or that the rare earth metals necessary for that technology will cause real environmental devastation somewhere else in the world.  In order to justify this claim the authors would have to compare the life cycle impacts of renewable alternatives.

2. Many of the impacts of climate change are already observable in New York state and the northeastern United States. Annual average temperatures are on the rise, winter snow cover is decreasing, heat waves and precipitation are intensifying, and sea levels along New York’s coastline are approximately one foot higher than they were in 1900. New York has also experienced an increasing number of extreme and unusual weather events, like Hurricanes Irene and Lee and the unprecedented Superstorm Sandy in 2012, which caused at least 53 deaths and $32 billion in damage in New York state.

As noted previously these claims have high uncertainty.  Nonetheless note that the sea level and the hurricane arguments are not supportable.  Sea levels are approximately one foot higher than they were in 1900 but there is no change in the rate of sea level rise.  NOAA’s Geophysical Fluid Dynamics Laboratory in Princeton NJ has concluded:

“In summary, it is premature to conclude with high confidence that increasing atmospheric greenhouse gas concentrations from human activities have had a detectable impact on Atlantic basin hurricane activity, although increasing greenhouse gases are strongly linked to global warming…Human activities may have already caused other changes in tropical cyclone activity that are not yet detectable due to the small magnitude of these changes compared to estimated natural variability, or due to observational limitations.”

New York was impacted by several hurricanes in recent years and that fact is used as “proof” that the climate is changing.  However actually reviewing the data shows otherwise.  Dr. Ryan Maue compiles data on the frequency of hurricanes across the globe and has found no trend.

Roger Pielke summarized hurricane landfalls and found a trend of decreasing landfalls since the early 1960’s. 

3. New York should therefore minimize the risks associated with climate change through a combination of measures to reduce statewide greenhouse gas emissions and improve the resiliency of the state with respect to the impacts and risks of climate change that cannot be avoided.

I have shown that the alleged risks associated with climate change are nonexistent so reducing greenhouse gas emissions will have no effect.  On the other hand, observed extreme weather has major effects on society.  Even if there is no climate change signal increased resilience is a no regrets policy that is in the best interests of the state

4. Climate change especially heightens the vulnerability of disadvantaged communities including communities of color and low-income communities, which bear environmental and socioeconomic burdens as well as legacies of racial and ethnic discrimination. Disadvantaged communities are more likely to experience flooding and urban heat island effects, and to live in housing vulnerable to destruction from storms. Low-income New Yorkers lack emergency savings to keep up with necessary expenses following the disruption from a major storm or climate event.

As shown above I do not believe climate change is an existential threat to society.  However, I agree that extreme weather heightens vulnerability of disadvantaged communities and that suggests that resilience measures should focus on reducing weather impacts in those communities.

5. Actions taken by New York state to reduce greenhouse gas emissions, and those taken to increase the resiliency of the state with respect to the impacts and risks of climate change, should prioritize the safety, health, and resiliency of disadvantaged communities, control potential regressive impacts of future climate change mitigation and adaptation policies on these communities, and prioritize the allocation of public investments in these areas.

I agree that resiliency measures should prioritize the safety and health of disadvantaged communities.  I submit however, that the concept that reducing greenhouse gas emissions can be used to control potential regressive impacts of future climate change mitigation on these communities is not in the best interest of those communities.  The fact is that mitigation of greenhouse gases invariably increases the cost of energy and the disadvantaged communities are disproportionately impacted more by energy costs.  Any money spent on mitigation is not going to affect impacts so there cannot be any paybacks so increased costs to those least able to afford those increases is not in the best interests of the disadvantaged communities.

6. Disadvantaged communities in New York state experience greater exposure to air pollution and subsequent negative health impacts, in large part due to legacies of racial, ethnic, and socio-economic discrimination. New York’s communities of color are more likely to:

(a) live near sites of high pollution, including power plants, highly trafficked automotive routes, waste transfer stations, landfills, hazardous waste sites and toxic industrial facilities;

(b) breathe in a greater volume of pollution, including both ozone and particulate matter;

(c) experience asthma and other pollution-related illnesses including increased hospitalization rates for childhood asthma;

(d) have higher rates of cancer due to disproportionate exposure to air pollution, including lung cancer and other pollution-affiliated cancers; and

(e) experience other negative health impacts, including but not limited to reduced fertility rates, adverse pregnancy outcomes and increased vulnerability to the consequences of co-morbidities like diabetes and high blood pressure.

I do not dispute that disadvantaged communities experience greater exposure to air pollution and subsequent health impacts but there are some caveats that should be kept in mind.  Many environmental justice organizations are taking the position that because of the legacies of the past that the only acceptable future scenario is no environmental impacts.  For example, it is not acceptable for a facility to add controls that significantly reduce emissions and impacts.  Instead, the facility has to be replaced with something with no local impacts. 

 There are technical issues with the demand for no local impacts from power plants.  The over-riding problem is that the primary air quality health concerns are from ozone and inhalable particulates.  Because those are both secondary pollutants that form by chemical reactions from the pollutants emitted by power plants, they don’t impact the neighborhoods around the power plants simply because by the time those reactions take place the emissions have been transported away from the plant.  Another problem is that the projections of reduced health impact outcomes rely on analyses that are contradicted by other work.  Finally, the projections of health impacts rely on the linear-no threshold model that is impossible to verify at the low pollutant levels associated with neighborhood power plants.

 Ultimately the discussion of how best to address the air pollution problems of disadvantaged communities involves trade-offs and value judgements that are beyond the scope of this post.


7. In the spring of 2020, New York experienced the devastating impacts of the Covid-19 pandemic. Tens of thousands of New Yorkers died, and many hundreds of thousands more became ill. Air pollution played a significant role in this pandemic, as residents of communities of color who live in highly polluted areas died disproportionately from Covid-19 when compared to patients from less polluted neighborhoods. Throughout the pandemic, New Yorkers of color continue to disproportionately contract, fall ill, and die from Covid-19, in part because of disproportionate exposure to toxic air pollution.

The basis of this claim is a study by Harvard that claimed that a small increase in PM2.5 in outdoor air increased the risk of death from COVID-19 by 15 percent.  However, that study is flatly contradicted by a study by University of Washington and Stanford researchers that found that nations with the highest smoking rates had the lowest COVID-19 death rates.  Because the inhalable particulates from cigarette smoke are many times greater than the inhalable particulates in New York air the disproportionate COVID impacts on New York are due to another cause.

8. The Covid-19 pandemic has also caused a national economic crisis which has also severely impacted New York State. Many New Yorkers lost their jobs during the Covid-19 pandemic, with unemployment rates reaching levels not seen since the Great Depression. Such mass job loss increased precarity for thousands of New Yorkers and left many less able to weather current or future emergencies. Child and dependent care shortages are and continue to be a barrier to work in New York, especially for women, who disproportionately take on unpaid caregiving responsibilities when their family cannot find or afford child and dependent care.  Low and middle-income families and families of color disproportionately lack access to quality child and dependent care.

No comment

9. New York state has an interest in reducing air pollution that increases risk for Covid-19 and ensuring that all populations are equally able to breathe clean air and live healthful lives. Actions undertaken by New York to reduce air pollution should prioritize the health and safety of disadvantaged communities, prioritize the allocation of public investments in these areas, and control potential regressive impacts of climate policies on these communities. Further, it is in the interest of the state to invest in creating stable and safe employment opportunities for individuals who have lost their jobs as part of the Covid-19 recession. This includes protecting and promoting the ability for all workers to equitably participate in a just clean energy transition by increasing equitable and comprehensive access to child and dependent care.

EPA and DEC have regulations in place to improve air quality.  I am not sure whether incorporating the other goals described will help or hinder the efforts to improve air quality

10. Racial justice and environmental justice are inextricably linked to achieving a just clean energy transition in New York. The murder of George Floyd on May 25, 2020 was followed by mass protests for Black lives in New York state and throughout the nation. These movements have forced a national reckoning with the fact that racial injustice has resulted in over-policing and mass incarceration of communities of color. It is in the interest of the state of New York that no funds from programs for pricing greenhouse gas emissions are invested in police, prisons or related infrastructure.

No comment.

11. The adverse impacts of climate change are having a detrimental effect on some of New York’s largest industries, including agriculture, commercial shipping, forestry, tourism, and recreational and commercial fishing. These impacts also place additional strain on the physical infrastructure that delivers critical services to the citizens of New York, including the state’s energy, transportation, stormwater, and wastewater infrastructure.

No evidence is presented that there are detrimental effects on these industries.  The tendency to blame any negative effect on climate change distracts resolution of the real cause of the problem.  Even if there is some tenuous connection between an alleged climate change impact and strains on infrastructure the question should be what is the most cost-effective approach to address those problems.  Should we try to indirectly invest to reduce climate impacts by reducing emissions or invest directly in the infrastructure to adapt to extreme weather?

12. Creating good jobs and a thriving economy is a core concern of New York state. Shaping the ongoing transition in our energy sector to ensure that it creates good jobs and protects workers and communities that may lose employment in the current transition must be key concerns of our climate policy. Setting clear standards for job quality and training standards encourages not only high-quality work but positive economic impacts.

Everybody wants good jobs.  The tradeoff between jobs that are depend on government subsidies and those that don’t should be addressed in this conversation.

13. Ensuring career opportunities are created and shared geographically and demographically is necessary to ensure increased access to good jobs for marginalized communities while making the same neighborhoods more resilient. Climate change has a disproportionate impact on low-income people, communities of color, women, youth, children and workers. This includes formerly incarcerated individuals. Disadvantaged communities and workers must have access to all aspects of the state’s clean energy economy, including as investors and developers of clean energy projects. It is in the interest of the state of New York to protect and promote the interests of these groups against the impacts of climate change and severe weather events and to advance our equity goals by ensuring quality employment opportunities in safe working environments.

No comment

14. Addressing climate change challenges through the expansion and growth of clean and renewable energy sources requires New York to make substantial proprietary and financial investments in this sector and to become an investor and partner in the development of renewable energy programs and projects. New York has long provided forms of state assistance, including grants, energy credits, or tax incentives to developers, project owners and other entities proposing clean and renewable energy projects. Key findings relating to state assistance in the clean and renewable energy sector are as follows:

(a) providing forms of state assistance in renewable energy projects results in New York becoming a co-investor in this sector with strong financial, proprietary interests in the projects it supports. Such assistance is essential since the expansion and development of this market, would not occur at the scale and pace needed without substantial financial investment by the state. New York has already invested billions of dollars in promoting its renewable energy programs and will continue to invest substantial sums over the next several years to assist the growth and development of the sector. Such investments are critical not only for the development of individual renewable energy projects, but also to ensure that projects are effectively planned and executed and produce adequate amounts of clean energy needed to meet the state’s future needs for safe, affordable reliable power;

(b) it is vital that the state’s investments in clean and renewable energy be protected and monitored through all stages of development to make certain that they are effective in producing the intended results.  The need for this protection has grown greater due to the enormous economic burden imposed on the state by the Covid-19 pandemic;

(c) one of the areas in need of most protection is the actual construction and operation of renewable energy projects, especially large-scale projects. Because the construction industry is inherently complex and challenging, the delivery of projects, especially large capital construction projects, is fraught with numerous high-level risks that stem from various sources. These include but are not limited to project funding, financial resources and stability of project partners, project designs and specifications. Risks also include site conditions, equipment and material supply chains, and the experience, capacity and technical qualifications of developers, contractors and craft labor personnel used for a given project;

(d) ensuring the sufficient supply of properly trained and qualified craft labor personnel is vital to the protection of state interests and investments in the renewable energy sector. Large-scale construction projects are both labor intensive and inherently dangerous operations.  The timely, successful delivery of these projects is critical to the delivery of safe and reliable power to consumers. Thus, the safe and successful completion of these projects necessitates a highly skilled workforce. It is critical that the state support the development of this workforce, as the construction industry generally is facing the most acute, widespread skill shortage in craft labor personnel in modern times. This shortage can cause various types of project failures, including major schedule delays, cost-overruns, increased safety incidents, or other serious problems;

(e) while many aspects of construction project planning cannot be controlled, ensuring the adequate supply of properly trained craft personnel can be effectively managed through the use of labor performance tools and policies. Key labor performance provisions include prevailing wage requirements, project labor agreements and responsible contractor provisions. These policies, in use in New York and throughout the country, are shown to be effective at protecting capital investments and the proprietary interests of investors. These tools also help ensure that adequate numbers of skilled craft personnel are deployed to projects in a timely manner and that the most highly qualified contractors will be attracted to such projects. These tools also protect the wage rates of local communities, promote adherence to required licensing and technical certifications, and maintain labor peace on projects to avoid disruptions and protect project delivery;

(f) project labor agreements promote the planning and timely completion of construction projects, especially larger scale projects, by establishing pre-determined and uniform employment terms. This ensures an adequate supply of properly trained craft personnel, creates stability for project planning and prevents labor disruptions. Responsible contractor policies help ensure that contractors and subcontractors used for projects are reputable, qualified firms that have sufficient resources and capabilities needed to perform the work successfully.  Prevailing wage requirements protect local area wage rates from being undermined; and

(g) project labor agreements, responsible contracting and prevailing wage requirements also produce valuable socio-economic benefits by creating quality middle class jobs and skill training opportunities in New York’s construction industry. Utilizing these policies will develop a new generation of craft labor personnel, create jobs in the state and foster economic development in communities where projects are located.

New York does have a long history supporting clean and renewable energy.  However, the results of those investments do not bode well.  The investments from the proceeds of the Regional Greenhouse Gas Initiative are often cited as an example of the value of New York’s support of clean and renewable energy.  The latest New York State Energy Research and Development Authority (NYSERDA) report New York’s RGGI-Funded Programs Status Report – Semiannual Report through June 30, 2020 describes the programs New York has set up to invest the proceeds from the Regional Greenhouse Gas Initiatives.  Upon closer examination though, I found that NYSERDA supports 20 programs with associated CO2 reduction benefits and another 18 programs with no claimed CO2 reductions.  I compared the cost per ton reduced for those programs against the 2021 $127 New York Value of Carbon metric for cost effective investments.  Seventeen programs and the 18 programs with no claimed reductions do not meet this cost effectiveness standard.  I found that only 1.1% of the NYSERDA RGGI funds cost-effectively reduce CO2 emissions.  I imagine that the limitations in this proposed legislation can only add costs to renewable developments and further reduce their effectiveness.

15. It is in the interest of the state to strengthen, monitor and enforce prevailing wages, project labor agreements and responsible contracting. While prevailing wage requirements are already required for some renewable energy projects, these requirements should be strengthened and used in coordination with the additional labor and performance standards established in this act.

No comment

16. The severity of current climate change and the threat of additional and more severe change will be affected by the actions undertaken by New York and other jurisdictions to reduce greenhouse gas emissions.  According to the U.S. Global Change Research Program and the Intergovernmental Panel on Climate Change substantial reductions in greenhouse gas emissions will be required by mid-century in order to limit global warming to no more than 2°C and ideally 1.5°C, and thus minimize the risk of severe impacts from climate change. Specifically, industrialized countries must reduce their greenhouse gas emissions by at least 80 percent below 1990 levels by 2050 in order to stabilize carbon dioxide equivalent concentrations at 450 parts per million–the level required to stay within the 2°C target.

The Paris Climate Agreement will reduce temperatures just 0.05°C.  It is not clear how much the alleged risks of severe impacts can be ameliorated by that small a change in temperature.

17. In 2019, New York state demonstrated national and international leadership on climate by enacting the Climate Leadership and Community Protection Act (“CLCPA”), the nation’s most aggressive climate law and the nation’s only climate law that provides for a just transition. The CLCPA created a comprehensive regulatory program to reduce greenhouse gas emissions from all anthropogenic sources 100% over 1990 levels by the year 2050, with an incremental target of at least a 40 percent reduction in climate pollution by the year 2030, and requires investment in and protection of disadvantaged communities. To meet the goals of the CLCPA, the state will need to transform its energy infrastructure, including the rapid and significant deployment of clean and renewable energy. It is in the interest of the state to promote and provide resources towards the development and maintenance of clean energy infrastructure.

In the absence of any New York estimate of the effect of greenhouse gas emissions reductions on global warming I did my own estimateI found that for the CLCPA emission inventories there would be a reduction, or a “savings,” of between approximately 0.0097°C and 0.0081°C by the year 2100.  To give an idea of how small these temperature changes are 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 for eliminating all greenhouse gases is a 39-inch change in elevation or 32 inches if only the CO2 emissions are considered.  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 a change in latitude of less than a mile. 

 New York should also be considered relative to the rest of the world.  According to the China Electricity Council[1], about 29.9 gigawatts of new coal power capacity was added in 2019 and a further 46 GW of coal-fired power plants are under construction.  If you assume that the new coal plants are super-critical units with an efficiency of 44% and have a capacity factor of 80%, the reductions provided by the CLCPA greenhouse gas inventory will be replaced by the added 2019 Chinese capacity in less than two years or four and a half years if the 2019 capacity and the units under construction are combined. 

[1] https://www.bnnbloomberg.ca/china-seen-adding-new-wave-of-coal-plants-after-lifting-curbs-1.1448154?utm_source=CCNet+Newsletter&utm_campaign=9afd780483-EMAIL_CAMPAIGN_2020_06_18_12_02&utm_medium=email&utm_term=0_fe4b2f45ef-9afd780483-36423245&mc_cid=9afd780483&mc_eid=1afdc1d1a3

18. By exercising a global leadership role on greenhouse gas mitigation and climate change adaptation, New York will continue to position its economy, technology centers, financial institutions, and businesses to benefit from national and international efforts to address climate change. Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change. In addition, such action will encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented. It will also advance the development of green technologies and sustainable practices within the private sector, which can have far-reaching impacts such as a reduction in the cost of renewable energy components, and the creation of jobs and tax revenues in New York.

The CLCPA does not include a requirement for a feasibility study with clear affordability, reliability, and environmental impact tests to determine whether it is appropriate for New York to proceed with a complete overhaul of the energy system.  I showed that action undertaken by New York to eliminate greenhouse emissions will have an immeasurable effect on the rate of climate change.  If the proposed transition of the New York energy system results in unacceptable affordability, reliability and environmental impacts the state’s actions will discourage other jurisdictions. 

19. It is in the interest of New York to take rapid action to reduce greenhouse gas emissions and transition to a just clean energy economy.  Such actions include:

  1. a) raising new, dedicated revenue specifically for climate programs;

(b) investing in clean and renewable energy infrastructure such as solar energy, offshore wind, grid storage technologies and energy efficiency;

(c) rapidly transitioning to zero-emission transportation, especially zero-emission school and transit buses, to reduce adverse health impacts for children, workers, and communities, and improve grid resilience and renewable energy reliance;

(d) prioritizing funding for locally driven projects to reduce emissions and increase resiliency, especially in disadvantaged communities that are most impacted by climate change and air pollution;

(e) creating quality employment opportunities for all New Yorkers in the transition to a just clean economy and ensuring the full participation and prioritization of disadvantaged communities; and

(f) ensuring workers and communities currently reliant on the fossil fuel industry are given resources to avoid adverse economic impacts.

I don’t think that the legislative finds presented a case that supports the notion that is in the interests of the state to implement these actions.

20. There is currently no state entity that is wholly dedicated to achieving the outcomes of the CLCPA. Without adequately devoting state resources and personnel, the outlined emissions reductions and electrification goals will not be realized in the target timeframe. Pursuant to the CLCPA, the state has less than 30 years to fully transition the 10th largest economy in the world to one that is fossil fuel free, and intentionally prioritize overburdened populations. Reaching these goals will improve the health and well-being of the residents of the state and advance the state’s economic interests. It is also critical that best value procurement requirements are established within the authority to optimize the solicitation, evaluation and award of renewable energy projects assisted by the state.

While there is no dedicated state entity dedicated to achieving the outcomes, NYSERDA has taken over that role because they have staff with the appropriate background and knowledge.  Unfortunately, their record with the proceeds from the RGGI auction are not good.  If New York has to rely on NYSERDA investment record to date to reduce fuel combustion CO2 emissions to zero for the CLCPA, then the cost would be $91.948 billion.  Note that in my opinion the primary reason for this abysmal record is political interference because many of the programs included appear more to cater to specific interests and the agenda of the Cuomo Administration than trying to efficiently and effectively reduce greenhouse emissions.

21. It is in the interest of the state to establish a dedicated authority to ensure that New York’s climate goals are accomplished. Such an authority would be able to nimbly manage the proceeds from a polluter fee which will amass significant revenue and require ongoing management.  This authority would also disburse funds for clean energy community scale projects in a timely and efficient manner while employing best value procurement practices. In addition, a new authority would have the capacity to ensure prioritization of projects and funds for impacted communities, coordinate statewide emissions reduction strategies and assist impacted workers in a transition away from fossil fuels through specialized assistance programs.

The last thing that this state needs is a dedicated authority for New York’s climate goals.  The idea that any Albany bureaucracy controlled by political appointees could nimbly manage proceeds is laughable.  As the NYSERDA RGGI investment results show, the more political interference the less efficient the process.

22. This legislation will build upon the developments outlined above by creating a comprehensive program for pricing greenhouse gas emissions and investing in a just transition to a low-carbon New York state economy, in accordance with the targets established in the CLCPA.

The theory of carbon pricing is that adding a price to greenhouse gas emissions will incentivize the market to develop the least cost alternatives to using fossil fuels.  Note, however, that the theory also suggests that the way to prevent this from simply becoming a regressive tax is to offset the proceeds with comparable reductions in taxes elsewhere.  This is not an aspect of the proposed pricing program in this legislation.

Conclusion

The findings note that Superstorm Sandy in 2012 “caused at least 53 deaths and $32 billion in damage in New York state”. It is notable that the February 2021 blackout in Texas caused similar impacts.  One disaster was caused by nature and the other by a failure in the planning for the electric energy system.  With all due respect to the electric energy planners, trying to anticipate all scenarios associated with a complete transition of the electric grid to renewables is probably impossible.  If that process is dictated by political considerations without adequate time for planning and testing, then I believe blackouts in New York with similar impacts to those observed in Texas are inevitable.  These legislative findings do not provide sufficient support to take that risk.

Two books and a recent essay suggest a different approach is more appropriate.  Bjorn Lomborg’s book “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet” shows that the media, politicians and activists that hype climate catastrophe are picking and choosing results that support that narrative but do not reflect the whole story.  He demonstrates that “in almost every way we can measure, life on earth is better now than at any time in history” and explains that “analysis by experts shows that we are likely to become much, much better off in the future”.  He shows that we are committing to try to solve climate change with policies that he demonstrates will not make much of a difference but will cost a lot and not do much to change global warming.  Michael Shellenberger “Apocalypse Never – Why Environmental Alarmism Hurts Us All” evaluates the current war on nuclear and natural gas fracking by the environmental alarmists.  He includes several examples of the hypocrisy of the loudest voices when it comes to the most obvious solutions.  His evaluation of concentrated power provided by nuclear and natural gas compared to the dilute energy provided by wind and solar shows that they are obvious choices while we develop better fossil-free alternatives.  The essay  Undue Climate Haste explains that the Nobel Prize (2018) winning climate economist William Nordhaus showed in his Nobel lecture in Stockholm that the ‘economic optimum’ for climate policy is to allow 3.5 degrees Celsius of warming in 2100. Economically, it is better to accept a certain amount of climate damage and to limit the cost of mitigation than the other way round: ambitious goals such as staying below 2 degrees or even 1.5 degrees are extremely costly.  Unfortunately, the CLCPA and CCIA are going down the exact path that these authors show will cost enormous sums of money, hurt more of the world’s poor than help, and will have no effect on global warming itself.

Update on NYSERDA RGGI-Funded Programs

The New York State Energy Research and Development Authority (NYSERDA) report New York’s RGGI-Funded Programs Status Report – Semiannual Report through June 30, 2020 (“Status Report”) describes the programs New York has set up to invest the proceeds from the Regional Greenhouse Gas Initiatives.  In this post I update an earlier evaluation whether the investments made from the RGGI auction proceeds are cost effectively reducing CO2. 

I am a retired air pollution meteorologist who has been involved in the RGGI program process since its inception sometime in 2004.  I have written extensively on RGGI because the program demonstrates practical difficulties with greenhouse gas control programs.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

RGGI is a market-based program to reduce greenhouse gas emissions. It is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector.  According to a RGGI website: “The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.”  New Jersey left RGGI in 2012 and re-joined RGGI in 2020.  Virginia joined in 2021 and the Governor but not the Legislature of Pennsylvania want to join in 2022.

RGGI has been touted as a successful example of a “cap and dividend” pollution control program.  New York State has been involved in the program since its inception and claims it yields environmental, health, and economic benefits.  Advocates for carbon pricing schemes assume that the investments from the proceeds are worthwhile so I will evaluate that presumption in this article.

In order to determine the value of emission reduction investments I will use the Social Cost of Carbon (SCC).  This is supposed to represent the future cost impact to society of a ton of CO2 emitted today.  It is a policy tool that attaches a price tag to the long-term economic damage caused by one ton of carbon dioxide, hence the cost to society.  It was extensively by the Obama Administration to justify the Clean Power Plan, has been proposed for use in the New York Independent System Operator carbon pricing initiative and is included in New York’s Climate Leadership and Community Protection Act.  At the end of 2020, the New York Department of Environmental Conservation (DEC) released a guidance document that provides social cost values for carbon dioxide, methane, and nitrous oxide for use by State agencies along with recommended guidelines for the use of these and other values by State entities.

Therefore, it is entirely fair to use the New York value of carbon as a metric to determine if the investments made from carbon pricing income are cost effectively reducing CO2 as needed to meet the CLCPA targets. New York guidance recommends using a 2% discount rate and establishes a 2021 value of $127 per metric ton.  If New York investments reduce CO2 emissions at a rate below that metric, then the investment will be less than the social costs to society of the ton of CO2 removed from the New York energy system.  If it is greater than $127, then the pollution reduction costs are greater than the cost to society and the investments are not a cost-effective solution.

NYSERDA RGGI Program Status

The key table in the Status Report is Table 2 Summary of Expected Cumulative Annualized Program Benefits through 30 June 2020.  It provides costs, energy savings, electricity savings or renewable energy production, greenhouse gas emission savings and the calculated cost benefit ratio.  The $/ton reduced metric is presented on an annual basis and as expected lifetime savings.  In order to determine if the NYSERDA RGGI investments cost-effectively reduce CO2 emissions necessary for the CLCPA targets, the annual numbers must be used.  More on this later. 

The NYSERDA RGGI Status Report Table 2 – Ranked Cost Benefit Ratio Data table lists all the programs in the NYSERDA report ranked by the annual cost benefit ratio with just that parameter.  It lists 20 programs with associated CO2 reduction benefits and another 18 programs with no claimed CO2 reductions.  Two of the 20 programs and another is close enough meet the $127 New York Value of Carbon metric for cost effective investments.  Seventeen programs and the 18 programs with no claimed reductions do not meet this cost effectiveness standard.  Table 4 in the Status Report notes that the NYSERDA investments spent through June 30, 2020 total $1,139.8 million.  In Table 2 of the Status Report the total incentives and total associated costs for the three programs that are cost effective total 12.3 million.  In other words, 1.1% of the NYSERDA RGGI funds cost-effectively reduce CO2 emissions.

The Status Report describes the programs and after reading the summaries I am not impressed and in fact I question the results.  The most cost-effective program, Multifamily Performance Program Assessments in the Green Jobs Green New York sector, had a cost effectiveness value of $61/Ton CO2e.  The program provides financing and co-funding for comprehensive energy assessments and the development of an Energy Reduction Plan, serving market-rate and low- to moderate-income residential buildings with five or more units to increase adoption of clean energy in NYS. Accomplishments.  According to the summary table, they managed to do a total of 316 assessments through December 2018 that resulted in 61,795 residential units served with installed measures for a cost of $3.3 million in “total incentives” and another $1.4 million in “total associated costs”.  Summing the incentives and associated costs and dividing by the 61,795 residential units yields $76.06 per unit.  The summary indicates that this is the cost of the comprehensive energy assessment and development of a reduction plan and that rate per unit is reasonable.  But this also means that the actual costs to implement the energy reduction are not included.  So how did NYSERDA claim any CO2 reduction benefits and what are the chances that the actual CO2 reductions were double-counted?  Finally, note that this program is complete.

There is another concern. A quick perusal of the programs listed with no reduction benefits demonstrates justifiable cynicism of yet another government program controlled by politicians.  The programs range from practical to clear pork barrel.  New York wants to be able to track emissions from generation sources within the State and from imported sources to create “tradable generation attribute certificates”.  Rather than fund the NY generation attribution tracking program through the general fund it is convenient to fund this through RGGI auction proceeds.  The research projects are another segment of funding where there is a justifiable rationale for funding projects that have no reduction benefits short-term because they could lead to long-term reductions.  At the extreme of clearly unjustified funding is the Brookhaven National Laboratory Ion Collider.  I have no idea the tortured logic that was used to justify spending any RGGI funds on this.

CO2 Cost Benefit Ration Annual vs. Expected Lifetime Savings

Earlier I noted that in order to determine if the NYSERDA RGGI investments cost-effectively reduce CO2 emissions necessary for the CLCPA targets, the annual numbers must be used.   While there may be a rationale to include the lifetime expected cost benefit savings relative for financial comparisons, in order to determine CO2 reduction cost-effectiveness for the CLCPA targets or the New York Value of Carbon it is inappropriate.   I did a post on the New York Clean Energy Dashboard last year that made that point and heard from the Senior Manager of Communications at NYSERDA claiming that when comparing clean energy program investments to the Social Cost of Carbon, the more appropriate comparison point is the expected lifetime value.  I responded with an explanation why that was untrue but did add the distinction between financial comparisons and carbon social costs to my post. 

The New York Value of Carbon Guidance includes a section entitled “Estimating the emission reduction benefits of a plan or goal” with an example that states:

The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $127 per metric ton. The value of the reductions in 2021 are equal to $127 times 5,000 metric tons, or $635,000; in 2022 $129 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.

This example makes the same mistake.  The Integrated Working Group damages approach value is the net present benefit of reducing carbon dioxide emissions by one ton.  The calculation methodology determines that value from the year of the reduction out to 2300.  It is inappropriate to claim the benefits of the annual reduction over any lifetime.  Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $127 or $6,350,000, but the guidance approach estimates a value of $37,715,000.

When I was developing a response to NYSERDA’s communications manager, I contacted Dr. Richard Tol, Professor of the Economics of Climate Change at Vrije Universiteit Amsterdam and a Professor of Economics at the University of Sussex who has direct experience estimating the social cost of carbon.  I asked the following question:

There is a current proceeding where NYSERDA is claiming that their investments are cost-effective but they use life-time benefits.  I concede that the ratepayer cost-benefit calculation should consider the life-time avoided costs of energy and can see how that reasoning might also apply to the social cost of carbon.  However, in the following definition, SCC is the present-day value of projected future net damages from emitting a ton of CO2 today, I can interpret that to mean that you shouldn’t include the lifetime of the reduction.  Am I reading too much into that?

He graciously responded that the use of life-time savings or costs is inappropriate in the following:

Dear Roger,

Apples with apples.

The Social Cost of Carbon of 2020 is indeed the net present benefit of reducing carbon dioxide emissions by one tonne in 2020.

It should be compared to the costs of reducing emissions in 2020. The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year).

Stay healthy,

Richard

Dr. Richard S.J. Tol

MAE Professor Department of Economics,

Room 281, Jubilee Building

University of Sussex, Falmer, Brighton BN1 9SL, UK

I have contacted DEC about the Value of Carbon example error.  The DEC response noted that “we will be making additional updates to the Value of Carbon guidance and this would be one update that could be addressed”.  In my correspondence with NYSERDA I offered the opportunity to discuss why the lifetime savings cost effectiveness metric is appropriate for social cost comparisons but never received an answer.

Conclusion

According to the NYSERDA 2003-2017 Patterns and Trends document the 2017 estimated New York CO2 emissions from fuel combustion were 157 million metric tons.  The total annualized cost benefit ratio ($ per ton of CO2 reduced from NYSERDA’s RGGI investments is $587 per ton.  If New York has to rely on NYSERDA to reduce fuel combustion emissions to zero for the CLCPA, then the cost would be $91.948 billion.

NYSERDA’s continued use of the $ per CO2 expected lifetime savings metric without qualification that it is inappropriate to use to compare to any social cost of carbon metric or for comparison of reductions necessary for the CLCPA targets is disappointing at best.  There is no excuse to continue this charade.  Of course, the fact that only 1 .1% of the NYSERDA RGGI funds cost-effectively reduce CO2 emissions programs suggest that this would be an embarrassment.

The CLCPA has set three greenhouse gas emission targets: 40% reduction in GHG emissions by 2030, 85% reduction in GHG emissions by 2050, and 100% carbon-free Electricity by 2040.  The ultimate problem is there is no requirement to determine whether these goals are financially possible.  The NYSERDA performance is not encouraging.

Air Pollution and Health Impact Projections

The recently released Fossil Fuel End Game report claims that peaking power plants should be replaced with wind, solar and distributed battery storage because it would save money and lives.  However, the basis for that claim ultimately comes down to the belief that there is no acceptable level of air pollution.  This post explains why I think that is absurd and explains how this concept is misused by activists. 

I am a retired air pollution meteorologist with over 40 years-experience analyzing the relationship between air quality and environmental standards.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Clean Air Act, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for six principal pollutants (“criteria” air pollutants) which can be harmful to public health and the environment.  The National Ambient Air Quality Standards (NAAQS) “provide public health protection, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”.  My career is based on the presumption that air quality that meets those standards is acceptable.

In order to achieve and maintain air quality that meets the NAAQS the Environmental Protection Agency working with state and local regulatory agencies have developed extensive procedures.  In this instance the important thing to know is that they have been monitoring air quality ever since the Clean Air Act was enacted and they have developed air quality models that can be used to predict ambient concentrations.  Importantly, the numerical models are based on observations and have been verified as being accurate since the Clean Air Act has been enacted.  Using those tools over the years they have a very good understanding of the status of air quality relative to the NAAQS.  According to the EPA nonattainment/maintenance status summary, there are multiple counties that do not attain the NAAQS for ozone and New York County does not meet the coarse particulate matter standard.  Note that all of New York State meets the inhalable particulate NAAQS.  All the other pollutants are in attainment.

Discussion

There is no question that air pollution can cause health effects.  The issue is whether there is a threshold when the health effect is so weak that it can be ignored.  The linear no threshold model (LNT) is a conservative model used to estimate health effects from small doses of radiation. According to the LNT model, “radiation is always considered harmful with no safety threshold, and the sum of several very small exposures are considered to have the same biological risk as one larger exposure (linearity)”. It is being used today to claim health effects for air pollution levels below the NAAQS. 

There is a fundamental problem with this approach for radiological assessments:

The problem is that, at very low doses, it is practically impossible to correlate any irradiation with certain biological effects. This is because the baseline cancer rate is already very high and the risk of developing cancer fluctuates 40% because of individual life style and environmental effects, obscuring the subtle effects of low-level radiation. Therefore, it is very difficult to validate this model.

Because it is so conservative there are consequences.  It assumes that all radiation is bad and that the health effects increases linearly with dose from the threshold of zero.   As a consequence: “The probabilistic nature of stochastic effects and the properties of the LNT model make it impossible to derive a clear distinction between ‘safe’ and ‘dangerous’, and this creates some difficulties in explaining the control of radiation risks.”

Despite those inherent problems the LNT model has been applied to air pollutants too.  Whenever you hear a claim that such and such a regulation will reduce air pollution and there will be some number of reduced health impacts the LNT model of air pollution impacts was used.  This presumes there is no threshold of an effect on an individual.  It extrapolates observed health effects on a population at high concentration down to low concentrations.  When the resulting small impact is multiplied by a large number of individuals then proponents of this approach claim reducing air pollution will result in a quantitative reduced health impact.

I think this is absurd as I will show in this example.  No one questions the fact that prolonged exposure to wood smoke can cause health problems.  I have no doubt that there are health studies that have conclusively shown that at high pollution levels people have contracted cancer.  For the sake of argument assume that the health studies have found that wood smoke at a continuous dose of 100 ppm for one year causes cancer.  The LNT model can be extrapolate that dose response down to 0.00019 ppm per minute.  Using that extrapolation model if 5,256 people sitting around campfires were exposed to the 100-ppm dose for one minute then the LNT models claims one of them will get cancer from that dose.  Anyone who has sat around a campfire probably has been downwind of the smoke and received a dose of wood smoke.  It does not matter what the actual health impact dose response rate is, if you extrapolate that down to the dose of people sitting around a campfire and multiply that by all the people sitting around campfires the LNT model predicts an impact.

Environmental activists combine the LNT model with epidemiological studies of air pollution to contrive health impact benefits particularly for inhalable particulates.  For example, in September, 2011 US EPA Administrator Lisa Jackson testified to Congress that fine particles kill hundreds of thousands of people in America every year, a claim based on EPA epidemiology and extrapolated projections.  However, Enstrom tested the validity of this relationship and found no effect of fine particulates.  Nonetheless, these results have been used for years to justify regulations and legislation.

Conclusion

I do not accept the premise that there isn’t a threshold of acceptable air pollution.  This presumption is behind the cost benefit analysis of most recent EPA air quality regulations.  Now it is being used in New York to justify the legislative phase-out of fossil fuels.  Coupled with the absence of evaluation of the life cycle environmental and economic impacts of fossil fuel alternatives this is a recipe for poor policy.

Fossil Fuel Phase Out Claptrap

Truthout is a nonprofit news organization dedicated to providing independent reporting and commentary on a diverse range of social justice issues.  According to the about description “Truthout works to spark action by revealing systemic injustice and providing a platform for progressive and transformative ideas, through in-depth investigative reporting and critical analysis. With a powerful, independent voice, we will spur transformations in consciousness and inspire both policy change and direct action.”  If the article Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most is any indicator, however, their platform is based on emotion and not facts.  The alleged problems with peaking power plants and neighborhood power plant impacts on local health are exaggerated and nearly fact free.  The proposed solution is untested and likely to make the lives that they want to improve worse.

I am a retired air pollution meteorologist with over 40 years-experience analyzing the effects of meteorology on electric operations.  While doing consulting work for the Environmental Protection Agency I evaluated air quality model performance and later worked at a utility company where I was responsible for ambient monitoring networks in the vicinity of power plants and evaluating their air quality impacts.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for those sources.  This background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The article is prefaced with a note that “this story is part of Covering Climate Now, a global journalism collaboration strengthening coverage of the climate story”.  The author is Leanna First-Arai. “a freelance journalist who covers environmental and climate (in)justice. Her work has appeared in Undark, Sierra Magazine, Yes! Magazine, Outside Magazine, on New England Public Radio and elsewhere”.

The Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most article describes the claims made in the recently released Fossil Fuel End Game report that I described here.  The basic premise is that New York City peaking power plants only operate a limited days per year, they are usually old and dirty plants located in disadvantaged communities, and they received around $5 billion to keep running in the last decade.  Therefore, they should be the first fossil plants to be replaced by clean energy.

I have been following this peaking power plant initiative for about a year and summarized my work here.  This article is the latest iteration of advocacy releases based on the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York StateI discussed the PSE report last year and the PEAK Coalition report entitled: “Dirty Energy, Big Money” in two detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. 

Oswego Harbor Power Plant

In order to show that this article is based on emotion and not facts consider the description and allegation related to the Oswego Harbor Power Plant.  In this section I have annotated (indented and italicized) my comments after each sentence from the relevant paragraph in the article.

Residents living within a one-mile radius of the Oswego Harbor Power Plant, one of only a handful of such plants left in Upstate New York, are ranked in the 99th percentile for incidence of heart attacks, based on an analysis of New York State Health Department data by the nonprofit research institute Physicians, Scientists and Engineers for Healthy Energy (PSE).

The insinuation here is that the residents within one-mile of the power plant have a high rate of heart attacks because of the power plant. 

The 73-year-old plant only went online six times in 2018 (the most recent year for which data are available).

There is a description of the plant in a US Army Corps of Engineers harbor infrastructure report that explains that there are two 850 MW units in operation and in service since 1975 – 46 years not 73.  The older units have been retired since before the turn of the century. The units burn residual oil that is stored on-site.  At the time of their construction residual oil was cheaper than coal and for many years residual oil was cheaper than natural gas so the units ran a lot in the late 1980’s.  The fuel price differential no longer supports the use of residual oil.  However, in times of great need the facility can generate 1,700 MW of dispatchable power without regard to weather-caused outages.

 The EPA Clean Air Markets Program Database provides data for the most recent quarter within 45 days so more recent data are available than claimed.  Table 1 lists annual data through 2020.  The important point in the context of this discussion is that emissions from the plant are minimal which is not surprising because of the short operating times.

 Table 1: Oswego Harbor Power Annual Emissions and Operations Data

Unit IDYear Operating Time Gross Load SO2 NOx CO2
  (Hours)(MW-h)(tons)(tons)(tons)
520169218,071442417,309
6201614623,212632423,659
520179219,132452517,426
6201714122,678562320,811
5201818626,025683225,075
6201816526,600652423,976
520199515,394371914,225
6201924023,600582522,407
5202024926,736693426,760
6202012523,906622521,024

But if residents suspect hazier-than-usual skies, no federal air quality data exists to help make sense of the short-lived plume of pollution, as the closest Environmental Protection Agency monitors are 40 and 70 miles away, respectively, in Syracuse and Rochester.

The insinuation that the DEC, EPA and owner of the plant know nothing about the plume of pollution is completely baseless.  The author clearly knows nothing about air quality regulations, air quality meteorology, or the Oswego Harbor plant.  The New York Department of Environmental Conservation (DEC) is responsible for maintaining air quality that meets the National Ambient Air Quality Standard limits under the guidance of EPA.  They do that by monitoring near emission sources and modeling facility emissions to estimate air quality impacts. 

 At this time there are no DEC air monitoring stations closer than Rochester and Syracuse.  EPA does not monitor air quality in New York.  However, that does not mean that there never was any air quality monitoring closer to the plant.  I know because I as responsible for submitting the data from the network around the Oswego plant.  After several years of not measuring any exceedances from the power plant DEC and EPA agreed that it was no longer necessary to run the monitoring network and it was retired by 1990.   At one time most, if not all power plants, had monitoring networks but one of two things happened.  If, like at Oswego, no measurements indicating problems were found then the networks were retired.  If problems were found then the emission limits were changed for the facility until the monitoring found that there were no problems.  Also note that these data were used to verify that the air quality models used to predict ambient levels near the plants were correct.  Under contract to EPA, I did that verification work using those data sets and later also compared the Oswego Harbor plant modeled impacts to observations.  That work proved that the models correctly characterize nearby air quality.

 It is not surprising that the modeling never showed anything approaching an exceedance of the National Ambient Air Quality Standards or that the highest observed monitored concentrations were accompanied with the smell of chocolate from the Nestles plant that was located in the opposite direction.  The stacks at Oswego are 700’ high and the plume rise from the hot gases pushes the plume higher.  As a result, the pollution plume is nowhere near the ground within a mile of the plant. 

The insinuated claim that the Oswego Harbor Power Plant is somehow associated with local high incidents of heart attacks is unsubstantiated.  The article states that the plant only ran six times in 2018 and the data show it only ran 352 hours so it was online for less than three days at a time.  Present operations are about 1% of the operating times and rates as in 1988 when the monitoring network that showed the plant did not adversely affect air quality.  If I had to guess why there is a high rate of heart attacks my money would be on the fact that Oswego is in the lake-effect snow belt and when it snows, it snows a lot.  Snow removal is a notorious cause of heart attacks.

Peaking Power Plant Replacements

The author and the advocates quoted in the article are unaware of the fundamental problem with the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  PSE defined peaking power plants by their current time of operation not by their design capabilities.  The Oswego Harbor Power Plant is the best example of this problem.  The plant was designed to provide base load power when it was thought that residual oil would continue to be a cost-effective fuel.  The two 850 MW units operated well when that was true but with today’s fuel costs it only offers support to system as backup capacity.  There are three nuclear plants within ten miles of the facility and if there is a problem with those units then the power plant can step in to replace their output.  For example, in the 2004 blackout Nuclear Regulatory Commission operating rules required the nuclear units to go offline and the Oswego Harbor Power Plant was called on to support the system until the nuclear units were allowed to go back online.  The units also come online when loads are very high and all power generation is needed.  There are other power plants in New York that operate much less than they were designed to operate that fulfill similar reliability needs.

The PSE report claims that all of the plants that they claim are peakers can be replaced by renewable energy and storage.  The problem with that is that their definition is based solely on operating times and does not consider the capabilities of the peaking units.  The New York electric system has more stringent rules than Texas.  In the wake of the blackouts last February, Texas is wrestling with how to prevent similar problems in the future by asking should power generators be required to guarantee that they can provide a certain amount of electricity?  New York’s response to this issue includes capacity payments to Oswego Harbor Power for 1700 MW of power six times a year.  This resource is dedicated to that need and can provide that capability because the capital investments necessary have already been paid, even though the fuel is relatively expensive it provides concentrated energy capable of 1700 MW, and the costs to maintain that much power capability are relatively low. 

The first problem with the PSE report claims that the steam turbine units like Oswego that provide peak capacity support can be replaced by renewable energy and storage is that the capital cost to develop enough energy storage to replace all those units has to be paid for a rarely used resource.  A major reason that New York’s capacity payments are as low as they are is because the resources needed to meet New York’s requirements has paid off those costs.  Replacing those facilities with anything will be much more expensive.  The second problem is that the renewable and energy storage approach proposed has never been implemented at the scale needed for New York’s electric resource requirements.  Replacing a system that has worked for decades with unproven technology could very well lead to reliability issues as the system is de-bugged.

Conclusion

All these analyses vilify peaking power plants oblivious to their value to the grid.  The PSE study estimated that they received around $5 billion in the last decade but only ran less than 5% of the time.  The New York electrical system pays for these units to provide capacity and ancillary services so that the electric system can reliably provide power when it is needed most.  The Texas energy system does not have a similar policy in place.  While Texas average prices are lower than New York prices their system is vulnerable to blackouts when peaking power is unavailable.  Simply put, New York peaking power plants are an insurance policy to prevent Texas-style blackouts.  The February 2021 Texas blackouts caused dozens of deaths and tens of billions of dollars in damages.  The New York peaking power plant insurance policy looks like a good deal to me.

Another big driver in the vilification of peaking power plants is the claim that they adversely affect air quality in neighboring disadvantaged communities. However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  My primary objection to this claim is that the health effects attributed to peaking power plants are based on air quality impacts from ozone and particulate matter.  However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5, that the impact is away from the adjoining neighborhoods.  That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most. Importantly regulations are now in place that ensure that they are retired or that their pollution control equipment is upgraded on a schedule that guarantees in-kind replacement of capacity and ancillary services.   In order to maintain existing levels of affordability and reliability I think it is best to rely on a proven solution using fossil fuels.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because wind, solar, and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly, in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.  It is the height of hubris that the New York legislature has pending bills to over-ride the reliability planning process and existing environmental regulations without including a feasibility study to define the wind, solar and energy storage resources needed, the technological readiness of those resources at the scale needed and the costs of that approach.

Finally, I do not disagree with the premise that disproportionate environmental risks to disadvantaged communities need to be addressed.  However, that goal has limits.  First, and foremost, it simply is not good policy to expect the removal of all environmental impacts.  For example, a replacement state-of-the-art natural gas fired combustion turbine that reduces existing impacts substantially should be an acceptable choice because it provides a proven affordable solution and reduces well-known impacts.  The proposed alternative of renewable energy and energy storage is unproven technology at the scale needed, is costly when the cost to provide uninterruptable power is considered, and could very well lead to worse overall environmental impacts especially when the effects of the rare earth metals needed for those resources is included.  The result is there is a high likelihood of problems with affordability, reliability, and environmental impacts due to the implementation of the proposed solution.  If those problems occur then the disadvantaged communities that these advocates want to protect will be disproportionately impacted.  I don’t think that the advocates understand that those impacts could be worse than the problems that they want addressed.

Community and Climate Investment Act Climate Pollution Fee

In the spring of 2021, the New York state Senate introduced the Climate and Community Investment Act (CCIA).  Coming on the heels of the Texas energy debacle one might think that politicians would not propose any changes to energy and environmental laws until the causes of that disaster were understood or would at least make implementation contingent upon feasibility studies to determine if the ambitious goals of this legislation don’t risk a similar outcome in New York. Such is not the case, however as I will show in this post

I have written extensively about implementation of the Climate Leadership and Community Protection Act (CLCPA) because I believe it will adversely affect affordability and reliability as well as create more environmental harm than good. The CCIA will make those impacts worse.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The sponsor memo for this proposed regulation lists specific provisions in the proposed legislation.   I prepared an annotated version of the draft bill that includes internal links to the sections of the bill corresponding to those provisions.  The summary of Senate Bill S4264A states:

Enacts the climate and community investment act; prioritizes the allocation of public investments in disadvantaged communities; addresses climate change challenges through the expansion and growth of clean and renewable energy sources; adopts best value requirements for the solicitation, evaluation and award of renewable energy projects;  establishes a community just transition program; establishes a climate pollution fee and a household and small business energy rebate; and creates the climate and community investment authority.

This article discusses the climate pollution fee which is another name for carbon pricing.  In theory, this supposedly measures the cost of the accumulated damage for centuries to come from emitting a ton of carbon dioxide today.  According to Resources for the Future (RFF), carbon pricing is a climate policy approach that works by charging industrial sources for the tons of emissions of carbon dioxide (CO2) they emit.  The problem is that there is a large gap between the elegant theory of carbon pricing described by RFF and real world carbon pricing.  In theory applying a carbon price across the globe on all sectors could incentivize the market to find the most efficient solution to provide energy at the lowest cost and not unduly affect the public by using the revenues to replace existing taxes.  The reality of the CCIA climate pollution fee proposed is that it is in one limited area with the funding going to special interests. As a result, tt is a regressive tax and a prescription for potential leakage and misapplied price signals.

The CLCPA mandated that the Department of Environmental Conservation (DEC) stablish a value of carbon.  At the end of 2020 DEC published this guidance document.  The Value of Carbon Guidance provides values for carbon dioxide, methane, and nitrous oxide for use by State agencies along with recommended guidelines for the use of these and other values by State entities. The guidance Value of Carbon Guidance  document summarizes the methodology and rationale.  The recommended values are provided in the Appendix: Social Cost Values. The CCIA legislation shows no sign that the months long CLCPA process to develop an appropriate system for valuing carbon was considered, much less incorporated.

Discussion

In order to address the recognized problems of a climate or carbon pollution fee in just New York, the proposed regulation includes a border carbon adjustment fee.  The fee applies to any carbon-based fuel sold, used or brought in the state by an applicable entity.  Consequently, the logistical requirements to calculate border adjustments is a big effort. 

The premise of a climate pollution fee is that it will incorporate the future cost to society of CO2 emissions today.  The DEC Value of Carbon guidance bases its recommendations upon the work of the Federal Integrated Working Group (IWG) social costs of carbon.  Dr. David Kreutzer explains that:

Estimating the social cost of carbon is susceptible to political pressure and model-gaming. The assumptions in play—about unsupportable time horizons, exaggerated emissions projections, overly high estimates of carbon dioxide’s impact on warming, and others—are all too easily corrupted, resulting in wildly varying estimations.

In fact, reasonable assumptions can push the social cost of carbon negative (which implies that a policy of subsidies for carbon dioxide emissions is the answer). However, the single input that has the most potential to overstate the social cost of carbon is understating the discount rate.  The constant pressure to justify ever lower discount rates for social cost of carbon calculations is almost comical when it mistakes wealth for poverty.

It is worth noting that the DEC Value of Carbon guidance did not follow the IWG recommendation for the discount rate recommended choosing instead to pick a lower value.  The CCIA fee appears to use the IWG recommended discount rate of 3%.

The fee calculation methodology is complicated.  The price is adjusted by year and a newly defined environmental integrity metric.  That metric adjusts the price based on the state’s reductions relative to a defined trajectory.  For example, the 2021 statewide GHG emission target is set at 85% of the 2018 GHG emissions.  DEC has not released its draft emission inventory for years since 1990 but my money is on an increase since 2018 simply because the State closed down 1,070 MW of nuclear capacity in 2020 and is closing another 1,080 MW of nuclear capacity this year.  I estimate that the power needed to replace those facilities will generate over 8,000,000 tons of CO2.  The CLCPA Climate Action Council process is underway and I believe is charged with determining the appropriate reduction schedule.  It is very likely that the schedule in the proposed law will not be consistent with the CLCPA recommendation.

I have given up trying to figure out how the environmental integrity metric will affect the price because of its complexity.  Without a lot more work I cannot determine how the five-year metric using cumulative actual and target emission reductions could affect the differing adjustments to the carbon pollution fee.  My impression is that the methodology and values chosen will ensure that the maximum increase (10%) of the climate pollution fee is inevitable.

The last statewide GHG emissions inventory developed by the New York State Energy Research & Development Authority estimated that the total emissions in 2016 were 377 million metric tons of CO2e.  Assuming that emissions will be the same in 2022 when the proposed legislation starts applying the fee the annual fee will be over $16 billion.  The annual adjustments keep the fees about the same for five years or so but then the reductions in emissions reduce the fees collected.  Obviously when all the GHG emissions have been eliminated the fee will also be eliminated. 

My biggest problem with this proposed legislation is mandates for specific information that is already available elsewhere.  In order to determine the tax levy, the emissions must be known.  The regulation includes a section for the calculation of emission factors which when combined with electricity production data can be used to estimate emissions.  This is a flawed approach for those facilities that actually monitor and report their emissions.  Direct measurements are a more accurate methodology than this approach.  Moreover, the DEC and NYSERDA already have a process in place to calculate emissions.  Importantly, the New York Independent System Operator has proposed a carbon pricing scheme that includes a methodology to estimate emissions for its fees.  Both systems are incompatible with this law.

There is a section for exemptions and deductions.  In order to prevent double payments a source affected by 6 NYCRR Part 242 (the Regional Greenhouse Gas Initiative) can deduct “the amount it paid to purchase CO2 emission allowances”.  Exemptions for de minimis quantities of emissions are also allowed.

Emissions leakage refers to a situation where a policy in one jurisdiction moves the emissions out of that jurisdiction to a less restrictive one such that the total emissions are not actually reduced.  The CCIA law includes a mitigation policy that calls for studies of ways to reduce this effect.  Leakage has been a concern in the CLCPA implementation process so the scoping plan recommending policy measures to prevent emissions leakage is redundant except for the fact that the CLCPA evaluation has not included an explicit cost like the $16 billion annual CCIA fee.

The legislation creates funds within the authority including 33% for the “community just transition fund”, 30% for the “climate jobs and infrastructure fund”, 30% for the “low-income and small business and household energy rebate fund”, and 7% for the “worker community assurance fund”. 

Finally, the climate pollution fee includes a requirement for report on the implementation of the fund.  The report is supposed to include the total revenues, the effectiveness of the fee to reduce GHG emissions, the amount of leakage, and overviews of the benefits and costs.

Conclusion

Dr. Steven McKitrick evaluated carbon pricing policies in Canada and explained that “there may be many reasons to recommend carbon pricing as climate policy, but if it is implemented without diligently abiding by the principles that make it work, it will not work as planned, and the harm to the Canadian economy could well outweigh the benefits created by reducing our country’s already negligible level of global CO2 emissions”.  This is entirely analogous to New York and the CCIA.   Importantly he notes:

However, a beneficial outcome is not guaranteed: certain rules must be observed in order for carbon pricing to have its intended effect of achieving the optimal balance between emission reduction and economic growth. First and foremost, carbon pricing only works in the absence of any other emission regulations. If pricing is layered on top of an emission-regulating regime already in place (such as emission caps or feed-in-tariff programs), it will not only fail to produce the desired effects in terms of emission rationing, it will have distortionary effects that cause disproportionate damage in the economy. Carbon taxes are meant to replace all other climate-related regulation, while the revenue from the taxes should not be funnelled into substitute goods, like renewable power (pricing lets the market decide which of those substitutes are worth funding) but returned directly to taxpayers.

The CCIA violates all these rules.  New York has emissions regulations for Part 242 and the CLCPA that both mandate specific reductions.  The revenue from the climate pollution fees won’t even be used to support renewable energy development and only a small fraction will be returned to ratepayers.  This is simply a regressive tax that will dis-proportionally adversely affect those it purports to want to help.

New York Climate and Community Investment Act – Overview

This spring the New York state Senate has introduced the Climate and Community Investment Act (CCIA).  This first post provides an overview of the proposed legislation.  Subsequent posts will address the many problems of this proposal. 

I have written extensively about implementation of the Climate Leadership and Community Protection Act (CLCPA) because I believe it will adversely affect affordability and reliability as well as create more environmental harm than good. The CCIA will make those impacts worse.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

On April 13 the New York Senate’s Standing Committee on Environmental Conservation and Standing Committee on Energy and Telecommunications host a public hearing to discuss and receive input from stakeholders on the Climate and Community Investment Act.  The summary of Senate Bill S4264A states:

Enacts the climate and community investment act; prioritizes the allocation of public investments in disadvantaged communities; addresses climate change challenges through the expansion and growth of clean and renewable energy sources; adopts best value requirements for the solicitation, evaluation and award of renewable energy projects;  establishes a community just transition program; establishes a climate pollution fee and a household and small business energy rebate; and creates the climate and community investment authority

The sponsor memo for this proposed regulation lists the following specific provisions.  I will address these provisions briefly here (indented and italicized) and in more detail in subsequent articles.  I prepared an annotated version of the draft bill that includes internal links to the sections of the bill that are described below.

Section 1 of the bill establishes that the bill shall be cited as the Climate and Community Investment Act.

No comment

Section 2 of the bill establishes legislative findings that climate change is adversely affecting economic well-being, public health, natural resources, and the environment of New York; and actions undertaken by New York to reduce greenhouse gas emissions will have an impact on the global greenhouse gas emission and the rate of climate change.

The findings list the New York alleged impacts of climate change on the state that are common to all laws and regulations in recent years.  One aspect that is different is an emphasis on arguments that those impacts “heighten vulnerability” of disadvantaged communities.  Also included is an argument that disadvantaged communities experience “greater exposure to air pollution and subsequent negative health impacts”.  There are several arguments that that COVID-19 makes the air quality, disadvantaged community and economic problems worse.  They even managed to get a reference to George Floyd in these findings.  The final arguments claim that climate change is having a detrimental effect on the New York economy so community investment will be a good thing.

 The findings then go on to claim that addressing these effects has value.  They argue that “it is vital that the state’s investments in clean and renewable energy be protected and monitored through all stages of development to make certain that they are effective in producing the intended results”.  They suggest that “properly trained craft personnel” and “project labor agreements, responsible contracting and prevailing wage requirements” are needed. 

 The findings then claim that New York actions will be affected by the actions undertaken by New York to reduce GHG emissions and that global warming must be limited to no more than 2o C “by reducing emissions at least 80 percent below 1990 levels by 2050” from industrialized nations.  They note that in order to meet the Climate Leadership and Community Protection Act that it is in the interest of the state to promote and provide resources for the infrastructure transformation.

Finding 18 states

“By exercising a global leadership role on greenhouse gas mitigation and climate change adaptation, New York will continue to position its economy, technology centers, financial institutions, and businesses to benefit from national and international efforts to address climate change. Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change. In addition, such action will encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented. It will also advance the development of green technologies and sustainable practices within the private sector, which can have far-reaching impacts such as a reduction in the cost of renewable energy components, and the creation of jobs and tax revenues in New York.”

 The findings wind up concluding that it is in the interest of New York to take rapid action to reduce GHG emissions and “transition to a just clean energy economy”.  The recommend that the way to do this is to establish a dedicated authority to “nimbly” manage the proceeds from polluter fees, disburse funds and prioritize projects and funds for impacted communities, reduction strategies, and assist workers impacted by the transition. 

Section 3 of the bill amends article 19 of the environmental conservation law to add a new title 13 addressing air pollution pricing regarding methodology, and air pollutant price index, implementation of fees, allocation of revenues, inventory, transportation pollution and reporting.

This section establishes “Methodology and valuation of pollution price index” that mandates a social cost of pollution for all regulated air contaminants.  Not surprisingly once they are established then “all covered sources shall be required to pay the fee”.  There will be a “value of pollution and mitigation program fund” trust fund established and the funds will be allocated as follows:

        • 40% to the environmental justice office
        • 20% to “expanding, operating, and maintaining” the Title V emissions inventory
        • 20% to “expanding, operating, and maintaining” air quality and point source monitoring within DEC
        • 20% to be allocated at the discretion of the authority
        • “No funds shall be allocated to fund police, prisons or related infrastructure”

The regulation specified that the “authority shall update and publish the inventory of emissions from Title V sources to:

        1. assess the extent to which given regulated air contaminants, especially air contaminants that have highly adverse health impacts, are co-emitted with greenhouse gas emissions;
        2. assess the extent to which regulated air contaminants that have especially adverse health impacts are likely to be reduced over time as a result of:
          1. the fee established in section three thousand forty of the tax law; and
          2. the investment programs established in title nine-C of article eight of the public authorities law;
        3. identify and analyze emissions hotspots and cumulative burdens, pertaining to regulated air contaminants in order to prioritize emissions reductions in these areas;
        4. assess emissions and pollution-related health impacts associated with the transportation sector; and
        5. make the Title V emissions inventory more accessible to the public including, but not limited to, taking action to release the related data, analysis and assumptions of agency websites.

This regulation also mandates development of a plan to accelerate the reduction of regulated air contaminants from mobile sources.  The plan is required to consider specific mechanisms such as electrification of freight transportation and market-based mechanisms.

Section 4 of the bill amends the executive law to add a new section 184 to limit diversion of funds dedicate to the climate and community investment.

“Diversion of funds dedicated to climate and community investment to the general fund of the state for any other purpose is prohibited”.  This section addresses other potential ways the funds could be diverted.

Section 5 of the bill amends the labor law by adding article 8-b which establishes responsible contracting, labor and job standards and worker protection.

This is way beyond my expertise but I believe that it is simply a mandate that all climate infrastructure funded by the state be done by union labor.  Please refer to the attachment for further information.

Section 6 of this bill amends section 231 of labor law to add a new subdivision 8 to require prevailing wage for building service employees that are employed in any building or facility that has received grants or tax abatements of one million or more.

The summary covers the section.  Please refer to the attachment for further information.

Section 7 of this bill amends the public authorities law by adding a new title 9-c b which establishes the climate change just transition.

For this overview the following list of the contents of the proposed amendments will suffice:

GENERAL PROVISIONS

Section 1910. Definitions.

        1. Coordination of programs.
        2. Transparency and accountability.
        3. Report on community ownership.

 SUBTITLE II

COMMUNITY JUST TRANSITION

Section 1914. Definitions.

        1. Office of community just transition.
        2. Establishment of community just transition program.
        3. Administration by the authority.
        4. Allocation of funds.
        5. Selection process.
        6. Identification of disadvantaged community needs.
        7. Community decision-making and accountability mechanisms.
        8. Criteria for implementing community accountability mechanisms.
        9. Consultation with the working group.

 SUBTITLE III

CLIMATE JOBS AND INFRASTRUCTURE

Section 1924. Definitions.

        1. Establishment of climate jobs and infrastructure program.
        2. Administration by the authority.
        3. Allocation of funds.
        4. Funding instruments.
        5. Selection process and criteria.
        6. Consultation with the advisory council.
        7. Comprehensive approach to existing structures.
        8. Advisory council of the climate jobs and infrastructure program.

 

SUBTITLE IV

JUST TRANSITION FOR IMPACTED WORKERS AND COMMUNITY ASSURANCE

Section 1933. Definitions.

        1. Establishment of worker and community assurance board.
        2. Establishment of worker assurance program.
        3. Establishment of community assurance program.
        4. Administration.
        5. Allocation of funds.
        6. Selection process.

1939-a. Designation of significant impact.

1939-b. Public engagement and social dialogue.

1939-c. Reporting.

Section 8 of this bill amends article 8 of the public authorities law to add a new title which establishes the climate and community investment authority.

This is another instance where I haven’t the experience to comment on the powers and duties.  The annotated version of the proposed law contains a link to § 2799-yyyy Powers and Duties that includes some powers I found surprising.  For our purposes the primary duty of interest is (w) the power to fix and collect “such fees, rentals, and charges” to provide sufficient revenue to meet the obligations of the authority.

Section 9 amends the tax law to add new articles 42 and 43 which establishes climate pollution fee and the Household and Small Business Energy Rebate.

The climate fee is complicated.  A border carbon adjustment fee is mandated.  The fee itself is based on carbon dioxide equivalent so is it inconsistent with the Part 496 methane and nitrous oxide carve outs.  It covers any carbon-based fuel sold, used or brought in the state by an applicable entity and fugitive methane emissions and sets its own price on carbon which is inconsistent with the value of carbon guidance prepared by DEC.  The price is adjusted by year and a newly defined environmental integrity metric.  That metric adjusts the price based on the state’s reductions relative to a defined trajectory.  

Section 10-11 of this bill establishes a severability clause. Section 12 of this bill sets the effective date.

No comment

Conclusion

The February Texas blackouts should be a cautionary tale for politicians who think their political will is sufficient impetus not only for an unprecedented transition of the energy system but also to use the transition to redress “legacies of racial and ethnic discrimination”.  The legislative findings and declaration roll up every possible effect of climate change on dis-advantaged communities not only as a rationale for the legislation but also to define the proposal as a moral issue unworthy of criticism. 

Unfortunately, there is much to criticize in the proposal.  It is not clear why a new air pollution fee program is needed to replace the existing fee program and disingenuous to not provide that explanation in the findings.  It layers requirements and mandates on existing programs and processes.  The carbon price scheme ignores DEC value of carbon guidance.  The law establishes an emission reduction trajectory target that is a goal for the CLCPA Climate Action Council process that is underway and will not develop its trajectory for months.  Carbon pricing appears to be the preferred Progressive policy approach to fund the transition but, in many cases, and in this proposal in particular, the suggested methods deviate substantially from carbon pricing theory (and not in a good way).

The foundation of this legislation and the Climate Leadership and Community Protection Act is that present renewable energy technology can be used to safely transition the energy system away from fossil fuels while maintaining affordability and reliability in the next 30 years.  No jurisdiction, however small, has actually achieved the zero-emissions goal of New York’s climate ambitions.  Jurisdictions that have tried to achieve less ambitious goals have had issues with affordability and reliability.  I believe that unless a feasibility requirement is incorporated in this proposed regulation, that blackouts similar to the what occurred in Texas in February 2021 are inevitable in New York.  Importantly the worst effects of those blackouts and higher energy costs will be on the dis-advantaged communities that this law purports to want to help.

Evaluation of Cornell Report: Can renewable generation, energy storage and energy efficient technologies enable carbon neutral energy transition?

Yale Climate Connections recently described an article, Can renewable generation, energy storage and energy efficient technologies enable carbon neutral energy transition? by the Ning Zhao (Systems Engineering, Cornell University, Ithaca, NY) and Fengqi You (Systems Engineering, Cornell University and Robert Frederick Smith School of Chemical and Biomolecular Engineering, Cornell University).  The study considered the New York targets and “analyzed scientific and economic data and concluded that the goals are technologically and financially feasible.”  I reviewed their work and disagree.  The inconsistencies between their results and other analyses done as support to the Climate Leadership and Community Protection Act (CLCPA) and omissions in their evaluation method do not make their conclusions credible.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in posts on implementation of the CLCPA because I  believe it will adversely affect affordability and reliability as well as create more environmental harm than good which affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The paper lists the following highlights:

  • A novel bottom-up optimization framework for energy decarbonization transitions.
  • Feasibility investigation on the decarbonization goals for New York State.
  • Offshore wind as major electricity source by the end of the planning horizon.
  • Heat pumps and geothermal technologies as main space heating methods.
  • Natural gas as an important but temporary energy source at early transition stage.

An optimization framework is ultimately no more than a curve fitting exercise.  Think back to a laboratory experiment where something is measured at several points, the results are plotted, and the graph is used to infer results outside the range of the observations.  The theory is that if you have enough descriptive variables, can make reasonable assumptions about the range and potential effect of each variable used, and then develop a sophisticated optimization model, then it can be used to project how, in this case, the energy system could transition to zero emissions technology.  The authors note that “To the best of our knowledge, there is no existing energy transition optimization study for the decarbonization of multiple energy sectors that incorporates region-level electricity generation and space heating thermal energy production, while accommodating scheduled energy system changes and climate targets”.

Of course, the problem is that the electric energy system is very complex.  As a result, including all the variables and constraints is a huge undertaking.  All it takes is inadvertently omitting one key constraint and the results of such a model aren’t credible.  For example, consider the Integrated Planning Model (IPM) which is used by the Environmental Protection Agency to evaluate the potential impacts of proposed air quality regulations.  The developers of IPM explain that it “provides true integration of wholesale power, system reliability, environmental constraints, fuel choice, transmission, capacity expansion, and all key operational elements of generators on the power grid in a linear optimization framework.” This model is so detailed that it includes “a detailed representation of every electric boiler and generator in the power market being modeled”.  However, in order to be able to afford to run the model simplifications are often employed.  In New York, the EPA version simplifies the transmission network so much that the fact that New York City is in a load pocket is lost and the results are not credible.  There are work arounds but, in my experience, the EPA version of this model often does not work well enough to provide credible results for New York State.

Evaluation of Figure 3

In order to evaluate the conclusions, I compared the results from the Zhou and You (2020) optimization model (“Cornell Study Model”) to observations and projections made by others.  The article does not make this easy.  For example, a key evaluation metric are the projections of annual electric generation by source shown in their Figure 3.  In order to be able to compare numbers I had to manually extract them off a blown-up version of the graph which gives a resolution of ~2,000 GWh.

As shown in Figure 3, the initial year for the study is 2019.  I assume that means that they ran their optimization model using input data so it is possible to check the accuracy of it relative to observed data.  I checked the model’s annual electric generation by source against the observed data that year from the New York Independent System Operator (NYISO) 2020 Load & Capacity Data report in Table III-3c Annual Net Energy Generation by Zone and Type – 2019

Despite the low resolution possible with my interpretation of the graph it is clear that the model does not do an adequate job representing the New York electric system annual electricity generation by source relative to 2019 data.  There were comparison data available for seven source categories.  There was insufficient resolution or it was not clear which source category should be used for the comparison for the others.  I don’t think there are any ambiguities for the nuclear, on-shore wind, and import generation categories.  The Cornell Study Model over-predicted nuclear generation by 24% or nearly 11,000 GWh.  Worse it exceeds maximum possible generation if the nameplate capacity operated every hour of the year by 7,106 GWh or 15%.  In order to get the 2019 generation shown in the graph, the 1,985 MW of onshore wind capacity would have had to be 46% vs. the observed 25%.  The Cornell Study Model under-predicted imports by 14,037 GWh or 61%.  There is an 11% difference in the hydro numbers but I think that is due to the exclusion of pumped hydro in the Cornell Study Model.  The remaining three categories are all natural-gas firing categories.  If they are all summed up the difference is less than 10% which is close enough for this methodology.

The 2040 Figure 3 generation source type projections were also evaluated.  Last fall the Analysis Group presented the results from their Climate Change Phase II Study for the NYISO.  Importantly, the analysis looked at the generation resource requirements “that meets electricity demand in every hour all year”.  Last October  I evaluated their results and noted that I agree with the methodology but was worried that they had not done an adequate job defining the worst renewable resource availability case.  Because they evaluated one-month periods their electric energy projections (GWh) are not comparable to the Cornell Study Model.  The Analysis Group did provide capacity (MW) projections for different generation sectors.  The Cornell Study report includes supplemental data with a spreadsheet (S1_Data_for_Policy_and_Geothermal) that lists capacity factors used in 2040.  Assuming that the capacity of each sector equals the projected energy (GWh) in Figure 3 divided by those capacity factors and number of hours, then there is comparable capacity (MW) data.  For energy storage I used information from section 6 of the paper: “For the energy transition under the scenario with carbon price policy and geothermal technologies, the electricity storage capacities in 2025, 2030 and 2050 are 2.9, 4.4 and 7.2 GW, respectively; the energy capacity for electricity storage are 3.7 GWh in 2025, 5.6 GWh in 2030, and 9.3 GWh in 2050”.  For 2040 I took the average of the 2030 and 2050 projections.

Tables 9 -12 in Climate Change Impact and Resilience Study Phase II list the nameplate capacity for zero-emission resource sectors.  I compared the Cornell Study Model nameplate capacities as calculated above in a summary table.  The Resilience Study considered two cases: one with the CLCPA mandates and one without.  The Study also compared their results with NYISO Grid in Transition study that also seeks to understand the reliability and market implications of the State’s plans to transition to clean energy sources.  That study also considered two similar cases.  The energy transition case study projections for both studies are markedly different than the Cornell Study.  For example, in Table 9 the Resilience Study projects on-shore wind capacity 68% higher, distributed solar 41% higher, utility-scale solar 88% higher, nuclear 29% higher, and energy storage 63% higher.  Of the 12 resource categories in the Resilience study only on is “close” at 11% different.

Discussion

I will briefly explain why I think there are such significant differences.  The biggest problem is the time-scale for the evaluation.  The paper states:

The demand predictions for annual electricity and space heating thermal energy within the planning horizon for New York State are shown in Fig. 2(a) in blue and orange curves, respectively. The energy demands are expressed in an annual basis, which has been applied in previous optimization works on energy system transition considering high-penetration of variable renewable energy. The spatial resolutions for both the electric and space heating thermal energy are state level.  In other words, the state-level demands as shown in Fig. 2(a) would be balanced with the energy supply in the state through optimization.

I interpret that to mean that the optimization is based on annual state-wide parameters.

If my interpretation is correct, then the entirety of the Cornell Study Model results can be ignored.  On an annual basis the Texas electric system worked but when there was a short-lived extreme stress on load the result was massive blackouts.  All the credible work done for CLCPA implementation determine the resource requirements based on short periods because an electric system that depends upon renewable energy has to address the period with the lowest wind and solar availability not any long-term average.

The ultimate problem is that no matter how many wind turbines and solar panels there are, when the sun isn’t shining and the wind isn’t blowing no electricity is generated.  In fact, the credible studies include a special resource to address those periods.  On October 8, 2020 Kevin DePugh, Senior Manager for NYISO Reliability Planning, made a presentation  that lists the characteristics of this Dispatchable Emissions-free (DE) resource:

  • Large quantity of DE Resource generation is needed in a small number of hours;
  • DE Resource has low capacity factor (~12%) during the winter;
  • DE Resource has only a 3.7% capacity factor in the summer;
  • DE Resource is not needed at all during spring and fall;
  • Substantial quantity of DE Resource capacity is needed, the energy need is minimal;
  • DE Resource must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping need;
  • On an average day, storage can meet evening peaks, but the DE Resource must generate if storage is depleted and renewable generation is low; and
  • In the Winter CLCPA scenario, the DE Resource output across the state must increase from 362 MW (1.1% of DE Resource nameplate capacity) to27,434 MW (85.4% of name plate capacity) in six hours of the most stressed day.

The Cornell Study Model did not address this problem because they optimized using annual parameters.  Omitting this problem is a fatal flaw.

I noted other issues before I stopped looking.  As noted previously the optimization model did not reproduce the 2019 resource mix.  For energy storage, “the technology specification  and economic data for Hornsdale Power Reserve Battery Energy Storage System that was installed by Tesla are used for battery storage systems in this study”.  However, the facility is making most of its money providing Frequency Control Ancillary Services and is not being used for energy storage.  I think the state-wide optimization approach smooths out all the transmission constraint issues which is a problem even in the considerably more detailed IPM system.  The optimization model projected that 25,714 MW of offshore wind capacity would be needed but the National Renewable Energy Lab (NREL) has determined that New York offshore technical potential estimate is only 21,063 MW.

Conclusion

I have no doubt that advocates for the CLCPA will point to the Yale Climate Connections report of this study as proof that New York’s climate goals are achievable.  However, even this cursory evaluation of the approach and results indicates that the claim that the goals are technologically and economically feasible are simply not credible.

Climate Leadership and Community Protection Act Lesson from the German Energiewende

The German Energiewende (“energy transition”) is often touted as an example for the Climate Leadership and Community Protection Act (CLCPA).  I agree but, as explained in a recent article Daniel Wetzel at German national daily Die Welt, the attempt to transition to green energy has shown that there are significant problems using today’s technology.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in posts on implementation of the CLCPA because I  believe it will adversely affect affordability and reliability as well as create more environmental harm than good which affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

According to Clean Energy Wire’s guide to the Energiewende, “Germany’s experience offers valuable insights and can serve as an example on how to wean a major economy off fossil fuels, even for countries with their own unique conditions and challenges”.   However, a German Government Audit report warns that the Energiewende is causing higher costs, and that there is a real danger of electricity shortfalls.  Pierre Goslin summarizes the report in “Explosive” German Government Audit Report: “Energiewende” Has Become “A Danger to all Germany”.

Goslin reports:

The “Energiewende” (transition to green energies) has seen Germany recklessly rush into wildly fluctuating wind and solar energy without properly planning the grave impacts they would have on the power supply grid and prices.

The German auditors had already voiced harsh criticism three years earlier in another special report, whose main focus had been on the high cost of the Energiewende. The latest report now also includes “an explosive analysis” on power supply instability and the high probability of power shortfalls.

The report finds that not only have the costs spiraled out of control, but that the German federal government “does not have a sufficient view of the emerging, real dangers to the security of supply” and that “ever higher electricity prices” are to be feared in the current system.

German electricity are among the highest in the world, and there is still no end in sight for the cost spiral. One study found that another whopping 525 billon euros will be needed by 2025 to upgrade the power grid, according to Die Welt.

The development of green energies in Germany has gotten so bad that the Federal Audit Office sees the risk the Energiewende could “endanger Germany as a business location and overburden the financial sustainability of electricity-consuming companies and private households.”  “This can then ultimately jeopardize the social acceptance of the energy transition,” warned Scheller.

Die Welt characterizes the Government Audit report as “explosive” and a long overdue wake-up call. The auditors accuse the federal government of not having properly taken into account the consequences of the coal phase-out, making assumptions that seem “unrealistic or are outdated by current political and economic developments” and making overly optimistic assumptions on the future available wind and sun.

Advocates for the CLCPA believe that wind and solar provide an economic way to transition off fossil fuels.  David Wojick recently published an article that succinctly explains why that approach why one factor makes that a false assumption: the Minimum Backup Requirement (MBR).  Wojick explains that “The minimum backup requirement is how much generating capacity a system must have if it is to reliably produce the electricity we need when wind and solar don’t.”  I have written about this issue but was unable to simply describe it this well.

Michel at the Trust, yet Verify blog evaluated the potential effect of increased electricity production from intermittent energy sources in a post using a simple solar and wind capacity increase data analysis model and found that in Belgium in enormous amounts of over-building are required to cover periods with low wind and solar.  With help from Michel we did a similar analysis for New York and I found that even with unrealistic assumptions about the “best case” availability of solar and wind capacity, there are periods with significant deficits. In order to prove the extraordinary claim that solar and wind can replace existing fossil the State of New York, a similar type of analysis using actual data to estimate realistic energy production must be done. That is the only way to provide the extraordinary proof showing just how much energy storage will be required to prevent deficits.

Conclusion

The Government Audit report accuses the federal government of making assumptions that seem “unrealistic or are outdated by current political and economic developments” and making overly optimistic assumptions on the future availability of wind and sun available.  The draft plans for the CLCPA are going down that same path.  I believe the German results will also occur in New York.

Climate Leadership and Community Protection Act Off-shore Wind Resiliency

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. 

The CLCPA was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation but there is one massive flaw.  The lawmakers who enacted this law presumed that the transition of the state’s energy system could be implemented by political will so did not include feasibility conditions in the targets or schedules.  This post is a short description of one aspect of the many implementation problems of this law.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in posts on implementation of the CLCPA because I  believe it will adversely affect affordability and reliability as well as create more environmental harm than good which affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

One of the targets of the CLCPA is to develop 9,000 MW of offshore wind by 2035.  This is considered necessary because off-shore wind has a higher resource availability.  Importantly this is just the start of what is accepted as a much larger offshore wind capacity that eventually will be needed for the ultimate goal of a net-zero emissions economy in New York in 2050.  For example, the Brattle Group analysis for the NYISO, New York’s Evolution to a Zero Emission Power System, estimates that 25,000 MW of offshore wind will be needed in 2040.  This article considers resiliency of the offshore wind capacity needed for the CLCPA.

Tony Heller writing at  Real Climate Science does an amazing job digging up newspaper accounts of past weather events like this description of the “Greatest Cataclysm in American History”.   In that article he uses newspaper archives and other contemporaneous accounts to describe the extreme weather on March 27, 1913 when there was widespread flooding in Indiana and Ohio, a massive tornado hit Omaha, NE, and tornadic storms ranged east into Pennsylvania.  One can only imagine the hysterical cries of climate change impacts if this situation were to repeat itself today. 

I think that comparing the weather of the past to today is important to understand that natural variability causes most of the observed extreme weather observed.  Historical weather observations should also be used to evaluate plans for the future.  If we cannot plan for the past then we shouldn’t even try to plan for the future.  Heller recently described a 2014 report from the Swiss Reinsurance (Swiss Re) Company titled “The Big One, the East Coast’s USD 100 billion hurricane event” that is the impetus of this post.  In the report Swiss Re examines how the 1821 Norfolk and Long Island hurricane would impact the region today. 

The Swiss Re report’s introduction describes the storm:

Nearly 200 years ago, a powerful hurricane decimated the Mid-Atlantic and Northeast United States. Packing wind gusts of over 156 miles per hour, the Norfolk Long Island Hurricane of 1821 surged up the Eastern Seaboard creating chaos and wreaking havoc from the Outer Banks of North Carolina all the way up to the Boston metropolitan area. If this hurricane was measured by today’s standards, it would be a strong Category 4 storm — unlike anything the Mid-Atlantic and Northeast have recently seen or experienced.

In comparison, Hurricane Sandy, with its unique track, 1,000-mile-wide wind field, and low central pressure, pushed record-breaking storm surge into the New York and New Jersey coasts, destroying businesses, homes, and lives in a short 24-hour period. But for all the devastation and damage that Hurricane Sandy brought, its intensity at landfall, measured by 1-minute maximum sustained winds, was equivalent to a weak Category 1 hurricane. Other events in recent years (Irene, Isabel, Gloria, and Bob), while significant, weakened prior to landfall, coming onshore as either Category 1 or Category 2 hurricanes, and not the major hurricanes originally anticipated and feared.

The report states that “If the 1821 Hurricane were to happen today, it would cause 50% more damage than Sandy and potentially cause more than $100 billion in property losses stemming from storm surge and wind damage.”  I had never heard of this storm but I knew about the “Great Hurricane of 1938” which decimated Long Island and New England leaving over 700 dead.  The question is how would a hurricane similar to these storms New York’s proposed offshore wind facilities.

The New York State Energy Research and Development Authority Offshore Wind Projects site describes the current status of the program to reach the 9,000 MW target by 2035.  As of early 2021 there are five offshore wind projects in active development.  The following figure from the website shows where the projects from the first two offshore wind procurements are located.

I wondered whether a storm with the same track as the 1821 and 1938 hurricanes would affect these locations. The Swiss Re report reconstructed the storm track and wind field for the 1821 hurricane:

The New York City National Weather Service has a web page describing the Great Hurricane of 1938 that includes a wind field map developed by Dr. Isaac Ginis at the University of Rhode Island:

The answer to my question whether a storm similar to the 1821 and 1938 hurricanes would affect the five offshore wind projects is unequivocally yes.  The Forward of the Swiss Re report makes an important point regarding this threat:

It’s been two years since Hurricane Sandy reminded us that the Northeast United States is vulnerable to hurricanes, and for those still recovering from the storm’s aftermath, the trauma of the hurricane continues. Yet despite Sandy being the third largest hurricane loss on record, the majority of New York, New Jersey, and other Northeast residents did not experience how devastating a hurricane could be. For many of us Sandy is little more than a distant memory of a temporary inconvenience.

In the months following Sandy many experts told us that Hurricane Sandy was a very unusual event. It was unusual in terms of its westward storm track, its interaction with the jet stream, the high tide, and how it intermingled with the continental weather systems. They tell us that the probability of a similar storm taking the same perpendicular track as Sandy is at least one in 500 years.

Once in 500 years is misleading. Although Sandy was unusual in a meteorological sense, it wasn’t a particularly intense storm and lacked the widespread high winds and rainfall that can occur with a Northeast hurricane. It’s highly unlikely that we will see a hurricane with the same characteristics as Sandy. However it’s very likely (1 in 50 years) that we will see, and in fact, have seen, other hurricanes in the Northeast that would have caused economic damages equal to or greater than those caused by Hurricane Sandy if they were to occur today. Sandy is a harsh reminder of what greater event potentially awaits us.

Conclusion

The official story is that renewable energy like offshore wind will be more diversified and resilient than the current electrical system. Different types of fuels at existing power plants truly provide a redundant and flexible power system that can provide reliable electricity when needed.  In contrast wind and solar power which are utterly dependent upon the vagaries of weather cannot be called flexible and certainly are not dependable without additional energy storage and grid support services that markedly increase the cost.  The claim that wind and solar are less prone to massive outages is absurd given that every night with calm winds causes an outage of both of these generating resources.  

Unfortunately, resiliency in the event of extreme weather is an even bigger problem. There is no question that a hurricane with stronger winds than Sandy will go through the area where New York is developing offshore wind.  The fact that two hurricanes with winds well over 100 mph have passed over New York’s offshore wind development areas should be a major concern.  I worry that New York will invest billions in these resources, get to a point where they are necessary for reliability only to see one storm come through and knock out the resource for an extended period.