New York State Carbon Pricing

The report “Pricing Carbon into NYISO’s Wholesale Energy Market to Support New York’s Decarbonization Goals” was prepared by the Brattle Group for the New York Independent System Operator (NYISO) and the New York State Department of Public Service (DPS). According to the Brattle Group the report finds “that adding a carbon charge into the wholesale energy market could improve the state’s ability to meet its decarbonization goals cost-effectively. The study reveals that refunding collected carbon revenues back to customers results in minimal impact on customer electricity costs compared to current policies.” This is a post on the basis of the study only because much of the analysis is beyond my capability to review.

Disclaimer: I am writing posts on New York State (NYS) energy policy because I am concerned that this whole thing is going to end as an expensive boondoggle and drive electricity prices in 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.


This report is a useful example of New York State energy policy in general. It universally refers to New York State policy when in reality it is implementation policy for Executive Orders from multiple Governors. The fact is that the legislature has never voted on any aspect of the policy, the DPS has been loaded with Cuomo appointees so it is not clear whether it will rate the interests of NYS ratepayers over the Governor’s agenda, and NYISO has also been cowed into sponsoring a report that is no more than a politically correct roadmap for an untried policy option. Needless to say I am disappointed with the response to date within New York.

The biggest problem in New York is that no one has provided an analysis of the total costs to meet the electric sector’s part of New York’s State Energy Plan (SEP) that calls for reducing state economy-wide greenhouse gas emissions 40% by 2030 and 80% by 2050, relative to 1990 levels and the call for generating 50% of electricity from renewable sources by 2030 to help meet that goal. This report illustrates the need for an overall summary. In particular it notes that “although average wholesale energy prices would increase, about 50% of the cost could be offset by returning carbon revenues to customers; another 18% would be offset by reduced prices for RECs and ZECs in the presence of higher wholesale energy prices, and increased TCC revenues; finally, another 23% would be offset by dynamic effects on investment signals.” This clearly shows that the component costs cannot be estimated individually and then combined for a total. Instead someone has to consider the interactions between the components to get a total price.

Ultimately, however, the biggest issue in the study is its use of the Social Cost of Carbon (SCC) as the basis for the report.   The report notes that “The Brattle Group was retained by the NYISO to evaluate conceptual market design options for integrating the social cost of carbon, a widely recognized regulatory standard, into competitive wholesale energy markets administered by the NYISO.” I am absolutely sure that the vast majority of New Yorkers have no clue what the SCC is, much less the shortcomings of its use in general, and the political manipulation of its numbers by the Obama administration in particular.

The SCC is the present day value of projected future net damages from emitting a ton of CO2 today. In order to estimate the impact of today’s emissions it is necessary to estimate total CO2 emissions, model the purported impacts of those emissions and then assess the global economic damage from those impacts. The projected global economic damage is then discounted to present value. Finally, part of the future damage is allocated to present day emissions on a per ton basis.

The ultimate question is whether using the SCC for NYS CO2 emissions reductions benefits is reasonable. Jonathan Lesser has evaluated Cuomo’s Clean Energy Standard and concludes that “the appropriate value for these CO2 emissions reductions is effectively zero. The reason for this is not that climate change is a hoax or that CO2 emissions do not affect the climate. The reason is simple economics: the marginal benefit of reduced CO2 emissions caused by the CES cannot be valued at the SCC because the latter reflects an average value of reducing many billions of tons of CO2. Moreover, because climate change is, by definition, a global phenomenon, the benefits to New Yorkers themselves from reduced CO2 emissions will necessarily approach zero, as virtually all the putative benefits will be captured outside New York.”

Someday I will prepare a more detailed post on the SCC but I also want to highlight some of the short-comings of the current value of the SCC used in this report. Consider that the future net damages includes impacts out 300 years. It is an act of extreme hubris to claim that any projection of how the world will operate in 100 years much less 300 years should be used to guide current actions simply because no one could have imagined the technology available in today’s society in 1917. Another key component of the SCC is that it considers global impacts not just NYS impacts. In other words we are being asked to pay today for some estimated future impact elsewhere. Were it not for the fact that there are plenty of global problems that could be funded today with demonstrable effects at a fraction of these proposed costs then I could accept the premise of this noble gesture. Ultimately when the State claims benefits exceed costs buried in there somewhere are SCC benefits that are not in anyone’s wildest imagination a direct connection to today’s NY costs.

I earlier noted political manipulation by the Obama Administration. Two examples prove my point. One of the key assumptions in the estimate of future net damages is just how much the effect CO2 emissions have on future temperature. The Obama SCC did not use the latest (and lower) value available at the time of this factor in their calculations so their values are biased high. Since the publication of the latest IPCC report other estimates of the sensitivity of temperature to CO2 based on observations and not modeling have reported even lower values.

An even more egregious example of manipulation is documented by the Institute of Energy Research. In order to estimate future economic impacts the discount rate is used to estimate how much money invested today would be worth in the future so that we can link today’s costs to the future. As shown in the IER post “the Office of Management and Budget (OMB) guidelines that all cost/benefit analyses are to be scored using both a 3% and a 7% discount rate. Despite this clear directive, the Obama Administration’s task force on the Social Cost of Carbon did not bother running the computer simulations with this setting.” Why not you may ask? Cynics like me suspect it is because that there are net benefits of CO2 emissions through the year 2030 using that discount rate.


This report exemplifies problems with current New York State energy policy. The legislature and public have not had a chance to comment on the goals espoused by the Executive Orders that are driving this policy. Even if agree that those goals should be pursued, do we really want to go there without knowing the price? The report shows that a comprehensive analysis of costs is necessary in order to determine the total costs. What is the benefit to New York? The use of the SCC as a primary driver of the benefits is not well understood by the public and upon closer examination its use in this context is inappropriate. Ultimately, it is fair to ask why the State is pushing ahead with these programs without answering these fundamental questions.

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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