On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done. On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law may suggest will be done. This post is an overview summary of that report concentrating on the presentation summary of the draft findings.
I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker. Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels I am convinced that the costs in New York will be enormous and my analyses have supported that concern. 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.
The Pathways to Deep Decarbonization in New York State Presentation can be viewed on the video of the webinar. The Pathways to Deep Decarbonization in New York State – Final Report itself and two appendices: Appendix A: Methods and Data and Appendix B: Literature Review of Economy-Wide Deep Decarbonization and Highly Renewable Energy Systems were included in the meeting materials.
I think the best way to summarize the report is to simply reproduce the conclusions in section 5 of the presentation and then discuss the points made:
This report presents E3’s initial strategic analysis to inform New York’s future decisions for meeting GHG goals under the CLCPA. Based on our detailed assessment of pathways to deep decarbonization in New York State, we find the following:
- Deep decarbonization in New York is feasible using existing technologies. This reinforces the conclusion of many other studies. All needed technologies currently exist and can safely be assumed to realize incremental improvements resulting from significant deployment. A high level of innovation will make the transition easier, but the transition is already technically feasible.
- There are different pathways to a carbon neutral future. A 30-year transition demands action now across all sectors of the State’s economy but affords some optionality. All scenarios that achieve carbon neutrality show significant progress across the “four pillars” of decarbonization: energy efficiency and conservation, decarbonizing the electricity supply, switching to low-carbon fuels, and negative emissions.
- Continued research, development, and demonstration is key to advancing a full portfolio of options. Some studies and scenarios rely on technologies that have only been demonstrated in a limited number of applications and require further progress before commercial readiness.
- Consumer decision-making drives the pace of decarbonization, particularly in buildings and on-road transportation. By 2030, key technologies like plug-in electric vehicles, electric heat pump heating and hot water systems, and other electric appliances in the home (e.g., stoves, clothes dryers) will need to become normalized, meeting or exceeding half of new sales with accelerating adoption through midcentury.
- Flexibility along multiple dimensions is key to maintaining reliability and reducing cost of a 100% zero-emission electricity system. In the electricity sector, several forms of flexibility are necessary for balancing a 100% zero-emissions grid. Flexible end-use loads and battery storage can provide sufficient short-term (intraday) flexibility to balance high levels of variable renewable output. The more difficult challenge is during winter periods with high heating loads and very low renewable energy production, which can occur over several days. This long-duration (interday) challenge can be solved through a combination of large-scale hydro resources, renewable natural gas (RNG) or synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power.
- Managed electrification can help mitigate the risk of very high winter peaks. In addition to efficiency and end-use load flexibility, investments in a balanced mix of electric heating system configurations and investment in research and development to continue the improvement in cold climate heat pump performance can help to mitigate potential risk associated with unintended consequences of unmanaged electrification.
The New York State Energy Research and Development Authority (NYSERDA) hired E3 to conduct the strategic analysis of New York’s decarbonization opportunities. It is strategic in the sense that they worked backwards from the targets and put together measures that would be needed to reach them.
The report notes that:
The CLCPA requires additional reporting of emissions associated with “extraction and transmission of fossil fuels imported into the state,” as well as the adoption of a 20-year global warming potential, a metric that emphasizes the near-term climate impacts of short-lived climate pollutants such as methane. The calculation of a 1990 baseline that includes these new requirements is currently underway.
This report is based on the existing inventory of 1990 emission that uses the 100-year global warming potential commonly used elsewhere. New York’s irrational war on natural gas includes the 20-year global warming potential in order to maximize the effect of natural gas and methane reductions relative to the targets.
The report claims that “Deep decarbonization in New York is feasible using existing technologies”. Their definition of feasibility apparently means somewhere, someplace, someone has successfully applied the technology. Using their criteria I am surprised they did not include nuclear fusion as a technology. After all fusion plasma has been maintained in a stable state for 70 seconds. Using their rosy projections surely this technology will be available for use in 2050.
Reality is only two paragraphs away: “Continued research, development, and demonstration is key to advancing a full portfolio of options. Some studies and scenarios rely on technologies that have only been demonstrated in a limited number of applications and require further progress before commercial readiness”. When the report claims “All needed technologies currently exist and can safely be assumed to realize incremental improvements resulting from significant deployment. A high level of innovation will make the transition easier, but the transition is already technically feasible”, there is a serious effort to stretch feasibility that most people would accept in this context.
I agree with the report’s conclusion that winter periods with high heating loads and very low renewable energy production is going to be a big challenge. The report claims that this can be solved through “a combination of large-scale hydro resources, renewable natural gas (RNG) or synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power”. I do not agree that RNG and synthetic fuels such as hydrogen are necessarily feasible at the scale necessary to keep the lights on when New Yorkers need the power the most once heating and transportation are electrified.
One final feasibility comment. The report notes that “investment in research and development to continue the improvement in cold climate heat pump performance can help to mitigate potential risk associated with unintended consequences of unmanaged electrification”. This refers to the very real problem that air source heat pumps become much less efficient when temperatures go below 20 deg F. Their study assumes “that a balanced portfolio of electric space heating systems – including cold climate air-source heat pumps with and without onsite combustion backup as well as ground-source heat pumps – would be deployed”. Heat pumps are very efficient because they move heat/energy rather than produce it when they provide heating. Ground-source heat pumps always have energy to move. The problem that air-source heat pumps have is there isn’t enough energy to provide the heat needed when temperatures are cold. Absent a repeal of the laws of thermodynamics, it is not clear what additional R&D is going to be able to do for air-source heat pump performance when there is no energy to convert.
The pathways proposed to achieve carbon neutrality show “significant progress across the “four pillars” of decarbonization: energy efficiency and conservation, decarbonizing the electricity supply, switching to low-carbon fuels, and negative emissions”. I address each pillar below.
While I believe that energy efficiency and conservation are the most effective tools for emission reductions, I also believe that there are limits to what can be practically achieved. New York is already among the most energy efficient states in the country so future progress will likely be difficult.
My primary concern is decarbonizing the electricity supply because all the analyses that show the availability of renewable resources have to date failed to consider small-scale solar variability. During winter periods with high heating loads the report notes that very low renewable energy production over several days could be expected but their analysis did not use the NY Mesonet data available from every county to refine their projection. Given the significant effect that the Great Lakes have on precipitation and cloudiness across much of Upstate New York that is a serious deficiency in their solar resources projections.
The report explains that “Advanced low-carbon liquid and gaseous fuels are key to decarbonizing sectors where electrification is challenging, such as freight transportation, aviation, marine, and high-temperature industrial applications”. Their fuels analysis includes hydrogen produced from electricity produced by renewables. The thought is that when all the renewables are built there will be many times when we don’t need the electricity so instead of curtailing production, they will use it to create hydrogen that can be stored for use when the wind doesn’t blow at night. This may or may not be feasible in my mind and because no jurisdiction has employed this technology in a similar application I tend to think it may not be feasible.
There is another little tidbit related to bio-fuels that needs to be recognized. The report notes that “the pathways modeled in our analysis can achieve deep decarbonization using available in-state biomass feedstocks that are assumed to be converted to advanced renewable natural gas and renewable petroleum products. We also assume that a small amount of wood consumption remains in 2050 to serve a variety of needs, including residential wood usage in the North Country”. In this instance does North refer to anything north of New York City? More importantly, their pathways “retain approximately 16 TBtu of wood consumption statewide in 2050; Compare to 2016 residential wood usage in the North Country of about 3 TBtu”. I personally don’t think that increasing residential wood usage five times over current use is a “small” amount.
Negative emissions strategies including both natural and working lands and negative emissions technologies make up the fourth pillar. The report defines “negative emissions” as “the removal of CO2 directly from the atmosphere or from the emission stream of renewable biogenic feedstock combustion (where the carbon emitted was first captured from the atmosphere in the photosynthesis process, resulting in a net decrease in atmospheric carbon)”. The report states that “With nearly 20 million acres of forest, New York State’s natural and working lands sink is projected to sequester between 23 to 33 MMT CO2e”. The obvious question that comes up is that given a five-fold increase in residential wood usage isn’t that going to cut down the sequestration potential?
There are two aspects of this that most New Yorkers do not realize are coming soon to their lives: customer choice and customer energy use. The report explains that “Consumer decision-making drives the pace of decarbonization, particularly in buildings and on-road transportation. By 2030, key technologies like plug-in electric vehicles, electric heat pump heating and hot water systems, and other electric appliances in the home (e.g., stoves, clothes dryers) will need to become normalized, meeting or exceeding half of new sales with accelerating adoption through midcentury.” What that translates to is you will only have a fifty-fifty chance to buy fossil-fueled appliances or cars in ten years even if the performance that the report admits has to improve has not reached the level needed for your application. That does not even begin to consider personal preferences for the capability and reliability of on-site fossil fuels. I have yet to see an explanation of what will happen when there is an ice storm after everything is electrified. I value the capability to have heat even when the power is down as a very nice benefit of natural gas.
In order to reduce the amount of energy and storage needed it is necessary to shave the peak load as much as possible. The report notes that “Flexible end-use loads and battery storage can provide sufficient short-term (intraday) flexibility to balance high levels of variable renewable output”. I believe that flexible end-use load translates to eventual remote control of customer power use. The theory is that smart meters can provide enough detailed information that they can be used to charge customers higher rates when the load gets high providing a signal for customers to shift usage. One of the unintended consequences of heating electrification and the expected change to the annual peak load moving to the winter is that shifting heating load is much less of an option. In the early morning when temperatures are coldest and people warm up their houses what load can be shifted? If it is a choice between a blackout or a brownout across the system or limiting power use by individual customers it is not a stretch to think that smart meters will limit usage.
Given the enormity of the challenge to meet the Climate Act targets and the composition of the Climate Action Council membership I suppose it was too much to expect unbiased, fact-based implementation pathways. However, the exaggerated feasibility claims and internal inconsistencies of this document worry me. The first key takeaway “deep decarbonization is feasible using existing technologies” is only true with a liberal definition of feasible and existing technologies.
The biggest problem is going to be the winter peak when it is likely that there will be insufficient renewable energy available for multiple days. E3 offered a combination of five options to meet the challenge: large-scale hydro resources, renewable natural gas, synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power. Note that New York needs additional resources to meet this new challenge and while large-scale hydro resources and nuclear power are possible sources to think that they can be developed in New York is very unlikely. Renewable natural gas from anerobic digesters is a proven technology but is it feasible to collect and store enough to meet the winter peak demand. Synthetic fuel production hasn’t even proven itself as a technology that can be deployed at scale much less meet the collection and storage requirements. CCS is another technology that has “only been demonstrated in a limited number of applications and requires further progress before commercial readiness” but even if the technology works the bigger issue is where are you going to put the collected CO2. In order to safely store CO2, you need a particular geological formation and that may mean that this technology cannot be used where it is needed in New York.
The conclusion that “Deep decarbonization in New York is feasible using existing technologies” coupled with the conclusion “Continued research, development, and demonstration is key to advancing a full portfolio of options” is a glaring inconsistency. Two pathways include a “small” amount of wood consumption in 2050 but it turns out that level is five times the existing level. Furthermore, that consumption is at odds with the negative emissions needed from forest sequestration.
Based on this, I fear that the scoping plan will not be scrutinized in sufficient detail to maintain reliability and affordability. The Climate Action Council will merely pay lip service to their responsibilities to the citizens of the State and the result will be disastrously high energy costs and impacts to reliability.
I believe that it is only a matter of time until the Iron Law of Climate, “while people are often willing to pay some price for achieving climate objectives, that willingness has its limits” catches up to the Climate Act. It is not only the enormous costs but it is also the changes in lifestyles that will precipitate public demand to repeal the law. I believe that is in the best interest of the State to get this over as quickly as possible so I think the time has come to accelerate implementation of New York’s Climate Leadership and Community Protection Act. In order to meet the requirement for an 85% emission reduction economy-wide by 2050 we should immediately stop all investments in fossil fuel infrastructure. New Yorkers will have to purchase electric vehicles and stop purchasing gas and oil furnaces, gas stoves and gas hot water systems at some point to meet these goals. According to the advocates the technology is feasible, available, affordable, and necessary. Let’s test the willingness of the citizens of the State to meet these goals now and get this over sooner rather than later.
 I consider New York’s policies to ban hydraulic fracturing and not permit new natural gas infrastructure irrational because the lower prices that resulted from that technology have been responsible for the majority of the emission reductions observed in New York’s electric sector since 2010.