Comments on CLCPA Transportation Advisory Panel Implementation Strategies

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  In particular, this post is my reaction to the Transportation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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.


I have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  In brief, each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

General Comments

My impression of these transportation strategies is that there is a dis-connect between their goals and reality.  Reality is that there are on the order of 9.4 million vehicles registered in New York State with 1.9 million in New York City.  According to the ChargeNY website on 12/2/2020 there were 58,856 electric vehicles or 0.6% of the total and more than half of those are plug in hybrid electric vehicles and supporting their future use is just more fossil fuel infrastructure so they will have to be banned.  One hundred years ago there was a choice between electrified public transit and personal automobiles and by 1920 the interurban and trolley network that covered much of the state was already in decline because of the convenience of personal transport.  I find it hard to imagine that the majority of people would be willing to make the sacrifice of giving up their car.

Strategy Comments

The first strategy “Transportation Electrification” proposes to adopt regulatory approaches and supporting policies to increase the sale of medium and heavy-duty zero emission vehicles to 30% by 2030 and the sale of light-duty zero emission vehicles to 100% by 2035, and require greater use of zero emission non-road vehicles.  This strategy is mostly wishful thinking.  The fact is that zero emission vehicles are not available with all the capabilities as currently available vehicles.  For example, the minivan offers enough room for all the kids and baggage can be used for hauling pretty big items.  It can be used to go 250 miles in any weather without the need for a long stop to re-charge.  Without an equivalent vehicle Christmas trips to the grandparents are a much more complicated endeavor.  Another example of a transportation element not addressed yet is recreational vehicles.  I own a motor coach, use it often and my experience suggests that an electrification mandate will kill the industry in NY.

The rationale for this strategy claims that zero emission vehicles save consumers money spent on fuels and maintenance neglects total costs.  Many people cannot afford new vehicles and there is a very limited used EV market.  Many people worry about the cost of replacement batteries for used cars.  The head of Toyota raised the issues of the energy loss inside the electric vehicle value chain and the depreciated costs of developing a massive electric vehicle support infrastructure for ten million vehicles.  I would add that the hidden environmental costs of the rare earth elements and other metals needed for electrification should also be addressed.  The car battery in each automobile weighs 1,000 pounds and fabrication requires digging up, moving and processing 250 tons of earth somewhere else – this CLCPA implementation mandate is going to cause massive environmental impact leakage.

The Clean Fuels strategy proposes to “Adopt a market-based approach and supporting policies to increase the availability and affordability of clean transportation fuels (renewable biofuels, green hydrogen, electricity) in New York”.  This strategy should address the environmental impacts of biofuels.    Hydrogen is nice in theory but because it has to be compressed or liquified for storage is impractical in reality.  Electrification has serious border issues if New York or even the Transportation Climate Initiative region continue to go down this path without the rest of continent following suit.

There are two components to the Public Transportation strategy:

      • Identify policies and programs that would double the availability/accessibility of upstate and downstate suburban public transportation services statewide by 2035 and
      • Identify policies and programs to support system reliability/network expansion projects identified by MTA in their twenty-year needs study.

As noted previously, there used to be an extensive public transit system in the state that died out where public needs could not be met.  The strategy claims there is “unparalleled support for public transportation based on NY being the least energy per capita for transportation purposes” overlooks the fact that is almost entirely due to New York City.  Even if you manage to double availability and accessibility in New York City that is an easy task relative to the rest of the state.  Current land use patterns preclude substantial increases in public transit services outside of metropolitan areas.  Consider that, for example, using public transit from the New York State Energy Research & Development Authority office building to the State Capitol is a 9.7 mile, 14 minute drive or a 46 minute bus ride that includes a one mile walk.  Of course, that does not include waiting time for the bus.  Rather than a vague plan with aspirational goals the strategy clearly needs to be in sufficient detail to explain what would be required to make this actually work.

The final strategy, Smart Growth and Transportation System Efficiency, also has two components:

      • Transportation-Oriented Development—Align roadway, residential and commercial development to be proximate and accessible to public transportation and consider holistic GHG emissions in smart growth developments;
      • Low-and Zero-Carbon Transportation Modes—Expand access to low-or zero-carbon transportation modes (biking, walking, carpooling) for first mile/last mile connections to transit and destinations.

While there certainly are areas where transit-oriented development can be done, to think it has widespread applicability outside the New York City metropolitan area is completely wishful thinking.  Advocates for this just have to admit that current land use patterns make this strategy useless.  The transportation modes component is another great theory proposed by someone who would not have to deal with impracticalities for anyone in rural areas and most suburban areas.  It boils down to the reality that anyone who has a remote car starter to deal with the inconvenience of a cold car is not going to use public transit in the winter.


I think that upon closer examination all of these strategies have flaws that make them unacceptable for the vast majority of people outside the echo chamber of transportation-related climate solutions ideology.  The only way these strategies can get started much less implemented is if the public does not catch on.  Experience shows that when the effects of these policies on transportation costs and personal choices become known to the general public that a backlash will occur.

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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