Energy-Intensive and Trade-Exposed Industries Advisory Panel Enabling Strategies Submitted to Climate Action Council

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post briefly addresses the Energy-Intensive and Trade-Exposed Industries (EITE) Advisory Panel enabling strategy recommendations more for completeness than anything else.  Emissions are small, choices are few, and there is not much to see here.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.

Energy-Intensive and Trade-Exposed Industries Advisory Panel Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050. 

The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph 1990 emissions are 33 million metric tons (MMt) of carbon dioxide equivalent[1] (CO2e) and 2018 preliminary draft emissions are 16 MMt.  Note the breakdown of the emissions by process, imported fossil fuels, and fuel combustions with the explanation at the bottom of the graph.  The inclusion of imported fossil fuels makes comparison of these data with other emissions estimates impossible. 

The projections for 2030 and 2050 show reductions that exceed the CLCPA targets.  In 2030 the projected emissions are 55% less than 1990 as opposed to a target of 40% and the 2050 emissions are 91% compared to the target of 85%.  In a previous post I noted that industrial energy use was 47% reduced and that reflected the loss of New York industry rather than any improvement in GHG emissions efficiency in operations. 

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

EITE Strategies

According to the meeting minutes, the advisory panel proposed the following enabling strategies:

  • Industrial sectors within the Advisory Panel scope total a small share (less than 4%) of the State emissions;
  • The “heterogeneous” nature of industry may result in a higher cost per ton of emissions reduced;
  • Energy-Intensive and Trade-Exposed industries are likely to represent a high share of industrial sector emissions. These industries are highly sensitive to increased energy costs, that often cannot be passed along, which could cause them to leave the State, resulting in leakage;
  • Emissions will decline with decarbonization of the Power Generation sector; near-term opportunities will likely focus on energy efficiency, while most deep carbonization opportunities will occur further into the future as new technologies become more viable.

A brief translation of these strategies.  This is a small and declining sector.  The “heterogeneous” nature of industry refers to the fact that there are many different sources so economy of scale is not going to reduce costs.  Clearly the unilateral transition off fossil fuels will increase relative energy costs and industries will have to leave to survive.  The final bullet basically says this sector needs a magical solution to produce emission reductions and remain viable within the state.

The recommendations are available in a slide presentation.  I am not going to critique these strategies individually there is so little to address.

The summary slide describing the strategies states:

Mitigation strategies: Directly reduce emissions and contribute to the achievement of the GHG emission limits or carbon sequestration needed to achieve net zero, where applicable:

1.Provide financial incentives and technical assistance for the decarbonization of EITE sectors

2.Create procurement incentives for business to capitalize on low-carbon economic opportunities

Enabling initiatives: No direct emissions benefit, but enable or magnify the mitigation strategies, enhance climate justice, or just transition. (Examples: outreach, education, and awareness; capacity building; workforce development; and research and development.)

3.Identify and support technological innovation to enable deep industrial decarbonization

4.Workforce development training to support Energy-Intensive and Trade Exposed (EITE) industries

5.Increase the available data on industrial GHG emissions to help prioritize efforts and monitor progress

6.Provide economic incentives to grow the green economy

In brief, the mitigation strategies consist of subsidies to provide GHG reductions and incentives, aka further subsidies, for companies to join the grifters already lined up to save the world as long as someone else is paying for it.  If there is an existential climate crisis why are there any initiatives with no emission reduction benefits?


This sector is a relatively small actor relative to total New York GHG emissions.  Reductions in the sector have exceeded the CLCPA targets but only because the sector has become much smaller.

It seems pretty obvious that this advisory panel was a political ploy to placate the industrial sector.  Unfortunately, there is not much that can be done to reduce emissions significantly or prevent the remaining industries from fleeing the state out of necessity.

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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