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 addresses the Transportation Advisory Panel enabling strategy recommendations.
I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented. 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 regulations, summarized 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.
Transportation 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 100 million metric tons (MMt) of carbon dioxide equivalent (CO2e) and 2018 preliminary draft emissions are 107 MMt. Note that as other sectors decrease their emissions the relative percentage of transportation sector emissions to the total increases.
 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.
There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050. The projected total reductions emission reduction goals for this advisory panel are a 16% reduction from 1990 by 2030 and a reduction of 77% by 2050.
Transportation Advisory Panel Strategies
The meeting minutes will not be available until the June Climate Action Panel meeting. According to the presentation, the advisory panel proposed the following enabling strategies:
- Transition of vehicles/fleets to electric/zero-emission technologies.
- Enhancing the availability, accessibility, reliability and affordability of public transportation.
- Aligning and integrating transportation investments into land use/development to mitigate carbon emissions.
- Implementing market-based strategies to impact travel decisions and finance investments in clean transportation.
The recommendations are available in a slide presentation. I am not going to critique these strategies individually because it would take far too long. Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues.
The Transition to 100% zero-emission light duty vehicle sales enabling strategy exemplifies what I think is a major disconnect between the transportation planners and the public. I have attended stakeholder meetings for the Transportation Climate Initiative and listened to the true believers explain that there are so many advantages to electric vehicles that if only the public understood everyone would buy into the technology. However, even this strategy recognizes that “Lack of consumer awareness/interest and consumer concerns about technology & charging/fueling” are barriers to success. The ultimate problem with all of the clean energy technologies is that they all only work most of the time. Most of the time a light-duty electric vehicle might work well for me but several times a year I want to haul a big load in my mini-van several hundred miles and range anxiety is a very real concern. My wife’s car is a regular sedan and again most of the time an electric vehicle would work. However, several times a year we drive down to see my son’s family in Brooklyn. The joke is that is takes four hours to get to the George Washington Bridge, another hour to get to Brooklyn and then an hour to park. I do not foresee any time in the future when that trip will be a realistic option with an electric vehicle. I am sure my personal reservations are similar to most people.
Another reservation mentioned in enabling solution is the “Potentially high cost of supporting charging and fueling infrastructure and Zero Emission Vehicle incentives”. Under cost and funding considerations the strategy notes that “Nearly $1 billion in ratepayer and NYPA funding is already committed for EV charging station installations”. I believe that this $1 billion charge to the ratepayer will be buried in bills so there is no direct accountability to this initiative. While I do see electric charging stations around town, I don’t see a lot of them so this funding is no where near what is necessary to provide charging support in public spaces. Moreover, what about the need to charge at home? While the cost for a simple charger is not that great, a faster charger, which I understand is needed to completely charge a depleted battery, is much more expensive.
The final reservation mentioned is that “Unmanaged charging could have significant costs for electric grid operators/ratepayers”. I live in a development that is on the order of 60 years old. It is very rare that there is a house with only one car and there are many homes with adult children living at home that have more. The personal charging infrastructure is going to be a challenge and that much additional load, and don’t forget they want to electrify home heating too, is probably going to require upgrades to the local distribution system. Again, it may work most of the time but when homeowners really need heat are they going to be able to charge their cars too. Finally, the challenge for charging in a housing subdivision is small relative to charging at apartment buildings and other public spaces and that challenge is small relative to providing chargers for people who have to park on the street in cities.
Ronald Stein recently described California warning signs that agree with some of my anecdotes about electric vehicles and highlight other issues:
- The highly educated and financially well off are currently the primary owners of EV’s.
- EV usage being slightly more than 5000 miles a year is a reflection that the EV is a second vehicle and not the family workhorse vehicle.
- The growing percentage of EV owners that are switching back to gasoline cars, is a message that may deflate EV growth projections.
- The larger and heavier gasoline driven SUVs are currently half of all the new car sales.
One of the key components of these plans is anticipated benefits and impacts to disadvantaged communities. For this mitigation strategy the strategy states:
Enhanced incentives for residents of disadvantaged communities are essential for faster ZEV adoption in disadvantaged communities. Incentives that support used ZEV purchases and EV charging at multifamily buildings can be especially effective at increasing ZEV adoption among underserved populations. Local ownership of EV charging stations and workforce development can support economic opportunities in disadvantaged communities.
I think this is another major disconnect between the members of the advisory panel and reality. Many people in disadvantaged communities cannot afford a new vehicle whatever the incentive. Another electric vehicle concern is the market for used cars relative to battery life. The common perception is that replacing the batteries is a major cost not necessary in a conventional used car. It is not clear how the CLCPA can subsidize new vehicle purchases, used vehicle purchases, and public EV charging support in disadvantaged communities and keep the option of personal mobility available.
There is another enabling mitigation strategy: “Transition to zero emission medium/heavy duty vehicles and non-road vehicles”. The summary claims that the ease of implementation and cost is similar for this sector has the same emissions impact, ease of implementation, and cost as for light-duty vehicles. I disagree with all three comparisons. Diesel vehicle emissions are a primary cause of inhalable particulates in urban areas so eliminating those emissions has more value than a comparison only to GHG emissions which could be the same for light-duty vehicles and this sector. Similar ease of implementation is absurd. There are electric cars that are at least arguably competitive to regular cars. There isn’t any similar level of technological availability for heavy duty trucks and given the limits of battery technology it is a very heavy lift to assume that a zero-emission technology will ever enable the same use of trucks as today. If you don’t have the technology, how can you possibly project costs? Furthermore, charging a fleet of medium or heavy-duty trucks is going to require a lot of energy at freight terminals and service centers so upgrades to the distribution system, likely including new substations, will be required at a significant cost.
From a personal standpoint the transportation initiative does not mention recreational vehicles. Since my retirement I have traveled over 60,000 miles, visited 40 states and been on the road about 20% of the time with a motor coach. I don’t see how that life-style will be possible in the net-zero world. Anyone who has driven I-95 in the winter has noticed a steady stream of campers headed south. Based on my experience many travel over 300 miles per day which I expect to be the limit of the electronic technology. The batteries necessary for that operating range will undoubtedly reduce storage space which will not be popular. Finally, there are very few campgrounds that have any apparent surplus of electricity. Upgrading campgrounds is another hidden cost.
Improvements to public transportation are a big component of the enabling strategies:
Identify implementable strategies to significantly enhance the availability; accessibility; reliability; and affordability of public transportation services with an emphasis on unserved/underserved communities.
A major problem with mass transit in all but the largest cities is that it is inconvenient. Outside of New York City I believe that using public transit basically doubles travel time. In the early 1900’s there was an extensive interurban trolley system in Upstate New York that basically met the proposed vision for the future. In Syracuse you could go to Utica, Rochester, and Oswego on those systems. They all failed by the 1930’s because even though folks had to drive on dirt roads with little heat in the winter and no cooling in the summer it was more convenient than taking a ride on a trolley. To dream that people will willingly give up that convenience when many have remote car starters is magical thinking.
The enabling strategy becomes even more detached from reality when they include plans for transit-oriented development which is “the creation of compact, walkable, pedestrian-oriented, mixed-use communities centered around high-quality train systems”. There may be some locations outside of New York City where this might work because high quality train, or rapid transit buses for that matter, can haul commuters to the city where there is a dense network of transit routes available that can take people to a variety of jobs. Upstate cities have no similar concentration of transit-friendly jobs in the center cities so how can anyone expect that people would want to live in a community that actively discourages ownership and use of a personal vehicle that does not have easy access to work.
Ultimately, the goal of the public transit strategies is to reduce the need for personal automobiles. There is a fundamental problem though because population density puts limits on transit system success. If there aren’t enough people living along the transit service then revenues will be insufficient to make them viable. In order to address there is a strategy to expand biking, walking, carpooling, ride-sharing, and micro-transit opportunities and another for automated vehicles for smart mobility. The idea is that if there were a convenient option people would be willing to consider transferring from, for example, an express bus to an automated vehicle for locations too far to walk from the main stop. Transferring between subway lines in New York City is only viable because of the frequency of service. Scaling that concept down to upstate cities with less dense ridership is unlikely to succeed.
Of course, the transit systems will have to be converted to zero-emission fleets too. According to a friend in the business new diesel buses cost ~$500,00, a new compressed natural gas bus costs ~$550,000, and a new electric bus costs ~$1,000,000. That does not include the cost of infrastructure which, especially for bus electrification, is a significant transition cost. Furthermore, the enabling initiative suggests making public transit “more attractive, accessible and user-friendly” but adding options to provide those services can run another $60,000 per bus.
Most of the other advisory panels avoided much detail on funding mechanisms and just suggested that some form of government funding would be necessary. This panel did address potential mechanisms but did not estimate costs. The strategy for “financing and market-based policies” includes nine potential policies: facilitating private financing, cap & invest or carbon pricing, clean fuel standards, electrification freebates, curb pricing, congestion/variable/demand parking pricing, mileage-based user fees, tax increment financing/special assessment districts, and registration fees. Note that this spring the Climate and Community Investment Act was proposed to, in large part, provide a funding mechanism for the CLCPA. However, when asked about the potential to increase gasoline prices by 55 cents per gallon, the Governor Cuomo said: “You can’t do it that way. I understand the concept, and the concept, it makes sense. But how does it work? What’s the economic impact? You’d have to ask all those questions.” I look forward to the scoping plan’s assessment of CLCPA costs because I don’t believe there is any way that the costs will be as low as 55 cents per gallon for the transportation enabling strategies. When combined with all the other advisory panel strategies, costs will be extraordinary.
I have three concerns with the transportation enabling strategies: feasibility, affordability and reliability.
According to preliminary data, the transportation sector was the second largest source of emissions in 2018. The projected total emission reduction goals for this advisory panel are a 16% reduction from 1990 by 2030 compared to the CLCPA target of 40% and a reduction of 77% by 2050 compared to the goal of 85%. I can only conclude that the failure to meet these goals means that the CLCPA targets are not feasible particularly because I suspect that the enabling initiatives over-estimate emission reduction effectiveness.
As noted above the costs were not included in the enabling strategies but considering the scope, they are sure to be large. On May 24 and 25 2021 a European summit met to discuss their net-zero plans and observers expect that that they had to concede that these plans will be very expensive. I expect the same affordability issues in New York.
The ultimate problem is that the proposed “solutions” only work most of the time and society expects energy options that work all the time. One of the initiatives proposes to “Expand the availability of low carbon transportation modes (biking, walking, carpooling, ride-sharing, micro-transit) statewide” which is an example of the personal impacts of “it will work most of the time” thinking. Biking and walking several months of the year is not only inconvenient but also dangerous whenever roads are covered with snow and ice. Electric vehicles will work when the power is available but what happens when there is an ice storm blackout? No heat and no way out are a dangerous combination.