Climate Leadership & Community Protection Act Climate Justice Working Group Presentation 28 June 2021

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. I have commented on the advisory panel implementation recommendations presented to the Climate Action Council this year.  This post describes the first Climate Justice Working Group presentation to the Climate Action Council.  Their presentation provided an overview of their expectations and specific comments on two of the advisory panel recommendations.  There is a recording available of the meeting here.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets 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 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.


Section 75-0111 of the CLCPA mandates that the Department of Environmental Conservation establish a Climate Justice Working Group.  I provided background information on the requirements and the membership in an earlier post.  The post also includes documentation describing the education and affiliation of the members of the working group.

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.

I think there is a controversy regarding the scope of this working group’s charge.  The CLCPA states that each advisory panel is required to coordinate with the climate justice working group while developing their enabling strategies.  There also are requirements that the draft and final scoping plan have to be developed in consultation with the climate justice advisory group.  I interpret that to be a consulting role but it is apparent that this working group believes that they have the responsibility to be the final arbiter whether the advisory panel enabling strategy recommendations adequately address climate justice.  As noted in my previous post, there is little technical expertise on this panel to support that role.  More importantly, their vision excludes any consideration of feasibility or competing interests.

Climate Justice Framework

My words cannot fully capture the tenor and content of the presentation by Elizabeth Yeampierre, the Executive Director of UPROSE.  It would be worth your while to listen to her seven-minute lecture to the Climate Action Council starting at 8:00 in the meeting recording.  I say lecture because my impression was that she believes that the climate justice working group has a mission that is not open to compromise, that the solutions have to come from the communities because they are most impacted, and those solutions have to not only address climate change but also co-pollutants.  Unfortunately, the basis for this climate justice framework is technically flawed and does not recognize that there is no zero-risk way to provide reliable, abundant, and affordable energy.

The rationale for the climate justice framework is that climate change is truly an existential threat.  According to Yeampierre, the next Intergovernmental Panel on Climate Change report is going show that there are thresholds for climate breakdown that will doom humanity because humans cannot evolve or develop new ecosystems to handle drastic climate shifts. However, humans have adapted their ecosystem to live across an incredible range of temperatures.  At the cold end of the spectrum the humans in the remote village of Oymyakon in eastern Siberia have adapted to an ecosystem where the record low temperature is -96 OF degrees below zero Fahrenheit and the record high is 94.3 OF.  The average monthly temperature in January is -51.5 OF and in July is 58.8 OF a range of 110 Fahrenheit degrees.  At the hottest extreme, Mecca, Saudi Arabia has had a record high temperature of 121.6 OF and record low of 51.6 OF.  The average monthly temperature in January is 75 OF and in July is 96 OF.  The 2.4 million residents of Mecca have adapted their ecosystem to live in a city whose annual average temperature is 87.3 OF.  I rate this claim as bogus.

Yeampierre goes on to point out that we need to act now because of the recent heat waves in the Pacific Northwest.  I believe that the definitive take down of that claim has been prepared by University of Washington meteorologist Dr. Cliff Mass.  The weather and climate of that region is his particular specialty and he explains that the “specific ingredients that led to the heatwave include a high-amplitude ridge of high pressure and an approaching low-pressure area that “supercharged” the warming” and showed that “global warming only contributed a small about (1-2F) of the 30-40F heatwave and that proposed global warming amplification mechanisms (e.g., droughts, enhanced ridging/high pressure) cannot explain the severe heat event”.  Again, her rationale for drastic action has no basis in fact.

In my opinion, the following justice lens diagram describes the Green New Deal which not only calls for public policy to address climate change but to also achieve other social goals and resource efficiency.  The diagram shows the plan to move from today’s “extractive” economy to a future “living” economy.  While I could certainly do a post just on this diagram, I will only summarize it below for the context of the Climate Justice Working Group.

On the left side of the diagram is today’s extractive economy where work’s purpose is exploitation.  The worldview is consumerism and colonial mindset.  Resources are to be extracted – “dig, burn, dump”.  Governance is militarism. 

The right side of the diagram describes the living economy where work and cooperation produce ecological and social well-being.  According to this, resources have to be regenerated, the worldview is caring and sacredness, and governance is by “deep” democracy.

The center of the diagram describes the plan to convert to the living economy.  Solutions that are “visionary and oppositional” will stop the bad and build the new.  If we “starve and stop” to “divest from their power” we can “feed and grow” to “invest in our power” through a values filter.  This filter moves capital by shifting economic control to communities, democratizing wealth and the workplace, advancing ecological restoration, driving racial justice and social equity, making most production and consumption locally based and retaining and restoring cultures and traditions.  All this occurs when the rules are changed to “draw down money and power”. 

I really don’t think that the majority of the politicians that voted for the CLCPA considered that the law to mitigate greenhouse gases to address climate change was also a mandate to move to a socialist utopia as described in this diagram.  I am certain that the majority of the voters would not endorse this plan.  The real question is how far is the Cuomo Administration going to go down this path to appease the environmental justice demographic but not alienate the rest of society.

In Yeampierre’s naïve view of the energy sector front line communities must defend lands and rivers from mines, power plants, mega-projects and industrial agriculture by expanding agro-ecology and transformative economies while building community-controlled energy and food systems.  This post is only going to address energy systems which she believes should be dominated by renewables like wind and solar.  The reality is that in order to convert to wind and solar the extractive impact on lands and rivers will be enormous because the rare earth metals required for those technologies require extensive mining.  Because wind and solar are diffuse, vast tracts of land will be blanketed with turbines and panels.  When those turbines and panels reach the end of their useful life they will have to be decommissioned and the materials disposed in landfills.  My point is that when looked at holistically the probable impact of renewable energy on communities will be larger but, for the urban environmental justice activists the impacts will be moved from their communities elsewhere out of sight and out of mind.

The urban environmental justice activists most hypocritical position regards health impacts.  Yeampierre advocates for a zero-risk approach to air pollution.  It is not enough to meet (with the exception of ozone in New York) the National Ambient Air Quality Standards (NAAQS) that have protected the health and welfare in the United States for decades.  The fact that the concentrations of all the air pollutants have dropped dramatically since the Clean Air Act is irrelevant because there still are elevated levels in disadvantaged communities relative to elsewhere even if those levels are less than the air quality standards.  The activists argue that, for example, power plants in urban areas have to be replaced by renewable energy and energy storage based on epidemiological statistics that claim excess health impacts from air pollution amongst other confounding factors.  That position is hypocritical because the extraction of the rare earth metals necessary for energy storage and renewable energy is done almost exclusively overseas where the health and environment protections are much weaker and labor protections nearly non-existent.   As a result, there are real health and welfare impacts directly attributable to their solution as opposed to the statistical artifacts that support their supposed problem.

There also is hypocrisy associated with their description of the extractive economy.  The unfortunate fact is that child labor is involved in the African mining industry.  It is sad and telling about their objectives that the Climate Justice Working Group has not called for New York renewable energy and energy storage facilities to require that their mineral suppliers are certified by the Responsible Mineral Initiative or something similar.

Working Group Observations on Enabling Initiatives

The working group summarized their observations and general impressions “mainly on the Transportation Advisory Panel recommendations”.  Abigail McHugh-Grifa, the Executive Director of the Rochester People’s Climate Coalition, presented the overview (starting at 14:45 in the meeting recording).  She holds a Ph.D. in Music Education, but “decided to give up her career in music to dedicate herself to climate work”.  She exemplifies my concern that the members of this working group lack the background and education to provide meaningful comments on technical issues. 

She explained that the working group decided to present comments on the enabling initiative recommendations from two panels, transportation and housing & energy efficiency, because they represent opposite ends of the spectrum in terms of how well the panels incorporated environmental justice priorities.  In other words, transportation did not address the pre-conceived notions of a “climate just” transportation system but the housing and energy efficiency checked all the boxes for their demands.

I annotated the slide used in her presentation with my italicized comments below:

  • Recognize that goals/benchmarks/accountability is essential
    • The recommendations need clear guidance on how benefits/investments will be defined, measured, tracked, and shared over the long term
    • Scoping plan must ensure data is available to accurately measure the success of implementing the CLCPA
      • I agree with this comment.
    • Better scrutinize every action for justice
      • Some of the recommendations presented false market-based solutions
        • The EJ community has historically been opposed to market-based solutions because they believe that they don’t prevent localized areas of high pollution. In the case of greenhouse gas emissions that is not a relevant concern so their problem is associated with co-pollutants.  The EJ community’s air pollution goal is zero risk, i.e., zero emissions. 
      • Provide greater clarity, reasoning, and purpose
        • Some goals such as the doubling of municipal-sponsored public transportation appear arbitrary without an analysis on the basis of the target
          • None of the enabling initiatives included any substantive documentation. As a result, I agree that more detail is needed to justify the enabling initiative recommendations.
        • Policies with significant implications like a feebate deserve more than a ‘handwave’. It sounds like ‘free money’. How does it actually work in practice?
          • I agree with this comment.
        • Provide explanation of how the social cost of carbon was incorporated
          • As far as I can tell the social cost of carbon has not been incorporated yet. It is another one of those pesky details that should be in the as yet unreleased documentation.
        • Edit jargon to plain speak, and remove vague, squishy language and strive to provide key details
          • In my opinion, the presentations by this working group exemplified vague jargon and a lack of details. Moreover, oftentimes understanding a technical topic requires knowledge of the jargon as detailed in a following section.
        • Increase ambition (using transportation panel recommendation examples)
          • Fill in the gap of connectivity between regions of the state that rely on public transportation by prioritizing high speed rail and long-range bus service
            • I don’t think the state can afford high speed rail and I am sure that the effect on travel in the only corridor (New York – Albany – Buffalo) where it might be feasible would not provide any meaningful reduction in GHG emissions.
          • Refine transit-oriented development strategy to elevate its estimated GHG reduction impact by 2050 from medium to high by placing the most emphasis on vehicle mile travel reduction.
            • Transit-oriented development refers to mixed use (residential, commercial and business) development along public transit lines to reduce the need for personal vehicles. Theory is fine but in practical terms I don’t see this as meaningful solution away from New York City.
          • Deemphasize vehicle electrification as the topmost solution as it fails to address single occupancy vehicle associated issues. This hinders our ability to address the root cause of runaway transportation emissions, and its related link to systemic issues such as racism and poverty
            • Apparently, the environmental justice advocates have issues with single occupancy vehicles. In the suburbs and in rural areas single occupancy vehicles are a necessity.  In order to convince those residents that there is a link to systemic racism and poverty issues there has to be a dialogue with the opportunity to challenge some of the presumptions but that approach was explicitly rejected by Yeampierre in her overview of climate justice.

The McHugh-Grifa presentation also used the transportation presentation as examples of some of the points made for the bullet points above.  One of her concerns was that the transportation panel recommendation outline presentation was filled with jargon and vague or squishy language and gave some examples.  For example, in slide 20, component for delivery, “make ready costs for support facilities”, she complained that “I have been doing this work for a while and I just don’t understand what that means”.  Apparently in her background in music education, she never got around to the obvious issue that if you electrify public transit buses, the transit garages aka support facilities have to be set up to recharge the batteries and service entirely different bus components.  In my conversations with an expert in this field he has pointed out many nuances and complications to this challenge that he has said that even the state’s bus electrification alleged experts don’t understand.  While I agree that the outline doesn’t do an adequate job providing documentation for the recommendations, I also have to point out that the presentation was never intended to educate members of the public who have no background in this sector simply because of space limitations. 

It got worse.  She complained of three problematic themes in the transportation recommendations that were not clear enough.  The first theme was that the recommendations only focused on “encouraging and incentivizing” behaviors rather than “concrete and enforceable policy change that would advance the systemic transformation of our transportation system that the climate crisis demands”.  In the context of single occupant vehicle use that translates to a vehicle mile traveled policy limit which I believe will bring out yellow vest protests the instant it is proposed.  The second theme was the need for clear metrics coupled with enforcement mechanisms as exemplified by the apparent failure of the transportation sector recommendations to meet the expected reductions targets.  I suspect that the transportation panel had some concerns that the reality of the changes to the transportation system needed relative to what is politically palatable led to the lack of specific enforcement mechanisms.  The last theme concerned public engagement.  Recall that a key premise of the climate justice framework is that decisions should be made by the communities.  Absent any technical expertise that is a recipe for disaster.

Just when I thought it could not get any more absurd, McHugh-Grifa complained that the transportation recommendations did not consider the potential effect of climate refugees.  She said that:

As climate conditions worsen, we in our region anticipate that we will see an increase in climate migrants and refugees that move to our area from other parts of the states and countries.  There is no indication that the transportation panel has taken these kinds of population shifts into account or is considering how the transportation needs of any given region may change over the coming decades

I agree that climate refugees will be a problem in New York but it will not be because of people moving into the state.  Instead, if these draconian policies come to pass, there will be a mass exodus out of state.

Response to Transportation Advisory Panel Recommendations

Transportation is a key climate justice concern.  However, I think that in general the working group and for that matter the transportation advisory panel vision for transportation is out of touch with the reality of transportation in the suburbs and rural areas.  For example, McHugh-Grifa stated that doubling the service would still be inadequate.  That brings up the question just how much of an improvement to service would be necessary to entice people away from their personal cars.  For example, I cannot conceive of any scenario where I would use public transit to go grocery shopping.  As disappointing as it may be for public transit advocates, the fact is that outside of New York City housing has evolved around the use of automobiles.  Changing that dynamic would require massive transformation of the rest of the state’s infrastructure.

The specific response to the transportation recommendations was presented by Eddie Bautista, Executive Director of the NYC Environmental Justice Alliance, who has a B.A. from N.Y.U. and an M.S. in City and Regional Planning from Pratt Institute.  His presentation starts at 28:20 in the meeting recording

Bautista claims that environmental and climate justices groups across the county are opposed to emissions trading programs like cap and trade. He consistently refers to a single study that claims that these programs not only don’t reduce hot spots but they exacerbate them.  The paper “Carbon trading, co-pollutants, and environmental equity: Evidence from California’s cap-and-trade program (2011-2015)” appears to be consistent with his claims.  Note, however, that a subsequent study that looked at a longer comparison period that “emissions from sources subject to the cap declined 10% between the program’s launch in 2013 and 2018”.  Because GHG emissions are a function of weather and economic conditions there is large annual emissions variability which I believe accounts for the differences between these analyses.  Moreover, the complaint that cap-and-trade programs do not eliminate pollution hot spots demonstrates a fundamental misunderstanding of air pollution control strategies.  Cap and trade programs are designed to address regional pollution problems like acid rain, ozone and global warming.  For those regional pollutants, concentrations are only a concern over large areas and impacts are not localized.  The Clean Air Act established air quality limits to address air pollution hotspots and every source has been evaluated to determine if it affects compliance with those limits.  With the exception of ozone, New York meets all those air quality limits.  Because ozone is a secondary pollutant, emissions from neighborhood power plants cannot create localized hot spots.  As noted with respect to Yeampierre’s presentation, it appears that the only environmental justice acceptable level for air pollution is zero.

I annotated the slide used in his presentation with my italicized comments below:

  • Transportation Climate Initiative (TCI) flaws
    • Best available evidence shows cap and trade systems do not eliminate air pollution hotspots, and often exacerbate them
      • This is a fundamental misunderstanding of air pollution control strategies as described in detail above.
    • Like RGGI, funds generated by TCI are vulnerable to budgetary raids by the Executive and Legislature
      • I agree with this comment
    • Reforms to cap and trade are unlikely to remedy pollution disparities given the program’s inability to surgically reduce mobile source emissions which are more complex to regulate than stationary sources
      • Because cap and trade programs were not specifically designed to address local impacts from any sources this is true.
    • The inherent design flaws of cap and trade result in environmental racism
      • My impression is that environmental racism refers to any disproportionate impact and that the only acceptable solution is no impact whatsoever.
    • The inadequate involvement of EJ groups in the policy process reflects a profound failure of democracy, and bolsters the case for abandoning sector specific carbon pricing policies for a comprehensive carbon fee like that in the CCIA.
      • New York agencies did an extensive outreach process relative to involvement in the Transportation Climate Initiative. I attended several of their meetings and environmental justice advocates were always in attendance and, frankly, it seemed that the majority of attendees were from that segment of society at least at one of the meetings.  I think this is a harsh and unwarranted criticism of the Transportation Climate Initiative stakeholder process.
    • Denial of Home Occupant Justice
      • Protect low and middle income renters by amending the provision on new market rate housing within Transit Oriented Development that is currently limited to home ownership to include renting and rent to own options
        • No comment – way down in the weeds
      • Clean Fuels Standard Concerns
        • Allowing high carbon fuel producers to meet their credit obligations by paying clean producers for their energy is a weak way to enforce the standard -as it lets them offset instead of eliminate their emissions -which by itself won’t guarantee that emission reductions and investments in overburdened communities occur at the necessary speed and scale required by the CLCPA
          • The Transportation Climate Initiative was not designed to meet New York CLCPA net zero societal GHG reduction targets. Instead, they were looking at moderate reductions and this offset option was part of that strategy.  The real question is whether this initiative has value as part of the CLCPA control strategy because these points are valid.
        • Clean air necessitates an ‘electrify everything’ approach.
          • No comment, see below
        • Allowing vehicles to combust lower carbon liquid fuels that still emit criteria pollutants won’t eliminate air pollution hotspots
          • This comment is correct

The second slide had two topics.  Bautista covered the electrify everything that moves topic and at 38:50 of the meeting recording, McHugh-Grifa discussed the hone in on equitable vehicle miles traveled reductions and the extra support for communities facing barriers topics.  She concluded that we need systemic change so we “respectfully request the transportation panel give it another go, ideally with more input from EJ groups or at least more commitment to incorporate the feedback from EJ groups that they have already received”.

  • Electrify Everything that Moves
    • Adopt ZEV for medium and heavy-duty vehicles and carve out explicit targets for trucks and bus conversion that prioritize diesel emission reduction in air pollution overburdened communities
      • As noted previously, widescale implementation of electric vehicles has severe environmental consequences elsewhere
      • As important, advocates for electric vehicles ignore all the downsides that make this technology a non-starter for many.
    • Mandate rapid phase in of the conversion of the state’s fleet to ZEVs
      • While it may be easy to mandate that the state fleet to convert, the question becomes where is the money going to come from.
    • Rapidly expand policies to encourage uptake of EVs –like incentives and enhancement/expansion of charging infrastructure
      • When I attended the TCI stakeholder meetings at least one speaker extolled the virtues of electric cars. Based on my reading I believe that you can make the case for one as the second car in the family which could be used most of the time.  The problem is that there are many instances where an EV does not make sense, e.g., the occasional long trip where in route charging would be necessary.
  • Hone in on Equitable VMT Reduction
    • Establish a New York State-supported Equitable (Fair & Affordable) Transit-Oriented Development (E-TOD) effort via the Regional Economic Development Councils or through a New York Statewide E-TOD Program.
    • Include at least 20% affordable housing minimum for all new TOD
    • Amend Municipal Home Rule Law to explicitly allow fees on new development to offset public transportation service costs
    • Require at least 50% of transportation sector climate monies to be spent on non-car programs
      • As noted before, I don’t think TOD is a viable alternative outside of the NYC metropolitan area so this strategy has limited value
  • Extra Support for Communities Facing Barriers
    • Within the Consolidated Funding Application (CFA) of the Regional Economic Development Councils, mandate prospective developers and employers to identify how their prospective projects (and related NYS funding requests) consider public transportation options for low-income workers.
    • Incentivize hiring of disadvantaged workers in transit manufacturing by enabling companies to get a credit for setting aside a certain proportion of their workforce for hiring them
      • No comment

Response to Energy Efficiency (EE) and Housing Recommendations

The Climate Justice Working Group made the point that this panel’s presentation was done better than the transportation panel and that they handled the climate justice considerations better.  The response to the EE and Housing recommendations was presented by Rahwa Ghirmatzion, Executive Director of PUSH Buffalo who studied English literature and economics at University of Buffalo starting at 40:48 in the meeting recording.  Because this article is already too long and because I don’t take exception to much of their comments on this panel’s recommendations my review will be much shorter. 

Ghirmatzion made a good point that the recommendations did not acknowledge New York’s energy affordability goal that households should not be paying more than 6% of their income on energy costs.  The point was also made that the baseline for state goals should be made available with a system to track progress relative to those goals.  I agree completely.

Her presentation discussed the need to support the transition to electric heating/cooling/cooking quickly.  The working group is convinced that people in disadvantaged communities want a “safety net style guarantee of renewable energy to every household”.  I have a hard time reconciling those initiatives that I believe will markedly increase energy costs with EJ advocacy support for them.  Given that there have been programs available for years where consumers can sign up for wind and solar power supply programs but participation has been abysmal, I believe that most ratepayers really only care how much it costs.  How can the advocates push for programs that will increase costs?

In the second slide of the response to the EE and Housing panel, Ghirmatzion recommended additional actions.  Of particular note was the suggestion to calculate costs and benefits holistically with considerations of the health impacts associated with poor indoor air quality and insufficient thermal comfort as well as the cumulative cost burden related to housing, energy, transportation, and healthcare.  Those are very good points.  There has been very little information on costs provided to date and total costs are the key.  One final point regarding the suggestion to tweak energy efficiency programs.  Energy efficiency has been part of New York energy programs for decades.  I have doubts that there is much more that can be done and have yet to see an evaluation of effectiveness relative to the goals.

Because of the length of this post, I am not going to discuss the questions and answers session starting at 48:00 in the meeting recording.

However, I have to mention Yeampierre’s response to the question at 1:35:44 about replicable solutions that could be expanded to further climate justice goals.  Her response at 1:36:49 illustrates my concern about lack of expertise leading to wasted time and effort related to the approach of advocacy panels setting policy.  She argues that current projects that use the industrial waterfront have been successful and suggests that using the waterfront as a delivery hub could be appropriate.  She suggested that this could be a way to connect to economically depressed farmers upstate by way of refrigerated barges to the waterfront to distribute healthy food.  This is a non-starter.  There is a reason that barges are used for bulk commodities that do not have delivery time constraints – they are slow.  Healthy food is fresh food and the range of suppliers within even a day of the New York City waterfront is so small that they could not possibly supply any meaningful fraction of the needs of the City.


I don’t think anyone disagrees with the concept that disproportionate environmental impacts on disadvantaged communities are a bad thing and should be addressed.  Unfortunately, the Climate Justice Working Group approach to this is fatally flawed.  On one hand their overview of climate justice did not include the concept of compromise so their comments on the panel recommendations were not constructive criticisms, they were demands for change.  Their criticism of the lack of detail in the recommendations is warranted but I don’t think the background and education of the working group is sophisticated enough to understand the nuances and unintended consequences of all the panel recommendations anyway.  On the other hand, their apparent goal is elimination of all environmental impacts to disadvantaged communities.  The reality of environmental regulation is that trade-offs and compromises are necessary because zero-risk policies are impossible to implement.  More importantly, pushing for minimal risks in one location means that risks are increased elsewhere as I explained relative to the rare earth metals used for energy storage. 

In my opinion, the Climate Justice Working Group’s rationales and recommendations are driven more by special interests and emotion than fact.  The summary article on the Pacific NW heatwave by Dr. Mass included a section on the politicization and miscommunication of science that was evident in this presentation.  I entirely endorse some of the comments he made:

  • “Hyping global warming puts unrealistic and unnecessary fear into the hearts of our fellow citizens.” 
  • “Global warming is an issue we can deal with, but only if truthful, factual, and science-based information is provided to decision-makers and the nation’s citizens.”
  • Politicians have “put political agendas ahead of truth and we are all the worst for it”.

In this instance I am willing to give the environmental justice advocates a pass on science accuracy especially given that the CLCPA and the state spokesmen have consistently hyped unrealistic global warming fears.  The bigger concern is the attitude of the Climate Justice Working Group vis-à-vis to any modification of their demands.  Because some of those demands are based on scientific mis-understandings and ignore worse unintended consequences it is not in the best interest of society as a whole, as compared to their narrow constituency, to implement all of their demands. 

Contrary to their belief the CLCPA says their role is to consult with the advisory panels and Climate Action Council not be the final arbiter of the enabling strategies of the scoping plan.  My impression is that they have adopted a “take it or leave it” position regarding their recommendations.  It will be interesting to see if the Climate Action Council adopts a scoping plan that addresses the science or bows to the emotion-based approach of the Climate Justice Working Group.

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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