I gave a presentation titled “Climate Act – All Pain and No Gain” describing the New York Climate Leadership and Community Protection Act (Climate Act) to the New York Propane Gas Association Fall Conference on October 25, 2021. This post summarizes the presentation because it gives a good overview of issues related to the Climate Act.
I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it 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. 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.
Background
According to their website the New York Propane Gas Association (NYPGA) is “a member-focused trade organization providing services that communicate, educate and promote the propane industry in New York”. I led off the discussion of the Climate act with my overview presentation on the Climate Act. The second speaker, Richard Goldberg from Warm Thoughts Communications, described their plans to fight the Climate Act. Finally, Assemblyman Phil Palmesano updated the group on the climate initiatives political situation in Albany. I am only going to discuss my presentation in this post.
Presentation
Because the slides and annotated slides with references are available I will not go through every slide in the presentation. Instead, I will highlight the points that I was trying to make and only include a few slides. There were four main topics: an overview of the science, a summary of the Climate Act, a description why I think there is no gain from the Climate Act and an explanation why it is all pain.
For the science overview I used slides prepared by Dr. Judith Curry that she graciously allowed me to use. One problem I had is that there is so much material that I could have presented it was difficult to pare down the content to fit the 30-minute time slot. I only used the first three slides from Dr Curry’s presentation. The first slide described the common perception of the climate crisis. The second explained problems with the climate crisis narrative:
- We’ve vastly oversimplified both the problem and its solutions
- The complexity and uncertainty surrounding climate change is being kept away from the public and policy debates.
- Rapid reductions in emissions are technologically and politically infeasible on a global scale
I also included her summary of the 97% climate science consensus and the disagreements about the current state of climate science:
- How much of the recent warming has been caused by humans?
- How much the planet will warm in the 21st century?
- Whether warming is ‘dangerous’
- And how we should respond to the warming to improve human well-being
My summary of the Climate Act used graphics from the New York agency publications. I noted that the rationale for the Climate Act is that we need to do something to address the “the greatest threat facing life as we know it” but explained that I did not have time to demonstrate that this claim is an exaggeration, see this example of the material I would have used if I had time. When I showed a list of the Climate Act targets, I explained that they were developed by motivated special interest authors and that the limits were set entirely to fit a political agenda with no thought of feasibility.

While I tried to avoid getting into the details of the greenhouse effect, I had to address a couple of points. I included a slide describing the greenhouse effect as background for the discussion of global warming potential (GWP) after a slide listing the six greenhouse gases covered by the Climate Act. The GWP is used to intercompare the effects of different greenhouse gases. It is a function of the gases’ ability to absorb radiation and their residence time in the atmosphere. The Climate Act vilifies methane by using a 20-year GWP time scale whereas, everybody else uses a 100-year GWP time scale. This triples the importance of methane in the accounting for all the gases. However, if the Climate Act is really intended to address the potential for New York emissions to cause global warming this is inappropriate. The actual effect of a greenhouse gas on global warming is a function not only of GWP but also observed atmospheric concentrations. Because the concentration of methane is so low in the atmosphere, doubling the concentration will “change the outgoing forcing by less than one percent”. In other words even if we control methane it will have not effect on global warming.
I included the following table that showed where the state currently stands relative to the 2030 goal of a 40% reduction of greenhouse gas emissions. The data in the table were extracted from the advisory panel presentations and are a sum of all six greenhouse gases expressed in million metric tons of carbon dioxide equivalent – adjusted for the 20-year global warming potential. In the most recent year of data (2018), emissions were only 8% less than 1990. Getting an additional 32% by 2030 is an ambitious goal. I also pointed out that Climate Act methane obsession increases residential, commercial, and waste sector emissions to nearly half the total in 2018.

My no gain for the Climate Act argument is that it will not have an effect on global warming. If the point is that we want to reduce global warming to reduce the effects we constantly hear about in the media, then perhaps it is time to re-think this approach. I showed that if New York manages to eliminate all the 1990 emissions that we can only expect a reduction, or a “savings,” to global warming of approximately 0.0097°C by the year 2100. Given that atmospheric temperature measurements only have a precision of 0.1°C that means we will never measure the change due to the Climate Act. In addition, we will never perceive that reduction using the general rule of thumb for temperature change with elevation or latitude because the predicted temperature savings is equivalent to a vertical distance change of 39 inches or latitudinal distance change of 0.9 miles. Most importantly emission increases elsewhere overwhelm any reductions New York can make. For example, emissions from coal plants under construction and completed in China in 2019 will subsume the reductions of all of New York in less than two years.
I also argued that there is a moral case for using fossil fuels that makes it very likely that fossil fuel will be the appropriate choice to provide reliable, affordable, and abundant electricity to the over 1.2 billion people in the world who don’t currently have it. The following slides shows that even as CO2 emissions have gone up poverty has decreased, life expectancy has increased and population has increased. Similar results for other parameters representing human well being show the same thing.

My presentation went on to describe how the Climate Act implementation was set up and the current status. I explained that the law established the Climate Action Council to develop a scoping plan to meet the targets. It has 22 members and 14 members were appointed indirectly or directly by former Governor Cuomo. Those members were chosen for political purposes rather than technical expertise. Technical expertise was supposed to come from the advisory panels composed of people with expertise or direct involvement. Unfortunately, direct involvement meant politically correct so technical expertise was short-changed. The result was that the proposed strategies from the panels are more aspirational than practical.
I went on to explain that the strategy recommendations developed since last year have been turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan in October so that the scoping plan can be finalized by the Climate Action Council by the end of the year. Next year the public and other stakeholders will get to comment on the scoping plan
In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented. The analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with different scenarios that incorporate emission reduction strategies. All of the analyses have common themes as shown in the following slide. They will have major impacts to reliability, cost, and personal choice. For the presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” that translates into mandates for electrification of heating, cooking, and hot-water.

Four scenarios are included in the integration analysis. Scenario 1 incorporates recommendations by the Advisory Panels for potential reduction strategies that included ambitious actions but the emission reductions were only 34% by 2030 instead of the 40% target. The remaining scenarios were designed to meet the 40% target at a minimum and include even more ambitious actions. Scenario 2: uses low carbon fuels (bioenergy and hydrogen) for combustion for difficult to electrify applications and for times of low renewable availability. In order to placate the members of the Climate Action Council who believe that all forms of combustion are bad Scenario 3 reduces combustion as much as possible and accelerates electrification of buildings and transportation actions. Scenario 4 was developed to respond to those on the Climate Action Council who think that more reductions faster are possible which pushes all the actions further.

At the October 1, 2021 Climate Action Council meeting new findings from the integration strategies were described. The one I find most unsettling notes that meeting the targets will require: “unprecedented rate of adoption of novel and potentially disruptive technologies and measures”. I explained that I did not know what a disruptive technology was so I had to look it up. I found a reference that explained that disruptive technologies “significantly alter the way consumers, industries, or businesses operate” and a “disruptive technology is one that enters the mainstream and changes the way most people think or behave.” However, that same reference notes that there are disadvantages: “New technology is typically untested and unrefined during its early stages and development can continue for years” and “innovations go through a period of problem-solving”. The problem is that the Climate Act schedule precludes most testing and problem-solving for these technologies For example, one of the low-carbon fuels proposed is green hydrogen produced by hydrolysis of water powered by wind and solar but the economic viability of this new technology is unclear. Beyond the mere unproven mechanics of the process as a way to store intermittent wind and solar for later use, the logistics of deploying the technology as well as the environmental impacts have not been addressed. The bottom line is that depending on disruptive technologies to meet the Climate Act goals is incredibly risky.
For this presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” and specifically discussed the potential mandates for electrification of heating. The silver bullet technology for home heating is the heat pump. I explained that they are more efficient than combustion and they have the advantage that they can provide both cooling and heating. I noted that they basically are refrigerators operated in reverse. Instead of taking heat out of the refrigerator to cool it they take heat out of the environment to warm the house. There are two types of heat pumps. Ground-source heat pumps use energy in ground that does not vary as much but are more costly and more difficult to retrofit. Air-source heat pumps are cheaper and can be retrofit more easily. However, they use atmospheric energy so they require backup heating capability in New York because there is insufficient energy available outside when the temperatures go below zero deg. F. I went back to the refrigerator analogy to make the point that refrigerators work well because they are insulated and well-sealed. In order to work as well in a building, comparable insulation and building shell efficiencies are needed. Clearly that is unlikely in most homes.
I explained that the mitigation scenarios all have mandates for heat pump installations. I extracted the heat pump strategies in the October 1, 2021 building sector descriptions for the following table. The scenarios assume that all furnaces sold in 2035 will be heat pumps and include a transition of heat pump sales (77% to 80%) by 2029. Note that this modeling does not propose how people will be coerced into those sales before the 2035 mandate. The modeling also makes assumptions about the number of heat pumps in the system by 2035 and 2050. Scenario 2 assumes 80% of the heat pumps installed are air source and Scenario 3 is a “lower share”. Backup is mostly electric in Scenario 2 and is all electric in scenario 3. It is interesting to note that only Scenario 3 admits that retirement before the end of useful life of fossil-fired furnaces is needed. It is not clear how they would design a regulation to enforce that mandate.

I explained that there are three painful aspects of the Climate Act
- Strategies don’t work everywhere
- Strategies don’t work all the time
- In some cases that is just a nuisance
- In other cases, it could be dangerous
- Without significant revisions I think it could lead to catastrophe
- Real costs will be substantial and their purported benefits are unrealistic
- It is not possible to offset consumer costs with the benefits claimed
I gave three examples of Climate Act strategies that do not work everywhere. One of the prominent buzz phrases in the advisory planning recommendations is “smart planning” which basically boils down to strategies that reduce energy use such that less generation is needed. One prominent example is to combine residential, commercial, and retail in one location to reduce energy use. For example, a smartly planned development could enable residents to walk to a grocery store rather than having to drive. However, in order to work the population density has to be high enough to support the grocery store. I don’t see how that strategy could work outside of New York City and its immediate suburbs. A major strategy to reduce transportation emissions is to enhance public transit to enable people to reduce vehicle use but this also needs a minimum population density and is unlikely to ever be a viable alternative in rural areas. Note that the Climate Action Council members who want to eliminate combustion sources would eliminate the use of wood burning for home heating. I believe that would be a non-starter for many rural residents who use their wood lots to provide the energy for heating their homes.
I noted that there are three examples of Climate Act strategies that do not work all the time. The second major strategy to reduce transportation emissions is to electrify vehicles. I will admit that electric vehicles work well for limited applications but they have limitations relative to gas powered cars. For example, I could use an electric vehicle for most of my local trips around Syracuse but I also use the car to visit family in Brooklyn. I don’t think that is a viable option with an electric vehicle because I would have to stop en route to charge up the car and then compete with around a million other car owners to find a place to charge when in the city. However, it is just a nuisance because I have the alternative of taking a train or flying down.
The Climate Act strategy to electrify home heating is more problematic. While heat pumps have advantages, the inescapable fact is that air source heat pumps don’t work well in really cold weather when you need heat the most. In my case, in order to ensure that I have sufficient heat when the temperature is below zero, I am going to have to have a backup radiant electric heat that is inconvenient and expensive. When everyone in my neighborhood has been forced to install similar systems, we will have to hope that the local distribution system will be able to handle the extra load because trying to heat our houses with toasters is not energy efficient. I also have to hope that my house service can handle the extra load at the time of critical need. If I get this wrong, it is not only inconvenient but also dangerous. I don’t think the odds of everyone getting this right are very high.
There is an even worse possibility. The future electric system is going to depend on intermittent wind and solar energy to provide electricity. If electric system planning gets this wrong the results could be catastrophic. I have previously described this situation as the Ultimate Problem with the Climate Act. In early 2020 a couple of analyses highlighted this issue as shown in the following slide. In order to keep the lights on grid operators have to balance load and generation which is relatively easy when the majority of the generators can be dispatched to do the matching. However, wind and solar are not dispatchable so it gets more complicated. In their presentation to the Power Generation Advisory Panel on September 16, 2020, E3 included a slide titled Electricity Supply – Firm Capacity that stated that: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”. They noted that they had found multi-day periods with low wind and solar output as shown in the slide when the renewable resource energy was far less than the load needed.

In order to provide sufficient electrical energy to power the future grid when home heating and transportation loads are added to the electrical loads, we have to know the frequency, duration and intensity of the periods when there is low wind and solar output. In February 2021, there was a disaster in Texas caused in part because the electrical system failed when it was needed most. Energy problems were related to the fact that the Texas electricity market only pays for the power produced, nuclear and fossil generators were not sufficiently resilient to cold weather, and the cold weather was accompanied by light winds so wind resources were mostly useless. In order to keep the grid operating they had rolling blackouts.
Superstorm Sandy , often mentioned as a reason why we need to implement the Climate Act, killed 147 people and caused $70 billion in property damages. The Texas energy debacle in February 2021 caused at least 151 deaths, property damage of $18 billion, and $50 billion for electricity over normal prices during the storm. Note that because one aspect of smart planning is to increase the cost of electricity when load is highest, that prices will be highest when backup resistance heating is required so there will be similar increases in cost over normal prices. If New York similarly mis-judges the availability of renewable resources similar impacts can be expected.
There is an even more concerning issue. If New York does its planning correctly the frequency, duration and intensity of low solar and wind output periods will be known and, assuming the disruptive technologies necessary do work as hoped, the electrical grid may be able to avoid a renewable resource reliability crisis. However, those are predictable conditions. What happens for a black swan event? The projected amount of offshore wind resources in 2050 is 10% of the capacity and 20% of the energy. What happens when a Category 4 hurricane hits the offshore wind farms? That would have the potential to destroy a significant portion of New York’s electrical generating resources for years. Maybe not at the same scale but an ice storm would also be problematic when everything is electrified. Clearly anyone who claims that a wind and solar energy system is “resilient” is pushing the envelope for credibility.
The final painful aspect of the Climate Act is the cost. The first summary of costs and benefits was presented at the October 14, 2021 Climate Action Council Meeting and I provided my first impression here. Costs in Scenario 2 are estimated to be $340 billion and if we start spending that in 2025 that is over $13 billion per year. They claim that the cost of inaction exceeds the cost of action by more than $80 billion. The basis for that claim is that improvements in air quality, increased active transportation, and energy efficiency interventions provide health benefits ranging from $160 – 170 billion and that reduced GHG emissions avoid economic impacts of damages caused by climate change equaling approximately $260 billion.

Conclusion
I concluded with five takeaways:
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- We’ve vastly oversimplified both the problem and its solutions
- Over-reliance on technological innovation is incredibly risky
- Strategies proposed don’t work all the time and you need them the most when they don’t work
- Texas energy debacle was caused in part by over-reliance on renewables and costs were equivalent to the costs of superstorm Sandy
- The bottom line is that the solutions don’t add up
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I think the presentation was well received. It was encouraging to talk to like-minded individuals because this is a hot button topic that I have found best to avoid because the true believers cannot be persuaded that there are issues and uncertainties associated with the science. It is troubling that I see the same slavish devotion to the premise that renewable energy solutions can replace the existing system if we only have the political will. On the other hand, now that we have specific policy recommendations, I am convinced that a list of what will be required will awaken the majority of New Yorkers to what is coming at them. Then we can explain the fact that the ambitions for a zero-emissions economy are not affordable and increase energy reliability risks too much with available technology. It is appropriate to call time out and determine a better course of action than the Climate Act.