The initial integration analysis results for the Climate Leadership and Community Protection Act (Climate Act) were discussed at the October 1, 2014 and October 14, 2021 Climate Action Council meetings. This post documents the implications on the cumulative environmental impact assessment.
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.
The Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA. Of particular interest are the 2030 targets: reduce greenhouse gas emissions by 40% relative to the 1990 baseline by 2030 and 70% of the electrical energy is supposed to come from renewable resources. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021. Both the Council and the advisory panels are composed of political appointees chosen more for their direct involvement in the CLCPA transition than their expertise in the energy sector so the strategies proposed were more aspirational than practical.
Developing a plan to transform the energy sector of the State of New York is an enormous challenge so the New York State Energy Research and Development Authority (NYSERDA) and its consultants are providing technical support to translate the recommended strategies into specific policy options in an integration analysis. An overview of the results of this integration analysis were presented to the Climate Action Council at the two October meetings. There is a notable lack of documentation available for the analysis so meaningfully reviewing the plan is difficult.
The integration analysis models the complete New York energy sector. The modeling includes a reference case that projects how the economy and energy sector will evolve out to 2050 in the absence of any Climate Act policies or mandates. The following slide from the first integration analysis presentation lists the four mitigation scenarios that were developed to compare with the reference case. The first simply developed energy strategies that implemented the advisory panel recommendations but the results showed that even more stringent policies were needed because the 2030 targets were not met. The second mitigation scenario meets the 2030 targets by using low-carbon fuels to meet the critical need for dispatchable resources to keep the lights on. The third scenario placates the members of the Climate Action Council that naively demanded that no combustion is necessary despite the lack of a proven technology that can keep the lights on in the worst-case scenarios. Because some members of the Climate Action Council are dupes who don’t appreciate the technological hurdles and risks to reliability of the transition to zero-emissions using renewable energy and have no personal accountability for recommending policies that put New York at risk of catastrophic blackouts, there is a fourth mitigation scenario that looks at options for eliminating combustion as much as possible as soon as possible.
Related Environmental Impact Statements
Consistent with 6 New York Codes, Rules and Regulations (NYCRR) §617.9(a)(7), a Generic Environmental Impact Statement is the appropriate mechanism for assessing environmental impacts related to the Climate Act. On September 17, 2020 the Final Supplemental Generic Environmental Impact Statement (SGEIS) for the Climate Leadership and Community Protection Act was released. It evaluated the environmental impacts associated with the incremental resources needed to comply with the Climate Act and built upon and incorporated by reference relevant material from four prior State Environmental Quality Review Act (SEQRA) analyses. Each of the analyses evaluated the environmental impact of the expected renewable energy resources needed at the time of the analysis was done. The most recent version considered the impact not only of previous New York proceedings but also the mandates in the Climate Act.
According to the 2020 SGEIS report:
Exhibit 2-5 summarizes the current renewable energy generation in New York, in addition to the offshore wind and distributed solar procurement goals, and the estimate of utility-scale solar capacity required to meet the meet the 70 by 30 goal. This SGEIS is evaluating a range of utility-scale solar that can maximize the competitive outcome, including up to an incremental 6,300 MW of utility-scale solar. Procurement of 5,800 MW of offshore wind by 2030 represents a portion of the 9,000 MW by 2035 procurement goal. Distributed solar capacity by 2030 is expected to exceed the 6,000 MW by 2025 procurement goal by an additional 3,000 MW and would reduce the amount of installed capacity procured through Tier 1.
Integration Analysis Expected Renewable Capacity The problem is that the original expectations of renewable capacity for the Climate Act falls far short of the renewable capacity requirements in the integration analysis for 2050. The integration analysis initial results presentation includes the following graphic that lists the capacity needed for each renewable energy source.
The following table compares the integration analysis installed capacity with the SGEIS Exhibit 2-5 expected renewable capacity. The integrated analysis does not differentiate between distributed solar and utility-scale solar. In order to compare the expected values, I pro-rated the total solar by the distributed and utility-scale solar values from the SGEIS. The table shows that the environmental impact statements done to date considered renewable resource capacities far less than what the integration analysis expects will be needed: one and half times more onshore wind, nearly twice as much offshore wind, and over three times as much distributed and utility-scale solar. In addition, no previous analysis considered the environmental impacts of massive energy storage facilities or the “zero-carbon firm resource” that the integrated analysis presumes will be provided by hydrogen resources. Moreover, these are just the generating resources. There will also be significant environmental impacts associated with the transmission system additions and upgrades necessary to get the renewable resources into the grid.
There is no question that the integrated analysis renewable resources should be addressed in another environmental impact statement. Assuming 3.3 MW turbines (average turbine size in the Article Ten queue in 2020), integrated analysis Scenario 2 calls for over 1,100 more turbines. The solar projects in the Article Ten queue in 2020 averaged 9.3 acres of equipment area per MW and that means that the SGEIS solar equipment area covered was 110 square miles and the Scenario 2 solar equipment area covered would be 353 square miles.
On January 8, 2021 I published an article on CLCPA Cumulative Environmental Impacts that concluded the biggest deficiency in the CLCPA was the lack of a feasibility study that incorporates environmental impact criteria. I also noted that when there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible. Now that we have those resource estimates another environmental impact assessment that covers the increased wind and solar resources as well as the energy storage, the zero-emission firm resource, and transmission system impacts needed is necessary.
At the time I noted that there should be a threshold for unacceptable environmental impacts. For example, I am worried about eagles. If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful. Now that has occurred and I am not willing to chance that environmental victory. Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines. There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed. Environmental thresholds should be included in the scoping analysis.