The Climate Leadership and Community Protection Act (Climate Act) codifies a New York approach to achieving net-zero emissions by 2050. The October 14, 2021 Climate Action Council meeting briefly discussed the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. This post describes the organization of the initial draft of the scoping plan as presented at the October 14 Climate Action Council meeting.
I have written extensively on implementation of the Climate Act 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. 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.
Climate Act Implementation
The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. 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 energy and climate agenda 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 and has since been updated. In mid-November documentation consisting of slide decks and spreadsheets was made available for the analysis but the lack of supporting descriptions makes interpretation of the slides 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. Also included are four mitigation scenarios (shown below) that are compared to the reference case. This analysis forms the basis for the contents of the scoping plan that will be released in early 2022.

Scoping Plan
The video recording of the October 14, 2021 Climate Action Council provided the first look at the scoping plan. It included an initial draft Scoping Plan walkthrough starting at 3:48:04 of the recording. Note, however, that it was near the end of the session so it was only a cursory discussion. There is a one slide outline of the organization of the Scoping Plan that is discussed at 3:48:47. Not shown in the outline, but mentioned, was that there would be technical appendices included in the scoping plan document.

The presentation skipped the following three pillars discussions. I have not spent much time on the climate justice working group (CJWG) effort discussed in the next two slides. When they get around to making their recommendations to the Climate Action Council, I will post a summary. Note that DAC is a dis-advantaged community.


The health pillar is a key factor in their benefit-cost claims. The largest health benefit is from a reduction in inhalable particulates. I have explained previously that I cannot accept their health benefit modeling methodology and results until they demonstrate that the observed state-wide reduction of inhalable particulate concentrations from 2000 to 2020 has produced health benefits on the order of 15 times greater than the integration analysis predicted health benefits due to Climate Act inhalable particulate concentration reductions.

The presentation skipped (at 3:51:50 in the recording) to the map of greenhouse gas emission categories, the advisory panels and the chapters in the scoping plan. The slide just shows how the panel recommendations were incorporated into the scoping plan.

The next seven slides in the presentation highlight various sector strategies. Starting at 3:52:52 in the recording there was an explanation of the format of the strategy slides. Each contains an overview sector and vision including current status and vision for 2030 and 2050 and summary of the mitigating sector strategies on the left. On the right there is more detailed strategy information by theme. For your information, I list links for the presentations by each panel to the Climate Action Council and provide my impression of the initial summaries here.
In the following I highlight some of the strategies that will be included in the scoping plan when it is released next year. For the transportation sector note that the they have pushed the date for 100% light-duty zero-emission vehicles up to 2030 as opposed to the current legally mandated date of 2035. In addition, they somehow believe that it is possible to get 40% or more zero-emission sales for medium- and heavy-duty vehicles by 2030. They also presume that a “substantial portion” of personal transportation in urbanized areas will be shifted to public transportation or other low-carbon modes. By 2050 all vehicles have to be zero emissions. Note that “Some segments of hard-to-electrify sectors (aviation, freight rail) will rely on hydrogen and renewable biofuels, as needed”.

The buildings highlights presume that by 2030 heat pumps will become the majority of new purchases for space and water heating and that 1-2 million households will be electrified with heat pumps. In 2050 they expect that 85% of homes and commercial building space statewide will have electrified with heat pumps.

The electricity sector highlights slide is deeply concerning to me. The only difference between the overview and the mandated Climate Act targets is that they expect more behind-the-meter solar to be installed by 2030 than the 2025 Climate Act target. The following slide for the Industrial sector includes a statement that says “Requires research, development, and demonstration to prove technologies at scale”. The power sector strategies have the same constraint but there is no recognition of that fact. In this slide reliability is mentioned in the eighth of ten strategies. All this despite a reliability planning speaker session that warned that “it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions”. At the time I wrote that the ultimate question is whether the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel. Based on this presentation I fear they are catering to magical solutions touted by the uninformed.

The industry slide is unchanged from the advisory panel recommendations. Kudos to the fact that their strategies recognize the technological challenges faced by a transition to low-carbon processes.

The agriculture and forestry sectors also seem to be very similar to the advisory panel recommendations. I worry that their plan to “increase carbon storage and sequestration in agricultural and forestry products through the avoided conversion of farm and forest lands, afforestation and reforestation, improved forest management practices, cropland management practices and harvested wood products” will fail. Currently solar developers are rushing to develop as much as they can, as fast as they can, and as easily as they can, and that means plopping down hundreds of acres of solar panels on prime farmland. There is no plan or avenue to address this issue at this time.

I think one can argue that the waste sector has a lot of wishful thinking in their strategies. It basically boils down to planning on waste reduction, reuse, and recycling initiatives that are so effective that landfills are “only used sparingly for specific waste streams”. That has been a goal of the state for decades but has never panned out. It is not clear why the climate action plan will fare differently.

The final slide lists state-wide and cross sector strategies. For the economy-wide policies it says that the scoping plan will seek “input on options for economywide policies that price carbon emissions”. Climate action activists want to put a price on carbon but no one dares to let the public know what that will entail and what it will cost. The gas system transition recommendations to reduce emissions from the natural gas system through “an orderly transition that is equitable, cost-effective, and maintains system safety and reliability” is another strategy that avoids the inevitable public pushback when the time comes to say you cannot use natural gas in your home. The other recommendations sound appealing but won’t have major impacts on emissions.

Conclusion
It is terrifying to me that the Climate Act Scoping Plan that is intended to drive the next energy plan for New York State appears to overlook the importance of electric system reliability. The organization slide for the plan does not mention reliability and the power generation sector strategies mention reliability only in passing. It is important to note that the ideologues who have been allowed to shape the scoping plan strategies apparently do not recognize that the zero-emissions dispatchable resource necessary to keep the lights on does not exist. When the strategies are reviewed by the organizations charged with electric system reliability next year it will be time to decide if the transition is really only a matter of political will or if the risks are too great with today’s technology.
Steven Koonin sums it up better than I can:
Emissions are best reduced gradually. The prevailing narrative that we must immediately undertake massive actions to eliminate global emissions by mid-century is not supported by the science. A crash elimination of emissions from our energy systems would be extraordinarily disruptive, raising energy costs and degrading reliability, stranding assets, and displacing workers. Those systems are slow to change, in part because they must be highly reliable and require large capital investments. While a zero-emissions electrical grid is central to decarbonization strategies, we don’t yet have the technology to create a grid that is also reliable and affordable. The recent EU electricity crisis, caused in large part by relying upon intermittent wind energy without adequate back up, illustrates the critical importance of reliability.
Reasonable people in the early 20th century settled in arid portions of the US West with the belief that rain would follow the plow. Errors in critical thinking are conflated with wishful thinking. Thus wind and solar will somehow become reliable as massive energy storage systems which don’t exist become available.
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