The Draft Scoping Plan outlines the implementation strategy for New York’s Climate Leadership and Community Protection Act (Climate Act) has been released for public comment by the Climate Action Council. The NY Business Council recently published a summary of the Draft Scoping Plan that I think is an excellent overview of the Plan.
I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, 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 Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. 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. Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants. The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”. Once complete an updated Energy Plan will guide New York’s energy policy going forward.
The NY Business Council is the “voice of business and employers in New York State Representing 3,500 business of all sizes, in all sectors Including nearly 100 local chambers and business groups”. At a recent webinar Ken Pokalsky referenced a summary of the Draft Scoping Plan that he prepared. I asked for permission to publicize his summary and this post is the result.
The summary of thescoping plan points out that the document and supporting documents “amount to more than 1,000 pages and provide significant details on the Climate Action Council’s analysis and recommendations. It explains that “Some sections, i.e., transportation and buildings, provide specific recommendations and timelines for action” and that “Others, including sections on the electric power and natural gas sectors, and on industry, provide far less in the way of a detailed implementation plan.”
The distinction between the sections is an important point. In order to be a credible basis for the Energy Plan’s roadmap for “providing clean, reliable, and lower-cost energy to all New Yorkers” the State has to prove that it is feasible. While the transportation and building sector sections provide more detail it is barely sufficient for a feasibility analysis. There clearly isn’t anything approaching a feasibility analysis for the electric power and natural gas sectors. I believe that this is partially due to the complexities of the electric and gas sectors. Unfortunately, a main driver of policy is the political calculus to incorporate social and environmental justice concerns. As a result, appeasing those interests is over-riding technological feasibility concerns.
Benefits and Costs
The following lists the benefits and costs presented with my indented and italicized comments.
- The plan discusses the range of adverse impact caused by climate change and asserts that climate change will be affected by the actions proposed in the scoping plan.
Pokalsky recently gave a presentation at the Real Cost of New York’s Climate Leadership and Community Protection Act webinar. My post on the webinar made the point that technical feasibility of wind, solar, and energy storage should be a primary concern but only one of six presenters raised that point because it is politically incorrect to argue the point. Pointing out that the Intergovernmental Panel on Climate Change technical reports don’t agree with the range of adverse impacts listed in the Draft Scoping plan and that the state has never quantified the effect of any New York GHG emission reduction program on global warming itself is even more of a politically incorrect argument.
In addition to reducing the impacts of climate change, it recognizes that the state will need to adapt to risks that cannot be avoid.
While the report provides few specifics on the cost of implementation measures, it reports on macro-level models of the cost and benefits of multiple compliance scenarios, each of which projects that benefits will significantly outweigh implementation costs, with benefits including public health benefits from improved air quality Improvements in air quality, increased active transportation, and “energy efficiency interventions” in homes generating health benefits ranging from approximately $165 billion to $170 billion. However, this analysis compares the costs of implementing this state specific scoping plan with benefits, including estimates of avoided economic damage from climate change at up to $250 billion, benefits that would require actions beyond those proposed in this scoping plan to achieve.
I have shown that the health benefits claimed exaggerate the projected values, that the estimates of avoided economic damages from climate changes are manipulated to be 5.4 times higher than other jurisdictions, and, despite all the biased calculations, the benefits are not greater than the macro-level cost estimates unless the benefits of reductions are counted multiple times. If only that error is corrected the total benefits range from negative $74.5 to negative $49.5 billion instead of positive net benefits ranging from $90 billion to $120 billion.
The scoping plan applies an analytic framework that projects approximately $140 billion in annual New York State energy system expenditures, including capital expenditures and fuel costs, representing 8.9 percent of gross state product. A significant share of that amount, including $30 billion of $50 billion in fuel costs, leaves the state. In part, the economic impact study discusses the effect of redistributing these annual expenditures to achieve the state’s renewable energy and energy efficiency objectives.
In the absence of detailed cost numbers, it is difficult to comment on the analytic framework for costs. This is a good description of what is available.
Public health benefits from reduced GHG emissions will include those related to heat, flooding and food, water, and vector-based diseases, and will result in indirect benefits from the reduction of emissions of GHG co-pollutants including particulates and various toxic emissions.
The heat, flooding, food, water and vector-based disease benefits are associated with the social cost of carbon calculations. I have prepared a white paper on these alleged benefits for anyone who wants to get into the technical details.
- The scoping plan focuses significantly on historic disparate impacts on disadvantaged communities. Throughout the document, the scoping plan references recommendations of the Climate Justice Work Group (CJWC) and the extent to which they were not adopted by the Climate Action Council.
This is an important point that I have not addressed in my work yet.
- The plan asserts that it establishes “the country’s – and perhaps even the planent’s – strongest GHG emission reduction and clean energy requirements,” and it will serve as a model for other jurisdictions.
At the end of the day, I believe that this is the only benefit of the plan. New York’s politicians will have bragging rights. Of course, the owners of the Titanic had bragging rights on their maiden voyage too.
The scoping plan will result in a cleaner environment and a more competitive economy, and will support new jobs, new businesses, and new economic opportunities. (The CAC also issued a report on projected job creation resulting from CLCPA implementation.) It contains several recommendations for retraining workers displaced by CLCPA mandates, and for offsetting any adverse economic consequences on communities impacted by the loss of facilities. It recognizes that CLCPA implementation will require an expanded, trained workforce, and supports measures such as project labor and community workforce agreements on CLCPA-related projects.
This is a primary concern for the Business Council. I have not addressed this in my work yet and given the amount of material will more than likely defer to the Business Council’s opinion.
- It recognizes the potential impact of emission leakage due to actions that increase the cost of energy, reduces the reliability of energy, or increase the cost of GHG emissions, and recommends some approaches, including credits for early action and targeted incentives.
This is another topic I have not addressed. Based on my work with Regional Greenhouse Gas Initiative emissions leakage I am pretty sure that leakage is inevitable but that the numbers can be manipulated to make it look like less of an issue.
The Business Council memo is intended to provide an overview of the most significant energy-related proposals impacting major sectors of the New York State’s economy. It does an excellent job in that regard. The memo points out that “Most businesses will be impacted by the recommendations of multiple sector-specific proposals”. The Business Council urges its members to review the scoping plan and get involved with their internal comment development process. I recommend that all New Yorkers review the plan and comment too.