The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. I recently was given the opportunity to brief my New York State Senator, John Mannion, about my concerns related to affordability and reliability in the Climate Act Draft Scoping Plan. This post describes the slide presentation and provides a link to the documentation handout for it.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions 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”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.
I list the presentation slides below. The documentation summarizes what I said for each slide and provides references for the statements. I highlight some of the key points I tried to make in this description of the slides.
I tried to make the point in the following slide that most New Yorkers are unaware of the Climate Act. Not only that but fewer still understand the scope and magnitude of the changes required in order to meet the Climate Act targets and even fewer are aware of the costs, benefits, and threats to reliability inherent in the massive transition of our existing energy system to the net-zero targets of the Act. The presentation hit the points that I think the public should understand.
In my presentation I explained that I think the root problem of the Scoping Plan approach is over simplification of possible solutions. Reality is that there are many issues with every aspect of the proposed energy transition. I said that there are two particular problems with the proposed solutions: they don’t work all the time and they are more complicated than existing technology. As a result, there are ramifications that need to be considered.
I included this slide to just hit the highlights of the Act. I mentioned that the 100% zero-carbon electricity by 2040 target was a particular worry of mine.
This slide more or less presented the material in the Climate Act Background section above. I did mention that 10 public hearings have been scheduled.
The point of this slide was to point out that the transportation vision requires massive changes to the transportation system and significant limitations on personal choice. I believe that most people recognize that there are limitations to electric vehicles and have decided that they are not a viable option as the primary household vehicle even if they could afford one. The primary limitation that people in Upstate New York understand is that electric vehicles don’t work so well in cold weather. In addition, electric vehicles are more complicated because at-home charging has infrastructure requirements and another daily chore to hook the car up for charging. This is a concern for those of us who have the option to charge at home but what about all those people who park on the street or in a parking lot? Providing infrastructure for them will be very expensive.
In order to prove the Climate Act is in the best interests of the State, the Scoping Plan claims benefits. I explained that I thought that the proposed health benefits were exaggerated, that I have been unable to verify their estimates and that they are all societal benefits that will not directly affect consumer costs.
The largest benefit proposed is for avoided GHG emission impacts on climate change. I estimate that these benefits should be on the order of $60 billion dollars based on eliminating New York’s maximum annual GHG emissions overnight and multiplying by New York’s value of carbon. The Scoping Plan claims benefits of at least $235 to $250 billion by counting the benefits multiple times. This is the same as claiming that a weight loss of ten pounds five years ago represents a 50-pound reduction. Obviously, that is wrong and if that error is corrected the costs are greater than the benefits.
This graph has been shown at public comment hearings and is the support for the Draft Scoping Plan claim that “The cost of inaction exceeds the cost of action by more than $90 billion”. I explained that there were issues with cost numbers in addition to the benefits problems described previously. In particular, it is necessary to parse the language to understand how the Integration Analysis presents the costs. They are presented as net direct costs because the cost to use fossil fuels are subtracted from the costs to meet the reduction targets. The bigger issue is that the net present value of benefits and costs are presented relative to Reference Case. I admit that I did not pick up on the implications of that condition for five months. It turns out that vehicle electrification costs appear to be included in the Reference Case because the electric vehicle legislative mandate was an “implemented policy”. However, the $700 billion costs to electrify the transportation investment category are a necessary cost for the net-zero transition. I don’t think they should be included in the Reference Case because those costs are a necessary transition expense. If those costs are moved from the Reference Case to the mitigation scenarios where they belong, the costs are much greater than the benefits.
I also made the point that this graphic is representative of the abysmal cost documentation in the Scoping Plan. For the most part the only numbers provided are in bar charts like this and none of the cost category values are quantified. This inexcusable shortcoming of the Draft Scoping Plan is the subject of a post which provides more information. I believe that the cost for every category in the Draft Scoping Plan should be listed in a spreadsheet and that costs for each measure that make up the category costs should also be included. Without this information it is impossible to provide meaningful comments on the financial viability of the scenarios.
The following slide explains that corrections to the inaccurate benefits and misleading costs presented in the Scoping Plan invalidate the claim that the benefits are greater than the costs. Approximately $700 billion should be added to the net system costs column in the revised section of the table and the avoided GHG benefits should be only $60 billion. The costs are greater than the benefits by at least $760 billion.
In 2040 the electric grid is supposed to be converted to zero emissions. In order to describe potential reliability issues associated with that transition this slide and the following two slides discuss the electric grid. The point of this slide is that the electric grid is big, complex and currently dependent upon generating resources that can be dispatched by the operators who match load with generation on a minute-by-minute basis.
This slide explains that significant infrastructure is required for the transition and that it will complicate matching generation and load. Wind and solar are not dispatchable without energy storage, transmission and ancillary services resources. I pointed out that short-term variations in wind and solar require an energy storage resources that is relatively small but will be used frequently. The Li-Ion 4-hour storage batteries work well for this requirement. There are significant diurnal variations in renewable resources if solar is a major component. This needs to be addressed by energy storage resources that are on the order of the size of the solar capacity in the system. In my opinion this resource has not been implemented on a commercial scale. In addition, additional energy storage is needed for cloudy days. The resources needed for both these applications will be used regularly. The biggest problem is the energy storage needed for infrequent but extended periods of low wind and solar output. A large amount of long-term storage capacity is needed to cover a multi-day renewable resource drought but it will not be used a lot. If it is not used much how will the market pay for the resource?
If the grid operators cannot match the load with available generation, then blackouts similar to the February 2021 blackouts in Texas are inevitable. The operators task is made more difficult because load is not constant. Ultimately the problem of most concern is that the periods when the renewable resources are lowest are also periods when load is expected to be highest once home heating is electrified. This is an enormously important issue but I don’t think it has received the appropriate level of consideration by the Climate Action Council.
I recently posted an article that highlighted the content (Presentation) and conversations at a NYISO meeting on March 24, 2022 that addressed the System & Resource Outlook Update effort with the Electric System Planning Working Group. I prepared the table that shows the existing capacity, the capacity proposed for the three Draft Scoping Plan scenarios, and the base case for the Update options discussed at the meeting. One of the concerns at this meeting of New York State reliability experts was the amount of new infrastructure needed. The total of new generation required is around three times the 2021 total existing generation. That does not include the ancillary services and transmission upgrades needed. The other concern was the Zero-Carbon Firm Resource. This is the “large amount of long-term capacity needed to cover a multi-day renewable resource drought that it is not used a lot” resource needed when the loads are predicted to be highest in the future. The problem is that there isn’t any commercially demonstrated resource available today or expected for this resource in the near future. The table shows that this resource is need to provided capacity that is greater than current installed capacity. The conversation that caught my attention is when the experts said: The results are “stunning” and “Is anyone listening”. They are clearly worried and the Climate Action Council has shown no sign of concern about this issue.
There is another issue for the Council. Comparing the Draft Scoping Plan capacity resource distributions with the NYISO projected capacity shows significant differences. It is not clear how will those differences will be resolved.
Unfortunately, the Climate Action Council seems to be more concerned about activist claims to stop all new fossil fuel infrastructure than the critical need for a proven replacement. It seems to me that it would be prudent to make the implementation schedule conditional upon the availability of the necessary technology. That Council leadership has not stepped up and said that fossil fuel infrastructure is needed until we have a viable alternative is necessary is not a good sign.
Even though electric grid reliability is an important topic it also it is one that most people don’t have any experience with so I included a description of reliability and affordability related to home electrification that we all understand. Because the buildings sector is the largest source of GHG emissions, decarbonization is a primary strategy. My primary residential reliability concern is what happens when there is an extended electric outage? There is not a lot of information available about the cost affordability for residential home heating so I added slides discussing residential heating sector costs.
The primary solution for residential home heating in the Draft Scoping Plan is heat pumps: “Modern heat pumps that work in very cold weather are commercially available and able to keep homes and businesses comfortable year-round, as long as they are properly chosen, sized, and paired with an energy-efficient building envelope. “ Frankly, everything I have seen on social media from NYSERDA about heat pumps is propaganda because it only shows the benefits and does not mention any downsides. The Plan notes three caveats for success: properly chosen, sized, and paired with an energy efficient building envelope or building shell.
The unmentioned downside is the building shell requirement. The Scoping Plan analysis included two levels: basic shell – 27-44% reductions and deep shell – 57-90% reductions. The Integration Analysis projects that residential building stocks will be 66% basic shell and 26% deep shell by 2050. In my opinion the description of what is required for the two levels is inadequate. I assume that the deep upgrade must meet the international standard for passive buildings that includes following measures: Improved thermal insulation, considerably improved airtightness, use of high quality windows, reduction of thermal bridges, and ventilation with highly efficient heat recovery. In my opinion deep shells will be needed more than the Plan assumes and bringing homes up to that level will be difficult and costly.
The upper half of table in the following slide shows the Retrofit Costs based on the referenced Integration Analysis spreadsheet. According to the device costs in the Draft Scoping Plan an air source heat pump plus electric resistance backup will cost $15,818. The other option is a ground source heat pump and that costs $40,491. The unpublicized costs are $6,409 for a basic building shell improvement or $45,136 for a deep building shell improvement. Combining the two, the air source heat pump option totals $22,227 for the basic shell and $60,954 for the deep shell. For a ground source heat pump the totals range from $40,491 for a basic shell to $79,218 for a deep shell.
The lower half of table subtracts out the replacement costs of the existing system to calculate the retrofit costs. In 2030 when you can no longer purchase anything but a heat pump you won’t have to buy the replacement appliance so you can subtract that cost. For example, if you own a distillate boiler the $9,260 replacement cost can be subtracted from the component costs – an air source heat pump with a basic shell is $12,967 instead of $22,227. As with all other aspects of the implementation there is a complication. In 2030 you will have to replace your existing appliance when it breaks with a heat pump. If it breaks during the winter, you won’t necessarily be able to do a deep shell retrofit at the same time because it is a big investment in time and effort. That will be a serious imposition on the homeowner.
It is also relevant that we keep the context of New York’s emissions relative to the rest of the world vis-à-vis global warming in mind. Although activists claim New York should do something because the state is “large” relative to other countries when it comes to our economy (9th), we should also consider the fact that our emissions are small relative to many others (35th). Moreover, when you consider GHG efficiency (the country’s emissions divided by its GDP) we are already doing a good job -New York ranks third behind only Norway and Sweden.
More importantly, New York’s 2016 GHG emissions were less than one half of one percent of global emissions in 2016 and global emissions are increasing by more than one half of one percent per year. Because global emissions are increasing so much, they will replace all of our emissions completely in about a year. Therefore, I expect no change of global warming effects on weather.
The presentation concluded that everybody wants to do something about climate change and do right by the environment. However, it is important that we don’t do something that will do more harm than good when we try to address climate change. Based on my analysis of the proposed strategies in the Scoping Plan it will do more harm than good. It boils down to the fact that existing technology is just not ready for the magnitude and schedule of the transition outlined in the Scoping Plan.
I did not prepare a slide with my recommendations. I think that politicians worried about the issues raised in this presentation should submit comments to the Climate Action Council but also send a copy to Co-Chairs Doreen Harris and Basil Seggos. The Council has to be made aware that there are real concerns from the public and I encourage public comments to the comment portal.
I suggest comments on a couple of topics. There have been suggestions that the Council will setup workshops on particular issues. I am going to submit a comment that includes a request for full disclosure on particular issues. Too often in the past only one side of the story has been heard. I think the workshops should be used to provide stakeholders with a venue to ask questions and get answers. When the meeting is announced it should offer an opportunity for stakeholder questions to be submitted before hand so that they can be addressed during the workshop. In my opinion workshops on the following topics would be appropriate: how reliability concerns in the electricity sector will be addressed and resolved, cost benefit calculations, residential electrification, and transportation strategies.
I am also going to submit a comment arguing that the Council has to make reliability and affordability a priority. As shown in the presentation it seems prudent that the implementation schedule should be conditional based on the availability of proven technology needed for reliability per experts from NYISO and NYS reliability council. The Council has to make it a priority to listen to the experts who are responsible for New York reliability. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. That is exactly what we will be doing if the Council does not listen to the experts.
I am also going to submit a comment saying that the Draft Scoping Plan cost documentation is inadequate. The cost categories for every cost in every figure in the Scoping Plan should be documented in a spreadsheet that lists the totals, the cost categories within the total,s and the costs for each measure that is included in the cost categories.
The Council should also establish criteria for reliability and affordability. The reliability criteria should define the implementation schedule conditions. They should provide guidelines for the NYISO and NYS Reliability Council definition of acceptable technology such as for the “Zero-carbon firm resources”. For example, technology X has been proven commercially on the scale necessary for New York’s requirements so we can proceed with implementation that requires it. Until a technology is available there has to be a hold on the schedule. Similarly, the Council should define affordability thresholds. For this parameter, the number of service disconnects or percentage of New Yorkers in fuel poverty should not be greater than value X would be appropriate conditions.
I listened to the introduction of one of the public hearings and the overview presentation was mostly an advertisement for the Climate Act. There was no suggestion that there might be issues associated with reliability. The machinations that “prove” that the benefits are greater than the costs indicate that the analysis was done so they claim a pre-determined conclusion. I hope that this overview gives readers a taste of the reasons why I am convinced that without changes the impacts of this so-called solution will be worse than the effects of climate change. Anything we do will be displaced in a year, cost a lot of money and risk catastrophic blackouts.
If any reader is interested in having me give this presentation to a group, let me know at NYpragmaticenvironmentalist@gmail.com.