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 but is anything but a pragmatic approach. Everyone wants to do right by the environment to the extent that they can afford and not be unduly burdened by the effects of environmental policies. Similarly, there certainly is a risk associated with climate change that popular opinion wants to address. This post highlights a couple of recent articles that I believe should be incorporated into a pragmatic alternative to the Climate Act.
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
As shown in the following overview summary. the Climate Act establishes a “Net Zero” target by 2050, various renewable energy mandates, a social equity component, and, of particular concern to me, a requirement for zero-carbon electricity by 2040. 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 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 describes the strategies to achieve the mandates. It was released for public comment on December 30, 2021, and comments on the draft can be submitted until June 10, 2022.

Alternate Climate Change Policies
My Citizens Guide to the Climate Act is intended to be a layman summary of the difficulties of a net-zero transition. I have posted articles recommending books that do a much better job than I have done to explain the problems here and here. Unfortunately reading a book is a big commitment and recently I described an article, Inconvenient Truths About Energy, that describes most of the issues that worry me. In brief, the consensus of all the authors of these recommendations argue that New York’s plans will cost a lot, hurt the world’s poor, and fail to fix the issues.
This post highlights two articles that are consistent with what I think would constitute a pragmatic approach to climate change. In “A ‘Plan B’ for addressing climate change and the energy transition” Judith Curry describes problems with all net-zero energy transition programs. On March 10, 2022 Doomberg published “A Serious Proposal on US Energy” that described four energy priorities.
Plan B
Judith Curry’s article describes the popular narrative that there is a climate change crisis and sums up the problem with the Climate Act and all net-zero energy transition programs:
“In a nutshell, we’ve vastly oversimplified both the problem of climate change and its solutions. The complexity, uncertainty, and ambiguity of the existing knowledge about climate change is being kept away from the policy and public debates. The dangers of manmade climate change have been confounded with natural weather and climate variability. The solutions that have been proposed for rapidly eliminating fossil fuels are technologically and politically infeasible on a global scale.”
She continues the discussion of the current state of the science and makes another important point that argues for a more pragmatic approach to potential climate change impacts. The Intergovernmental Panel on Climate Change (IPCC) modeling “projections neglect plausible scenarios of natural climate variability, which are acknowledged to dominate regional climate variability on interannual to multidecadal time scales”. Natural climate variability accounts for most of impacts of the extreme weather events that “prove” the need for immediate action. Ultimately “emissions reductions will do little to improve the climate of the 21st century – if you believe the climate models, most of the impacts of emissions reductions will be felt in the 22nd century and beyond”. The emotional plea that we have to do something immediately for our children and grandchildren is not supportable.
The article goes on to address the urgency for the energy transition. She defines Plan A as the attempt to reach net-zero in carbon emissions by 2050. It is based on the precautionary principle that “rapidly reducing CO2 emissions is critical for preventing future dangerous warming of the climate”. The Climate Act rationale is that there is a crisis. However, Curry points out:
Note that the IPCC itself does not use the words ‘crisis’, ‘catastrophe’, or even ‘dangerous’; rather it uses the term ‘reasons for concern.’ Apart from the scientific uncertainties, the weakest part of the UN’s argument about manmade global warming is that it is dangerous. The highest profile link to danger relies on linking warming to worsening extreme weather events, which is a tenuous link at best.
Curry raises another important point:
All other things being equal, everyone would prefer clean over dirty energy. However, all other things are not equal. We need secure, reliable, and economic energy systems for all countries in the world. This includes Africa, which is currently lacking grid electricity in many countries. We need a 21st century infrastructure for our electricity and transportation systems, to support continued and growing prosperity. The urgency of rushing to implement 20th century renewable technologies risks wasting resources on an inadequate energy infrastructure, increasing our vulnerability to weather and climate extremes and harming our environment in new ways.
The article goes on to discuss a Plan B:
The problem is with the urgency of transitioning away from fossil fuels, driven by fears about global warming. By rapidly transitioning to this so-called clean energy economy driven by renewables, we’re taking a big step backwards in human development and prosperity. Nations are coming to grips with their growing over dependence on wind and solar energy. Concerns about not meeting electricity needs this winter are resulting in a near term reliance on coal in Europe and Asia. And we ignore the environmental impacts of mining and toxic waste from solar panels and batteries, and the destruction of raptors by wind turbines and habitats by large-scale solar farms.
She goes on to argue:
Here’s a framework for how we can get to a Plan B. A more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation. Whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.
So what does a Plan B actually look like? Rather than top-down solutions mandated by the UN, Plan B focuses on local solutions that secure the common interest, thus avoiding political gridlock. In addition to reimagining 21st century electricity and transportation systems, progress can be made on a number of fronts related to land use, forest management, agriculture, water resource management, waste management, among many others. Human wellbeing will be improved as a result of these efforts, whether or not climate change turns out to be a huge problem and whether or not we manage to drastically reduce our emissions. Individual countries and states can serve as laboratories for solutions to their local environmental problems and climate-related risks.
A Serious Proposal on US Energy
As good as Dr. Curry’s article is, it is short on specifics for an alternate implementation plan. The Doomberg article provides some specifics. The article proposes four priorities to address the direct connection between energy and economic power. My proposed plan incorporates three of the priorities.
Not so long ago the idea that natural gas could be used a bridge fuel until aspirational technology that had zero emissions but could maintain current reliability standards was generally accepted as a rational approach. Doomberg quotes EQT CEO Toby Rice with what has happened to the natural gas industry: “You’re in a situation today where I think it’s very hard pressed for companies to be incentivized to go out and develop this large-scale infrastructure that this country needs, this world needs because of the regulatory uncertainty and just the pressure we get from anti-fossil fuel, keep-it-in-the-ground groups that are out there.” Doomberg argues that “It is time to put an end to nuisance lawsuits, regulatory inertia, and environmental radicalism” because expanding the use of natural gas provides immediate benefits. “It borders on criminal negligence that much of the Northeast burns oil to heat their homes” New England relies on foreign sources of not only oil but natural gas because of a lack of infrastructure. New York State decisions blocking pipelines have materially contributed to this negligence.
Doomberg’s second priority would expand the production of a crucial component of solar cells:
With the natural gas industry unleashed, the President should make co-located production of polysilicon another national priority. The US blundered into allowing China to secure a dominant position in this critical market, and it is time to reverse that error. Making solar cells is incredibly energy-intensive, and cheap natural gas is the ideal feedstock. There’s going to be huge demand for solar in the decades ahead, and the only thing stopping the US from being the preferred global supplier is a lack of polysilicon production capacity.
The single stupidest New York decision related to zero-emissions energy is the closure of two nuclear stations. The Shoreham plant was completed but closed in 1989 before it operated. Indian Point was closed before its operating license expired removing 2,000 MW of the only zero-emissions capacity that can be expanded at the scale needed for New York’s electric system. The third Doomberg priority proposes a commitment to nuclear power. In particular, “accelerate the development and deployment of small modular reactors (SMRs), which are safer, cheaper, and quicker to bring online than traditional nuclear power plants”.
Finally, Doomberg argues that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead”. The reason: “there simply aren’t enough battery materials available to support the conversion of a substantial portion of our automotive fleet to full electric.” It is ludicrous to not recognize that battery materials are a constraint, and that we must manage to that constraint.
Pragmatic Environmentalist Alternate Plan
The basis of my recommendations is my belief that the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology, that there is little additional risk for a policy that emphasizes innovation over implementation at this time, and that doing “good enough” will address many of the problems that the Climate Act purports to address. In short, my alternate plan would incorporate the natural gas, nuclear, and pivot away from BEV Doomberg priorities. A recent article summarizes my fears that the Climate Act “solutions” are worse than the problem and his alternative priorities are more appropriate.
The ultimate problem with a transition of the electric grid that depends upon intermittent wind and solar generation is that there are extended periods when those resources are low. Electric resource capacity planners have identified the need for a dispatchable emissions-free resource (DEFR) for those periods. Unfortunately, there is nothing available at this time that meets the characteristics needed for that resource.
I recently published an article describing my pragmatic principles as they relate to the Climate Act and I will mention several here. Gresham’s Law of Green Energy shows that reliance on subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth. I recommend a deployment plan that makes wind and solar implementation conditional upon the development of viable DEFR before any further deployment. There is no sense going down that path until the required technology is unavailable. In the meantime, inherent subsidies should be discarded. New York’s electric markets should pay very little for any generating resource that is not dispatchable and discount “semi-dispatchable” resources that cannot guarantee availability during periods of high expected demand. In this approach solar net metering would be eliminated and the subsidies for the Champlain Hudson Express project would be much reduced because power is not guaranteed during the winter.
The Pareto principle or 80-20 rule states that 20% of efforts or inputs can yield 80% of the results or outputs and exemplifies “good enough”. The Doomberg priority that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead” is a great example of the value of that principle. I also believe that going all in for natural gas as suggested by Doomberg should be a priority. New York’s irrational jihad against natural gas is not in the best interests of the state.
One of the problems highlighted in the Draft Scoping Plan is the effects of diesel exhaust on environmental justice communities. The aspirational goal to convert tractor trailer trucks to zero-emissions BEVs is such a great leap forward in technology that it could be years, if ever, before it could be viable. Conversion to PHEV trucks could resolve some of the issues but the development and deployment of compressed natural gas (CNG) trucks is further along. Encouraging CNG trucks and cars would provide immediate reductions in inhalable particulate and ozone ambient concentrations. This is a real problem as opposed to the contrived problems claimed from the use of natural gas that are incorporated into the Climate Act.
There is another viability aspect of the need for DEFR that should be considered. One of my pragmatic principles is that we can do almost anything we want, but we can’t do everything. New York’s reliability experts are worried about the quantity of generating capacity that is needed to meet the 2040 goal of a zero-emissions electric grid in general. However, the fact that recent analyses project that the quantity of DEFR needed is on the order of the entire existing generation capacity raises a financial concern. The only time that DEFR is needed is when there is lull in wind and solar resource availability. When the costs for that high quantity but low-capacity requirement are determined it may be so high that New York will be unable to address other pressing environmental issues.
Conclusion
Three books support the conclusions of the articles referenced here: “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet” by Bjorn Lomborg; “Apocalypse Never – Why Environmental Alarmism Hurts Us All” by Michael Shellenberger; and “Unsettled: What Climate Science Tells Us, What It Doesn’t, and Why It Matters” by Steven Koonin. The referenced articles make a compelling case that the Climate Act is simply not good policy. Dr. Curry explains that the claims of a crisis are not backed up when the veneer of the climate change “science” narrative is peeled back to the fundamental findings. This obviates the need to charge ahead deploying today’s renewable technologies. The Doomberg article offers serious solutions for the energy system.
I believe that existing technology is just not ready to meet the ambitions for a zero-emissions economy embodied in the Climate Act. I concur with Dr. Curry that a “more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation” and that “whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.” My pragmatic approach would make deployment of wind and solar contingent upon the development of a viable DEFR technology. The development of a new and hopefully more viable nuclear generating technology such as small modular reactors should be a priority even if a DEFR solution is found. There are many advantages of natural gas that make it ideal for intermediate and peak load uses on the electrical grid; residential heating, cooking, hot-water, and backup electric generators; and as vehicle fuel. It is not perfect because there are some emissions but when considered on a fair reliability, affordability, and environmental impact basis it deserves to be part of a sustainable solution to minimize overall global impacts and improve human well-being.
I have no illusions that the Climate Act will be modified to incorporate nuclear and natural gas as priorities with the current administration and legislature. However, when the costs are finally publicized to the general public or even worse show up on utility bills, we will see how much New Yorkers are willing to pay for achieving greenhouse gas emission reduction objectives and whether that willingness has limits. I have long maintained that the costs will be too much and that there will be “yellow-vest” protest response.