Climate Act Draft Scoping Plan Scenario Components

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. The comment period for the Draft Scoping Plan is open until June 10, 2022.  The Council requested feedback on the components of three mitigation scenarios.  This is an overview summary of the components.  I plan to describe the components by sector in more detail in future posts.

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 Climate Act 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.

Integration Analysis Reference Case and Scenario 1

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates.  The primary reference for the scenario descriptions is Appendix G Section I: Techno-Economic Analysis (Section I).  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)” (Section I p.11). The initial analysis found that the Advisory Panel recommendations in Scenario 1 did not meet the Act emissions limits (Figure 1).

There is another aspect to Figure 1.  In order to understand the true impact of these scenarios it is important to know what is included and what is not included.  In particular the Reference Case has “a business-as-usual forecast plus “implemented policies”.  The inclusion of implemented policies in the Reference Case means that many New York State policies that exist only to meet climate goals are not included in the expected costs for the Climate Act itself. 

Figure 1: Screen capture of Figure 4 and its foornote on Section I – page 12.  Note that there is no caption for the figure but there is a footnote.  The footnote is the primary reference for the definition of the Reference Case

The footnote for the preceding figure states that the Reference Case includes a business as usual forecast plus implemented policies, including but not limited to federal appliance standards, energy efficiency achieved by funded programs (Housing and Community Renewal, New York Power Authority, Department of Public Service, Long Island Power Authority, NYSERDA Clean Energy Fund), funded building electrification, national Corporate Average Fuel Economy standards, a statewide Zero-emission vehicle mandate, and a statewide Clean Energy Standard including technology carveouts.  The following table from Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions lists specific programs in the Reference Case.  In order to provide a full accounting of the control measures the Scoping Plan documentation should include a description, the emissions reductions expected, and the costs expected for each of the scenarios.  That information is not provided so the Draft Scoping Plan is fatally flawed.

Figure 2: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Integration Analysis Mitigation Scenarios

The consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   Figure 3 lists the control measures used. The three mitigation scenarios are described in Section I on page 14:

Transformative levels of effort are required across all sectors, and all three scenarios include high levels of electrification, including Scenario 2, which also incorporates the strategic use of low-carbon fuels. Scenario 3 pushes harder on accelerated electrification to meet the emission limits using a very low bioenergy and low-combustion mix of strategies. Scenario 4 pushes beyond 85% direct reductions in 2050 by layering some low-carbon fuels back in, examining very high VMT reduction, and assuming high (but also highly uncertain) levels of innovation in the waste and agriculture sectors. Scenario 4 is the only evaluated scenario that achieves carbon neutrality without the use of negative emissions technologies like direct air capture of CO2, which is also subject to high uncertainty, but is required in Scenarios 2 and 3 to address the gap between remaining gross emissions in 2050 and the ambitious assumed projections of natural sequestration.

Figure 3: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Chapter 9 of the Draft Scoping Plan includes four figures (starting at page 72) that list projected emission reductions and the strategies employed to achieve them for all four scenarios.  The following text reproduces the figures and extracts the sector strategies for multiple dates in the timeline in order to show how the strategies differ between the scenarios.

Scenario 1: Advisory Panel Recommendations

Representation of the Advisory Panel recommendations, which provide a foundation for all scenarios; however, scenario modeling shows that further effort is needed to meet Climate Act emission limits.

Figure 4: Draft Scoping Plan Page 72

2022

• Buildings
  • Increased sales of high efficiency appliances and smart devices
  • Start ramping up sales of heat pump space heaters and water heaters
  • Bioheat blends in NYC buildings
• Transportation
  • Start ramping up sales of zero-emission light-duty vehicles

2025

• Oil and Gas Sector
  • Leak detection
  • Strategic pipeline decommissioning

2030

• Buildings
  • All new sales of single-family and low-rise residential heating systems are heat pumps
  • 0.9 million homes electrified with heat pumps
  • 13% of all homes have efficient shell upgrades
  • 15% renewable natural gas in pipeline
• Transportation
  • 1.8 million zero-emission light-duty vehicles
  • 3% renewable diesel
• Generation
  • 70% clean energy standard
  • 3.6 GW battery storage
• Hydrofluorocarbon (HFC)
  • Adoption of ultra-low global warming potential technologies

2035

• Buildings
  • All new sales of multi-family and commercial heating systems are heat pumps
• Transportation
  • All new sales of light-duty vehicles are zero-emission

2040

• Generation
  • 100% zero-emission electricity
• Transportation
  • All new sales of medium and heavy duty vehicles are zero-emission

2050

• Waste
  • 100% waste diversion
  • Methane capture
• Agriculture
  • Mitigation in animal feeding, manure management and soils
• Industry
  • 33% of natural gas use electrified
  • Hydrogen use
  • Carbon capture and sequestration for all cement and iron&steel facilities
• Aviation
  • 100% renewable natural gas, renewable distillate and renewable jet fuel
• Forestry
  • Forest sequestration returnes to 1990 levels (-35 MMT)

Scenario 2: Strategic Use of Low-Carbon Fuels

Advisory Panel recommendations adjusted for strategic use of bioenergy derived from biogenic waste, agriculture and forest residues, and limited purpose grown biomass, as well as a critical role for green hydrogen for difficult-to electrify applications. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 5: Draft Scoping Plan Page 72

Italicized items are changes from Scenario 1

2022

• Buildings
  • Increased sales of high efficiency appliances and smart devices
  • Start ramping up sales of heat pump space heaters and water heaters
  • Bioheat blends in NYC buildings Scenario 2 eliminates bioheat blends
• Transportation
  • Start ramping up sales of zero-emission light-duty vehicles

2025

• Oil and Gas Sector
  • Leak detection
  • Strategic pipeline decommissioning

2030

• Buildings
  • All new sales of single-family and low-rise residential heating systems are heat pumps.
  • 1.5 instead of 0.9 million homes electrified with heat pumps
  • 25% instead of 13% of all homes have efficient shell upgrades
  • 9% instead of 15% renewable natural gas in pipeline
  • There is no figure that provides similar information for the Reference Case so it is not clear, for example, how many homes are electrified with heat pumps in the Reference Case
• Transportation
  • 2.7 instead of 1.8 million zero-emission light-duty vehicles (90% new sales)
  • 100% zero-emission bus sales
  • 75% renewable distillate instead of 3% renewable diesel
• Generation
  • 70% clean energy standard
  • 3 GW instead of 3.6 GW battery storage
• HFC
  • Adoption of ultra-low global warming potential technologies

2035

• Buildings
  • All new sales of multi-family and commercial heating systems are heat pumps
• Transportation
  • All new sales of light-duty vehicles are zero-emission

2040

• Generation
  • 100% zero-emission electricity
• Transportation
  • All new sales of medium and heavy duty vehicles are zero-emission

2050

• Waste
  • 100% waste diversion
  • Additional methane capture
• Agriculture
  • Mitigation in animal feeding, manure management and soils
  • Future R&D
• Industry
  • 33% of natural gas use electrified
  • Hydrogen use
  • Carbon capture and sequestration for all cement and iron&steel facilities
• Aviation
  • 100% renewable natural gas, renewable distillate and renewable jet fuel
• Forestry
  • Forest sequestration returnes to 1990 levels (-35 MMT)
• Negative Emission Technology, for example, direct air capture
  • -26 MMT

Scenario 3: Accelerated Transition Away from Combustion

Advisory Panel recommendations adjusted to include a very limited role for bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 6: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 2

2022

• Buildings
  • Increased sales of high efficiency appliances and smart devices
  • Start ramping up sales of heat pump space heaters and water heaters
• Transportation
  • Start ramping up sales of zero-emission light-duty vehicles

2025

• Oil and Gas Sector
  • Leak detection
  • Strategic pipeline decommissioning

2030

• Buildings
  • All new sales of single-family and low-rise residential heating systems are heat pumps
  • 1.8 instead of 1.5 million homes electrified with heat pumps
  • 25% of all homes have efficient shell upgrades
  • Early retirement of old heating systems
  • 4% instead of 9% renewable natural gas in pipeline
• Transportation
  • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
  • Early retirement of old vehicles
  • 100% zero-emission bus sales
  • 75% renewable distillate instead of 3% renewable diesel
• Generation
  • 70% clean energy standard
  • 3 GW battery storage
• HFC
  • Adoption of ultra-low global warming potential technologies

2035

• Buildings
  • All new sales of multi-family and commercial heating systems are heat pumps
• Transportation
  • All new sales of light-duty vehicles are zero-emission
  • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

• Generation
  • 100% zero-emission electricity
• Transportation
  • All new sales of medium and heavy duty vehicles are zero-emission

2050

• Waste
  • 100% waste diversion
  • Additional methane capture
• Agriculture
  • Mitigation in animal feeding, manure management and soils
  • Future R&D
• Industry
  • 83% instead of 33% of natural gas use electrified
  • Hydrogen use
  • Carbon capture and sequestration for all cement and iron&steel facilities
• Aviation
  • 100% renewable natural gas, renewable distillate and renewable jet fuel
  • Limited reuse of captured methane
• Forestry
  • Additional afforestration and forest management -40 MMT instead of -35 MMT
• Negative Emission Technology, for example, direct air capture
  • -20 MMT instead of -26 MMT

Scenario 4: Beyond 85% Reduction Advisory Panel recommendations adjusted to reflect accelerated electrification and targeted use of low-carbon fuels. This scenario includes additional reductions in VMT and innovation in methane abatement. This scenario reduces gross GHG emissions beyond the 2050 limit and avoids the need for negative emission technologies.

Figure 7: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 3

2022

• Buildings
  • Increased sales of high efficiency appliances and smart devices
  • Start ramping up sales of heat pump space heaters and water heaters
• Transportation
  • Start ramping up sales of zero-emission light-duty vehicles

2025

• Oil and Gas Sector
  • Leak detection
  • Strategic pipeline decommissioning

2030

• Buildings
  • All new sales of single-family and low-rise residential heating systems are heat pumps
  • 1.8 instead of 1.5 million homes electrified with heat pumps
  • 25% of all homes have efficient shell upgrades
  • Early retirement of old heating systems
  • 7% instead of 4% renewable natural gas in pipeline
• Transportation
  • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
  • Early retirement of old vehicles
  • 100% zero-emission bus sales
  • 7% renewable distillate
• Generation
  • 70% clean energy standard
  • 3 GW battery storage
• HFC
  • Adoption of ultra-low global warming potential technologies

2035

• Buildings
  • All new sales of multi-family and commercial heating systems are heat pumps
• Transportation
  • All new sales of light-duty vehicles are zero-emission
  • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

• Generation
  • 100% zero-emission electricity
• Transportation
  • All new sales of medium and heavy duty vehicles are zero-emission

2050

• Waste
  • 100% waste diversion
  • Additional methane capture
• Agriculture
  • Mitigation in animal feeding, manure management and soils
  • Future R&D
• Industry
  • 83% of natural gas use electrified
  • Hydrogen use
  • Carbon capture and sequestration for all cement and iron&steel facilities
• Aviation?
  • 100% renewable natural gas and renewable distillate
  • 71% renewable jet fuel
  • Limited reuse of captured methane
• Forestry
  • Additional afforestration and forest management -40 MMT instead of -35 MMT
• Negative Emission Technology, for example, direct air capture
  • -20 MMT instead of -26 MMT
• Additional innovation in methane mitigation and natural sequestration

Conclusion

There are only a couple of things to mention.  I have noticed that anyone who has addressed the Council request for feedback on the components of the three mitigation scenarios has advocated for Scenario 3, Beyond 85% reductions.  Given the paucity of information available I can only assume that they supported it because it sounded more stringent. 

The list of control measures that are included in the Reference Case, and thus don’t show up as direct costs for the Climate Act, includes multiple measures that only exist as part of the State’s initiatives to address climate change.  I think that is a semantic trick that disguises the real costs of the transition to net-zero because it is clear that the costs associated with at least some of those measures are not included in the cost-benefit analysis.  Because the control measure descriptions, emission reductions and costs are not provided in detail, it is impossible to determine how many are misleadingly categorized to be able to claim that the Climate Act benefits are greater than the costs.  It is also impossible to determine if the Draft Scoping Plan excluded the emission reduction benefits associated with those measure.  If their costs were not included then it is wildly inappropriate to not exclude the benefits from the cost-benefit analysis.  There is no indication that those emission benefits were excluded.

In future posts I will address specifics associated found in specific sectors.  From what I have seen so far there are plenty of concerns.