Draft Scoping Plan Cost Documentation Announcement

Note: This post was updated to add a revised link to the spreadsheet that lists all the clarifying information update on May 29, 2022.

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 Draft Scoping Plan that describes how to meet those goals was released to the public at the end of 2021 and the comment period is open until June 10, 2022.  This post announces the fact that the with two weeks left in the comment period the numbers that were used in the Benefits and Costs chapter of Appendix G of the documentation are now available.

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 (85% reduction and 15% offset of emissions) 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. 

Draft Scoping Plan Cost Documentation

The Draft Scoping Plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   In my recent verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading.  I recently published an article that consolidates documentation that supports my contention that the costs far exceed the benefits.  A main finding in my cost-benefit analysis is that most of the values in the supporting documentation (Section 3.4 Benefits and Costs, Appendix G Integration Analysis Technical Supplement Section I) are only presented in bar charts.  In other words, the values of the numbers are not included.

At a recent meeting there was an opportunity for the public to ask questions about the New York State Energy Research & Development Authority (NYSERDA) work supporting the Draft Scoping Plan.  I asked about the cost information and John Williams, Vice President, Policy and Regulatory Affairs, responded.  He indicated that detailed information was available and suggested that I follow up for more information.  I sent him an email asking for specific information.  I explained that, for example, in Appendix G, Section I, Figure 48 lists the net present value of system expenditures in Reference Case and Scenarios 2-4.  The only associated number given in the text is a mention that the Reference Case totals $2.7 trillion.  I said that I believe that at a minimum the values of the cost categories listed on the right-hand side of the bar charts should be available in a table somewhere for each of the scenarios.  I also said that detailed control measure costs should also be available so that the public can check the category costs and critique specifics.

On May 27 Mr. Williams responded:

In response to your inquiry for additional cost information, we have added clarifying information to the existing Excel document, “Appendix G Annex 2: Key Drivers and Outputs,” which can be found on the Climate Action Council Draft Scoping Plan website.  At the end of the workbook, you will see a series of green tabs. The “Cost Methods Overview” tab describes how costs were calculated throughout the analysis. Accompanying tabs provide the data associated with the cost figures published in the Draft Scoping Plan.

We hope this will help you and all stakeholders better understand how our cost analyses were performed.  Please reach out if there are any questions.

My hats off to Mr. Williams for responding to my request.  He is the only one in the Administration that has responded to any of my comments.

Conclusion

While I really appreciate the response it is a problem that this obvious need was not included until there are only two weeks left in the comment period.  Unfortunately, only two things were provided: the numbers associated with the cost figures in Section 3.4 Benefits and Costs of Appendix G and a table summarizing the cost methods.  I also believe that it is problematic that a casual reader would have no idea that this new information has been included in an update because the appendices listing on the Climate Act Draft Scoping Plan page does not mention that an update is available.  Finally, tacking 15 tables at the end of an already huge spreadsheet does not foster easy use.  I have extracted all the new tables in a separate spreadsheet.  The spreadsheet table summarizing the cost methods is difficult to read so I have also extracted that information in a document.

I will follow up with another post later regarding the information provided.