Draft Scoping Plan Comments Submitted in May

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 describes comments that I submitted in May 2022 for your information and in hopes that others will be encouraged to submit their own comments. 

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.  That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

The remainder of the article lists the summaries of comments that I submitted in May 2022.

Caiazza Comment Electric Service and Distribution System Upgrades Needed for Electric Heating

I submitted these comments on May 15, 2022.  They are based on the work of Kip Hansen.  He estimated costs associated with the distribution network for upgraded residential electric service; electrical distribution system improvements so that all homes can heat with electricity and use the more usual and affordable” overnight electric vehicle chargers; and disconnecting natural gas supplies.  I applied his reference information to New York and found that these costs range from $16.8 to $43.1 billion.  These costs don’t include “the costs to homeowners, who must pay for the service upgrade, service entrance wires, and circuit breaker panel box. And, of course, does not include the purchase new appliances or the installation of EV chargers.”  This cost estimate also does not include disconnection costs for fuel oil or propane heated homes.  Finally, these estimates only apply to single family homes and not the 4.2 million housing units that are in multi-family buildings.

I believe the Draft Scoping Plan should describe all the control measures, provide references for assumptions, list the expected costs for those measures and list the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  This information is not available so I could not confirm that these costs are included in the Integration Analysis or provide the opportunity to provide meaningful comments. 

Caiazza Personal Comment on the Benefits Greater than Costs Claim 

I submitted these comments on May 30, 2022 to incorporate the cost data that was released last week. The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   In my verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading.  This comment explains why that the Draft Scoping Plan must address this issue and makes recommendations for changes to language to clarify the caveats associated with the claim.

These comments show that the trick used to deceive the public into hearing that benefits out-weigh costs excludes legitimate Climate Act costs by mis-categorizing initiatives such as the 2035 zero-emission vehicle mandate as part of the business-as-usual Reference case.  In addition, the Plan uses incorrect guidance to inflate the societal benefits of avoided emissions.  The final Scoping Plan should describe all the control measures, provide the assumptions used for the strategies, and list the expected costs and expected emission reduction for each measure for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios so the public can decide for themselves which costs associated with “already implemented” program are appropriate. 

Caiazza Personal Comments on Benefits of Climate Action

I submitted these comments on May 31, 2022 to include the information on my Citizens Guide Climate Act Effects on Global Warming Page into the record. The Draft Scoping Plan asserts that there will be benefits from the implementation of the Climate Act but provides no documentation to support that claim.  These comments highlight the claims that must either be substantiated by analysis and documentation or removed from the final Scoping Plan.

These comments include my personal analyses of the potential effect of the Climate Act on global warming and global emissions both as an example of the analysis necessary to make claims and as a cautionary tale.  The fact is that any expectation that the Climate Act will have any detectable effect on the severity of current or future climate change is mis-placed because the expected impact on global warming is an immeasurable 0.01°C by the year 2100.  If you cannot measure the change in temperature there is no way you can detect a change in the purported effects of that temperature change.

In addition, when New York’s emissions are considered in the context of global emissions it is unreasonable to expect that other jurisdictions will be encouraged to implement similar restrictions.  In the first place, New York’s emissions are less than one half of one percent of global emissions.  At the same time, New York’s 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world.  That ranking was achieved in no small part because New York has had access to abundant, reliable, and affordable energy for many years.  Expecting that countries without our wealth will be encouraged to develop costly zero-emissions energy resources is naïve and immoral.


There are not many days left until the end of the comment period.  I am planning to submit as many comments based on the work done in my blog as possible in that time.  If time were not so short, I would spend more time writing stand-alone articles for the blog.  As an alternative I am just going to copy the summary from comments submitted as a blog update every few days for the next couple of weeks.

If you are a New Yorker, I encourage you to submit comments at the Climate Act comment page.  I fear the only thing that we can count on from the comments submitted is a tally of how many people support the Draft Scoping Plan versus how many people don’t.  In New York’s political climate it is all about the numbers and not the science, technology, or expert opinion.  Just go to the page and you can enter 2000 characters of text as a comment.  If nothing else just explain that you have concerns about reliability, affordability, safety and lack of personal choice associated with the transition to net-zero.  Feel free to copy as much of my material as you want and do not feel obligated to mention the source.

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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