Draft Scoping Plan Comments on Electric Vehicles

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 plans for this transition are described in the Draft Scoping Plan. This post discusses the comments I submitted on electric vehicles in the transportation sector discussion of the Plan.

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 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 July 1, 2022.

I prepared the comments described here because I found that the Integration Analysis is simply making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  I am convinced that the Integration Analysis future energy system modeling did not consider feasibility in any of its projections.  Instead, the analysts simply tweaked projection assumptions until they got the reductions they needed. 

Cost Issues

The Integration Analysis projections for electric vehicle costs start in 2020.  Note, however, that 2020 is a modeled year,” reflecting historical trends”.  I don’t think that the observed data in 2020 and 2021 is consistent with the model projections. For one thing the analysis projects a decrease in the EV costs and this was not observed.  In my comments I recommended that the final Scoping Plan address those discrepancies. 

As far as I can tell, the electric vehicle costs are based entirely on new vehicle sales. There is no acknowledgement that the used car market will likely change because of the cost of battery replacement.  Sellers will likely get less relative to new cars in the battery electric vehicle market.  Buyers may get a relative deal but will lose in the end when the batteries have to be replaced.

My comments analyzed the Integration Analysis spreadsheet documentation.  The total costs for vehicles and a charging system for each new zero-emissions vehicle for the Reference Case are shown at the top of the Light Duty Vehicles Total New Vehicle Costs of Vehicles and Chargers table.  The cost from 2020 to 2050 is $619.6 billion.  The scenario minus reference case costs are listed for each scenario in the lower section of the table.   The biggest problem is that the device costs for zero-emissions charging technology and the vehicles themselves is presumed to decrease significantly over time.  Home EV chargers and battery electric vehicles both are claimed to go down 18% between 2020 and 2030.  The cost decreases are so large that the total costs for the zero-emissions vehicles adoption is cheaper than using existing technology by $44 billion for Scenario 2 and $37.8 billion for Scenarios 3 and 4.

One issue I have with the Integration Analysis spreadsheets is that the data provided cannot be used to reproduce the total numbers.  For example, the device costs for different types of medium-duty trucks, heavy-duty trucks, and buses are listed.  To get those cost, device prices have to be multiplied by the sales for each category.  The Integration Analysis spreadsheet provides the sales for combined medium and heavy-duty vehicles.  Without knowing how those totals are broken down by the device cost categories it is impossible to estimate the total costs.

Even without being able to calculate the costs for those vehicles there is an apparent inconsistency with the recently released net present value of system expenditures.  The transportation investment cost for the Reference case in Figure 48 is $1,056 trillion and the costs for the mitigation scenarios are higher by between $3 and $40 billion.  As shown above light-duty vehicle costs relative to the Reference Case are lower by $38 to $40 billion.  As noted above, I cannot provide precise numbers for the medium-duty trucks, heavy-duty trucks, and buses category but the device costs decrease similarly to the light duty vehicles.  I guess the costs would be an order of magnitude less.  Consequently, I am comfortable saying that the mitigation scenarios are projected to be $40 billion less than the Reference Case.  I could find no cost numbers for the other components of the transportation category such as aviation, public transit and railroads.   Light-duty vehicles account for two thirds of the total transportation sector emissions and the total costs for the light duty vehicles in my estimate of costs is about the same fraction. As a result, I don’t expect that the costs for the other sectors will be so large to account for the difference between reference case in Figure 48 $3 to $40 billion and my estimates which are negative $40 billion.  Simply put, the costs are included in the Reference Case for the cost benefit analysis in Figure 48 and the Integration Analysis spreadsheets costs are inconsistent.

Implementation Issues

There is no bigger disconnect between the ZEV proposed strategy and reality than the ZEV charging infrastructure requirements.  The biggest problem is the millions of cars will have to rely on chargers that cannot be dedicated for the owner’s personal use because the owners park on the street or in parking lot.  In order to provide a credible ZEV strategy, the final Scoping Plan has to describe a plan how this could possibly work.  The Integration Analysis simply presumes that it will work.

The Draft Scoping Plan assumes without documented analysis that zero-emissions trucks will be viable alternatives to current equipment.  It is not enough to say they are viable because they have started to appear on the market.  They must be tested.  Moreover, there is no recognition that the trucking industry is nation-wide.  If the proposed zero-emissions technologies costs are cheaper and don’t impose marked changes to operations then everyone will convert because it is a better solution.  However, if it is not a better, cheaper solution that drives adoption of zero-emissions vehicles everywhere what is the plan for out-of-state vehicles?   I cannot imagine that trucks will have to meet New York registration requirements if they are just passing through the state.  If deliveries to New York must use zero-emissions vehicles that would mean swapping the motive power and that would markedly increase costs.  Because of its importance to the viability of the Integration Analysis the final Scoping Plan should account for these issues.

My analysis of the Integration Analysis spreadsheet documentation showed another issue.  The analysis presumes an unprecedented adoption rate for light-duty electric vehicles but provides no reason why this is possible.  Anecdotally, I don’t want to accept the downsides of an electric vehicle for my lifestyle and the vast majority of my friends feel the same way.  Where is the evidence that people will willingly choose zero-emissions vehicles?

Public Engagement

A common theme in the Draft Scoping Plan is that any doubts that the public has about any aspect of the net-zero transition can be simply addressed by convincing them with appropriate information.  I guess the Draft Scoping Plan assumes that this will drive the adoption rate.  The problem is that the draft Scoping Plan only tells one-side of the story instead of presenting all the issues and making a case for their preferred approach.  Simply put, that is propaganda and it has no place in the Scoping Plan.

There is another disconnect between the public and the Climate Action Council when it comes to grid-interactive assets. This refers to using electric vehicle batteries as storage for the grid at times when the grid needs the power.  I am positive very few people know about this component of the plan and cannot imagine public acceptance when they are told about it.  The concept is that their vehicles will be grid-interactive assets and that means that they will lose control of their vehicle’s range because someone, somewhere decides that the power they have stored in their car for their own use is needed somewhere else.  The personal inconvenience of that loss of control is a losing proposition in my opinion.

There are many specific issues with zero-emissions vehicles that are not addressed in the Draft Scoping Plan.  As the United Kingdom implements their own EV mandates electric system upgrade costs have become obvious.  California is leading New York in EV adoption but there are warning signs that implementation is not working out as expected.  None of the apparent unintended consequences are addressed.  Safety issues related to fires are becoming an issue but the Draft Scoping Plan does not recognize the issue. 


I think that the transportation sector strategies in the Draft Scoping Plan are mostly wishful thinking.  As the technology stands now it will be a long time before there isn’t a cost premium to get comparable vehicle capabilities for both new and used vehicles.  The Integration Analysis projected deployment rates and device costs are both overly optimistic.  The final Scoping Plan should present bounded estimates of costs and impacts and provide documentation that describes the positive and negative issues associated with electric vehicle deployment.  The documentation has to make its case relative to the other side of the story and not simply ignore that there are any downsides or uncertainties.  I am particularly concerned that the feasibility of the planned transition relative to affordability and reliability has been ignored.

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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