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. I was interviewed for a segment on the electric vehicle component of the Climate Act on Spectrum Cable’s Capital Tonight program hosted by Susan Arbetter. This post provides documentation for the information I provided in the interview and expands on some comments that could not be covered completely.
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. This blog emphasizes that pragmatic environmentalism is all about balancing the risks and benefits of both sides of policy issues. 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 Leadership and Community Protection Act (Climate Act) is New York’s response to climate change. The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “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. The deadline for submitting comments is July 1, 2022
Climate Act Transportation Sector Strategies
The Climate Action Council strategies to achieve net-zero are described in the Draft Scoping Plan document. The overall plan to reduce greenhouse gas (GHG) emissions is to electrify as much as possible and produce the electricity using mostly wind and solar generation. Electrification is also a key component of the transportation sector strategy. Chapter 11 explains that the reductions in the transportation sector are important because the transportation sector emits 27% of the total GHG emissions, second only to buildings.
According to Table 8 from the Plan, there are four themes to the transportation sector emission reduction plan. The first, transitioning to ZEVs and equipment, was the focus of the interview. Both the enhancing public transportation and mobility alternatives and smart growth and mobility-oriented development themes aim to lower emissions by reducing the use of personal vehicles. The last theme, market-based solutions and financing, addresses paying for the strategies. The interview discussed personal vehicles so I am going to focus on light-duty vehicles.
The transportation sector theme transitioning to ZEVs and equipment has two strategies. The first, Light-Duty ZEV Adoption, proposes to transition light duty vehicles to battery electric or hydrogen fuel cell power. Note that because hybrid vehicles still use some fossil fuel, they are not acceptable. The second theme, Adoption of Zero-Emission Trucks, Buses, and Non-Road Equipment, is very similar to the light-duty vehicle strategy except for different kinds of vehicles.
The Integration Analysis developed three scenarios for meeting the Climate Act targets. I recently did a post summarizing the differences between those scenarios and the reference or business-as-usual case for the transportation sector. I based my analysis on the Annex 2: Key Drivers and Outputs Spreadsheet. The spreadsheet Tab: Scenario Definitions lists specific programs in the Reference Case which I summarized in Table 1.
The first question addressed in the interview is when is this supposed to happen. There is legislation in place that mandates that all new vehicles sold in 2035 must be zero-emissions vehicles (ZEVs). At this time only 5% of vehicles sold are zero-emissions. The expected transition over time varies between the three mitigation scenarios but note that in 2030 the Integration Analysis projects that over 90% of the vehicles sold will be ZEVs. The sales transition to ZEVs is expected to occur naturally. In other words, the expectation is that enough people will be willing to purchase ZEVs that this won’t need to be regulated before 2035. However, note that the mitigation scenarios expect that in 2025, 33% of all vehicles sold will be ZEVs. Also note that two of the mitigation scenarios propose to accelerate the adoption of ZEVs and reduce emissions faster by mandating early retirements in 2030. I believe that it is overly optimistic to expect that one of every three cars will be a ZEV in three years so it is possible that if not enough people are willing to shift to ZEVs that New York may believe it is necessary to eventually add early retirement regulations.
Another question addressed in the interview was how much will this cost. I explained that the Integration Analysis documentation in the Scoping Plan says that in 2022 diesel/gas vehicle cost is $31,787 and battery electric vehicle cost is $41,646. Note that the Draft Plan projects that battery electric vehicles will be cheaper than gas/diesel by 2028: diesel/gas cost is $32,514 and battery electric is $31,951. That is an optimistic ~5% per year decrease in costs. The following table from Inside EVs lists the costs of battery electric vehicles on September 18 2022. There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.
There is another important vehicle cost issue. I think there is an omission in the Draft Scoping Plan because they only talk about new car sales. There is no discussion how the used car market will change. Because batteries will have to be replaced in used cars and they are a major expense I think that will have a significant impact on the used car market.
Another component cost of electric vehicles is charger costs. As shown in the Integration Analysis table below the 2022 cost for a light-duty vehicle is $2,176 and in 2035 the analysis expects costs to go down to $2,018. There is a lack of detail about charger types. I found a reference that describes two types of home chargers: Level 1 chargers that with a cost to install of $1800 can recover 4 to 5 miles of range per hour and Level 2 chargers costing $2200 that recover 25 to 30 miles of range per hour. I assume that the Integration Analysis cost estimat is for Level 2 chargers that can fully charge vehicles overnight. However, we also need to consider the costs for fast Level 3 chargers as part of overall costs even though they are not suitable for home use. They are much more expensive $50,000+ but can recover 100 miles of range per hour. Anytime an owner is on a long trip they are going to either need to find one of these chargers or interrupt their trip for an extended duration stop. In my opinion, charging limitations would effectively preclude New Yorkers from driving south for spring break.
There is another massive omission in the Draft Scoping Plan relative to chargers. What about renters and people who park on the street? Who is going to pick up the tab for all those chargers? Chargers could be assigned in parking lots but on the street that would be problematic. In both instances snow removal becomes an issue too.
In my opinion personal choice limitations are the biggest concern of the electric vehicle transition. ZEVs have range limitations and I personally want the ability to travel long distances without range anxiety. There is a safety issue buried in the necessity for longer fueling times. In order to match the 2000 cars that a typical filling station can service in a busy 12 hours, a future station would require 600 Level 3 chargers at an estimated cost of $24 million and a supply of 30 megawatts of power from the grid. Imagine the chaos if an evacuation was needed, everyone was driving a ZEV, and this limitation over-whelmed the capacity of available charging systems.
There was insufficient time to fully address a couple of other issues. Past transformative energy transitions occurred because the perception of the new technology was that it was better because it improved personal choice and opportunities as well as offering clear cost savings up front and over the lifetime of the vehicle. This transition is different. We are being forced to use technology that limits our ability to travel when and where we want and it costs more than what we are paying today. The benefits are for a problem that New York cannot solve on its own and alleged impacts that we cannot question. In my opinion that is a pretty hard pill to take.
We did not get a chance to talk about why aren’t hybrids good enough. In brief, the Climate Act mandates zero-emissions and hybrids use fossil fuels. The reality is that New York’s GHG emissions are so small relative to global emissions that there will not be any effect on the state’s climate and global climate change impacts to New York. Global emissions have annually increased by more than one half of one percent per year and New York’s total share of global emissions is less than one half of one percent. In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year. If New York allowed hybrids as a control option even if it meant some emissions costs would be lower and many of the personal choice limitations would be addressed.
Ms. Arbetter and I agree that many people are unaware of the implications of the Climate Act. She asked me to describe what the Draft Scoping Plan has to say about zero emission vehicles because that is one of the components that has the most impacts to New Yorkers. I tried to describe what is included and what is not included in the Plan to help spread the word.
We both agree that New Yorkers should take the opportunity to provide comments so that the Climate Action Council gets engagement from as many people as possible. I hope that readers will follow up and submit comments. While you could try to wade through the Draft Scoping Plan itself, the document has been described as follows:
The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it. Here’s an example: “Regardless, any transition must be carefully planned, detailed, and clearly communicated to ensure that expectations are aligned across stakeholders.”
Instead of reading the document I suggest spending some time reading about issues and research things that are of particular interest to you at the Climate Act website and my Citizens Guide. Once you have your thoughts together go to the comment website and submit your comment. For your information I have summarized all my comments here. One final note, I submitted comments based on the interview discussion that are described here.