Draft Scoping Plan EV Cost Comment

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 recently interviewed for a segment on the electric vehicle component of the Climate Act on Spectrum Cable’s Capital Tonight program hosted by Susan Arbetter. During the interview I suggested that one of the questions about electric vehicle costs she asked was appropriate for a comment. This article describes the comments I submitted on the issue raised in the interview.

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.   This page documents all the comments that I submitted as part of the Climate Leadership and Community Protection Act implementation process. 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.

One of the reasons that Capital Tonight did an interview with me was to let their viewers know that the comment period is open until July 1.  During the interview she asked me what the costs for Zero-Emissions Vehicles were in the Draft Scoping Plan.  When I told her the numbers for 2022 in the Integration Analysis spreadsheet she said: “That is a lot more than a gas-powered car”.  Later in the interview she asked what I would recommend people should write comments about.  I said that people should send comments to the Council about anything that impacts them directly.  I used the example regarding her question about the car prices as an appropriate question.  This comment specifically addresses that concern and a couple of others we did not discuss due to time constraints. 


The Integration Analysis vehicle cost projections rely on a single vehicle type for light-duty vehicles.  In the first place the value for regular vehicles seems high and, relative to all electric-vehicle prices last fall, the battery-electric costs seem low.  In my comment I recommended that the Climate Action Council consider updating the Integration Analysis to better represent different types of vehicles.   I also urged the Council to consider including the costs of used cars into the analysis particularly because low and middle-income households purchase used cars rather than new cars.  Finally, I questioned the optimistic rate of battery-electric cost price decreases used in the Integration Analysis. 

Integration Analysis Vehicle Costs

Ms. Arbetter asked me to talk about the Draft Scoping Plan costs because she knows that I have dug into the Integration Analysis enough to be able to give her specific answers.  I based the numbers I presented    on the Integration Analysis spreadsheet IA-Tech-Supplement-Annex-1-Input-Assumptions.   In the Trans_Device Cost table (excerpt below) the 2022 diesel and gas vehicle costs are both listed as $31,787 and battery electric vehicle cost is given as $41,646. The following table from Inside EVs lists the costs of battery electric vehicles on September 18, 2021.  There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.

Source: https://insideevs.com/news/534027/electric-car-prices-us-20210918/

Given the relative importance of future light-duty vehicle costs to New Yorkers I think that this analysis of vehicle costs needs to be refined.  A single category for light-duty vehicles is unacceptable.  A quick search for rental cars finds the following vehicle types: full-size, economy/sub-compact, compact, intermediate, standard, standard sport, intermediate SUV, standard SUV, premium, and luxury.  Kelly Blue Book’s buying guide for electric vehicles has another list of vehicle types.  Somewhere, someone must have compared different vehicle types to come up with a single number. 

I have the following recommendations for this aspect of the Scoping Plan.  At an absolute minimum, the rationale used for the single value must be documented.  If it was a weighted average, then the assumptions should be shown.  However, I think it would be more appropriate to incorporate more vehicle categories in the analysis that encompass a broader range of vehicles used.  While the more categories the better, why not at least provide costs for compact, intermediate, full-size in both regular and SUV models?  I am sure a more refined analysis would improve the value of these cost estimates. 

Used Cars

Due to time constraints in the interview, I was not able to make the point that the Draft Scoping Plan EV cost analysis only considers new cars.  With all the Climate Act emphasis on equity for low and middle-income New Yorkers, the document is ignoring those who cannot afford a new vehicle and that is a major flaw in the EV analysis.  According to EDF Energy:

The battery on an electric car is a proven technology that will last for many years. In fact, EV manufacturers guarantee it. Nissan warrants that its electric car batteries will last eight years or 100,000 miles, for example and Tesla offers a similar guarantee.

Future Costs

During the interview I also noted that the Draft Scoping Plan predicts that costs for battery-electric vehicles will be less than regular vehicles by 2028.  Specifically, the Integration Analysis spreadsheet 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.  Although I concede that many reports support similar cost reduction trajectories many of those reports are biased because they are from organizations with a financial stake in electric vehicle adoption and/or written by authors whose career is dependent upon the clean energy transition. 

My primary future cost concern is the cost of battery raw materials.  PWC describes the automotive supply chain and notes that:

The lithium-ion battery pack alone can account for up to 50% of the value of today’s EVs. Battery prices have fallen steadily in recent years and that share will likely be much lower over time. But even so, these batteries are primarily made by companies outside the traditional auto supply chain, creating new competition for legacy suppliers.

I believe that the Climate Action Council should address New York’s ZEV plans in the context of other similar plans in other jurisdictions particularly in regards to the world’s supply of lithium.


The primary purpose of this article is to show by example how to take a particular concern and put it into a comment.  Both Ms. Arbetter and I believe that more New Yorkers need to get involved in the Climate Act.  The easiest way to do that is to submit comments where you can fill out a form and directly submit a 2,000-character comment or attach a file.  If you have technical issues with the form, you can email your comment to: scopingplan@nyserda.ny.gov.

If you can describe a problem, document issues with the Draft Scoping Plan treatment of the issue, and then ask a question or recommend a revision, then I think your comment will be effective.  If that is too complicated, then simply explaining that you have general concerns about the direction of the plan would help counteract the environmental lobbying organizations letter writing campaigns.  There is a tendency on the part of many members of the Climate Action Council to claim that the quantity of comments regarding a specific issue should be the final arbiter of policy decisions.

The bottom line for my specific comment is that the Integration Analysis does a terrible job dealing with the costs of zero-emissions vehicles.  For a topic that is one of the primary interests of New Yorkers the overly simplistic approach is unacceptable.  The Integration Analysis should be revised to consider multiple vehicle category costs to improve the results and give the public a better idea what implementation of the Climate Act will mean to them personally.

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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