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. This article describes the comments that I submitted addressing all the alleged benefits claimed in the Draft Scoping 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. 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.
The Climate Leadership and Community Protection Act Scoping Plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”. However, the benefit claims are poorly documented, misleading and the largest benefit is dependent upon an incorrect application of the value of carbon. My comments address the Scoping Plan benefit claims and explain how the value of carbon is used incorrectly.
The Scoping Plan claims net benefits range from $90 billion to $120 billion. The Plan describes health benefits totaling $165 to $170 billion due to improvements in air quality, increased active transportation ($39.5 billion), and energy efficiency interventions in LMI homes ($8.7 billion). The benefit claims are not documented well enough to confirm those estimates but they appear to be biased high. The claimed benefits for the avoided cost of GHG emissions range between $235 and $250 billion. However, Climate Act guidance incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times. If the multiple-counting error is corrected, the avoided carbon damage benefits range from negative $74.5 to negative $49.5 billion. These errors should be corrected in the Final Scoping Plan.
The Scoping Plan air quality improvement benefits range between $100 billion and $103 billion for the low values and the high values range between $165 billion and $172 billion. These benefits are due to an air quality improvement for PM2.5 of 0.35 µg/m3 that is supposed to “avoid tens of thousands of premature deaths, thousands of non-fatal heart attacks, thousands of other hospitalizations, thousands of asthma-related emergency room visits, and hundreds of thousands of lost workdays”. However, the modeled impacts rely on a linear no-threshold model. The observed PM2.5 reduction in New York City since 2005-2007 is 5.6 µg/m3 and that is 16 times higher than the projected decrease due to the Climate Act. Using the linear no-threshold model that means that we should be able to observe sixteen times tens of thousands of premature deaths, sixteen times thousands of non-fatal heart attacks, sixteen times thousands of other hospitalizations, sixteen times thousands of asthma-related emergency room visits, and sixteen times hundreds of thousands of lost workdays. When the Climate Action Council and Final Scoping Plan verifies that these reductions have been observed I will accept these benefits.
The Scoping Plan admits that the health benefits from increased active transportation “should be considered a first-order approximation of the benefits of increased active transportation”. The active transportation health theory claims that as people are forced out of their personal vehicles some will switch to walking and biking. Those activities are healthier so there is a benefit. However, the analysis was conducted at the state level, rather than modeling changes in walking and biking activity due to changes in vehicle miles traveled within counties or individual communities. Because the actual number of places where this strategy could actually encourage more walking and bicycling to work is small relative to the state as a whole, the $39.5 billion health benefit claim is far too high. The Final Scoping Plan active transportation benefits should be revised to take into account the number of places where this might work.
The majority of the health benefits from energy efficiency interventions in Low and Middle Income (LMI) homes are the result of “non-energy interventions”. The Climate Act intends to transform the energy sector so it is disingenuous to claim health benefits not directly related to energy efficiency programs themselves. Of the $8.7 billion in benefits claimed $3 billion is due to reduction in asthma-related incidents resulting from better ventilation not directly due to energy efficiency. The $2.4 billion in benefits from reduced trip or fall injuries and reduced carbon monoxide poisoning benefits are non-energy interventions and should not be claimed as benefits for GHG emission reduction programs. The “non-energy interventions” benefits should not be included in the Final Scoping Plan.
The Scoping Plan claims that 2020-2050 societal benefits are greater than societal costs by between $90 and $120 billion. The largest proposed benefits come from avoided GHG emission impacts on climate change due to emission reductions. The Climate Act Scoping Plan manipulates the emissions, the emissions accounting, and calculation of social cost of carbon benefits to inflate these benefits to claim that there are net benefits. In order to maximize the benefits from emission reductions the Scoping Plan uses non-conventional assumptions to contrive increased emission estimates that are 1.9 times higher in 1990 and 2.3 times higher in 2019 than conventional, or UNFCCC, format for emissions accounting used by other jurisdictions. New York’s Value of Carbon guidance chooses a lower discount rate that places lower value on immediate benefits relative to higher delayed benefits received in the future. The combined effect of the higher emissions and lower discount rate means that New York’s societal benefits of GHG emission reductions are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions. Most importantly, it is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. The Value of Carbon guidance incorrectly calculates benefits by applying the value of an emission reduction multiple times. Using that trick and the other manipulations results in New York societal benefits more than 21 times higher than benefits using everybody else’s methodology. When the over-counting error is corrected, the total societal benefits range between negative $74.5 billion and negative $49.5 billion. The Final Scoping Plan should only take credit for societal climate change benefits based on total emission reductions from the baseline, the maximum observed total emissions or the most recent total emissions.
If anyone wants an example of a report that was written to justify a politically driven preconceived notion the Draft Scoping Plan fits the bill. No where is this more evident in the cost-benefit analysis that had to show that the plan would have benefits greater than the costs. The costs are poorly documented but it is still obvious that overt manipulation was used to claim lower costs in many ways. Furthermore, the costs are presented relative to a Reference Case that does not represent business-as-usual per usual practice. Instead, the Reference Case includes programs that even they are already implemented would not be considered were it not for the Climate Act.
The benefits assessment is nearly as bad. While it is common practice to claim health benefits to air quality improvements no one has validated the methodology used by comparing health outcomes with the significant air quality improvements observed since the 1990 Clean Air Act. The benefits analysis also claims benefits because people will walk more when they take away personal transportation options. In a desperate attempt to find benefits for low and middle-income communities they included “non-energy interventions” benefits which clearly is outside the scope of Draft Scoping Plan implementation strategies.
The largest of the so-called benefits comes from the reduction of societal impacts when New York greenhouse gas emissions are reduced. New York has a unique accounting system enshrined in the Climate Act law by politicians who had no idea of the implications. Even though the machinations project benefits multiple times greater than other jurisdictions it was still not enough to get the benefits large enough to out-weigh the costs. The Draft Scoping Plan incorrectly calculates the societal benefits by applying the value of an emission reduction multiple times. If you lost five pounds five years ago you cannot claim that you lost 25 pounds but that is what the Draft Scoping Plan is doing.
Worst of all is that the Climate Action Council propaganda is working. I see many reports that reference the claim that the cost of inaction exceeds the cost of action by more than $90 billion. That claim is simply not true. The benefits are imaginary but the costs will be real.