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 brief article describes a comment I submitted that was based on a post from last March. The comment was trivial but raised some general issues relative to the way the Council is addressing 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. 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 comment itself is a technical comment on a trivial problem and has no major bearing on Climate Act implementation. However, it raises a pervasive issue that needs to be addressed. All indications from the Climate Action Council meetings this year are that the plan for public involvement is simply going through the motions. There was no attempt to start identifying comments as they were submitted to determine if they rose to the level where the Council would have to address them specifically. Instead, Council leadership has insisted that they can only respond once the comment period closes. In addition, there is no provision for the kind of discrepancy documented here to be reconciled. While this problem is not a big deal, the terrifying prospect is that the issues associated with reliability raised at last summer’s Reliability Planning Speaker Session could possibly be treated the same, that is to say ignored.
Every time I have dug into the numbers, the Draft Scoping Plans numbers are not a reasonable estimate compared to my work. I have consistently found that the Scoping Plan costs estimates are biased high and the benefits proposed are biased low. This is a specific example that shows that one of the conclusions for Scenario 4 is not correct.
In particular, this comment evaluated the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 compared to Scenario 4 due to rail passenger improvements. The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion. I estimate that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a reduction of 64.7 million miles. While my estimate is for 2035, consistent with the Empire Corridor evaluation, and the Draft Scoping Plan is for 2050, I don’t think there is any question that the numbers are inconsistent.
I concluded that the Final Scoping Plan must provide more detailed documentation because there is little reason to trust the cost estimates in the Draft Scoping Plan because of the pervasive issues I have found. I believe that the Final Scoping Plan documentation should provide sufficient information so that anyone can readily determine the costs and emission reductions for their particular concerns. In my opinion in order to fulfill this obligation, the Final Scoping Plan must describe all control measures, assumptions used, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.
I have little hope that any of my comments will be considered much less acted upon. The leadership of the Climate Action Council already has the answer from the back of book. They are going through the motions of the public stakeholder process hoping that they can claim more people support the Draft Scoping Plan than don’t. While comments from an individual like me may not be of consequence, the possibility that comments from the organizations responsible for reliability will also be dismissed does not portend well.