I am on the road and don’t have the ambition to develop a long post so this will be a short one. The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway. On August 23 the Climate Action Council meeting agenda includes an item for “Public Comments Summary and Proposed Process for Integration”. This post provides my prediction for that item.
I have written extensively on implementation of the Climate Act. Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost. Based on my analysis of the Climate Act I don’t think that will be the case. I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good. 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 established the Climate Action Council who 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 meet the goals. 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 and will be finalized in 2022. The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition. While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.
Climate Action Council Meeting August 23, 2022
The agenda and meeting information are available in the 2022 Climate Action Council Meetings section of the Climate Act Materials and Meetings website. At some point a recording for the meeting will be posted on the site. I will eventually do a post to see if my forecast for what I think will happen verifies.
The agenda for the meeting includes the following items:
- Consideration of July 11, 2022, Minutes
- Subgroup Progress Reports
- Integration Analysis Updates
- Public Comments Summary and Proposed Process for Integration
- Proposed Process for CJWG Feedback Integration
- Proposed Process for Disadvantaged Communities Barriers & Opportunities Report Integration
- Next Steps
Most of these discussions will be perfunctory. The subgroup progress reports will give vague updates of the work to date. The primary issue with these topics is that there is no way to reconcile different opinions so I doubt that they will add value to the process. It is intriguing that work on the Integration Analysis has been going on. It will be interesting to see what topics were addressed.
Given that I submitted 27 comments totaling 356 pages I am particularly interested in the process for handling Draft Scoping Plan comments. In previous meetings Agency staff has talked about the volume of comments. I predict that the summary agenda item will make that a point of emphasis, will undoubtedly count the comments in favor and make a big deal that the majority of the comments support the Draft Scoping Plan approach. Of course, this ignores the fact that most people in the state are unaware of any of the details of the plan and did not submit comments.
If the Council really wants to integrate public comments, then the process should include the following. The comments have to be provided in a searchable database for the Council and public as soon as possible. The comments have to be categorized into specific topics for the Council with a summary of the issues raised. It is unreasonable to expect that the Council and the public should have to figure out the substantive issues on their own. Instead I predict that the comments will be available in a list, perhaps consolidated somewhat for the obvious form letters. It might be searchable but that will be the extent of the accessibility concession.
I have become so cynical of the process that I believe the last two environmental justice topics will just be treated as window dressing. Any overlap with Administration priorities this election year will be highlighted and any inconsistencies will be ignored.
If the State really was planning to integrate public comments, then the process would have been on-going. As issues were raised in the comments those that were impactful should have been passed on to the Council. With only a couple of months left before the Final Scoping Plan has to be drafted there simply is not time to understand all the comments much less for meaningful integration of them.
I hope I am wrong but I am not holding my breath that the plan for integrating comments will actually address substantive comments. I expect that my comments will be acknowledged but I doubt that they will be considered.