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. Prior to the August 23 the Climate Action Council meeting I posted a prediction for the “Public Comments Summary and Proposed Process for Integration” agenda topic. This post is a forecast verification based on the meeting presentation slides. I will update this more when the video for the meeting is posted.
I have written extensively on implementation of the Climate Act and submitted extensive comments on the Draft Scoping Plan. 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. In the previous post, I predicted that the agenda item discussing public comments would make the number of posts 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. The number of posts was a point of emphasis in the following slide but the slides did not provide a scorecard of comments in favor relative to the comments opposed. So I was only half right.
The slides summarized the feedback received. There were cost impact concerns as shown in the following. It will be interesting to see if the Council responds to the issues raised or just decides that they need to do more advertising to convince people that these issues are not real.
Capacity, reliability, and security of the electric grid issues were raised. I have often written about those issues so will be very interested to see how the council handles them,
The presentation also described comments made about “Jobs and the New York economy”, “Alternative fuels”, “Scoping Plan goals, timeline and process”, “Renewable energy technologies”, “Climate justice and equity”, “Perceived ban on wood burning”, “Economy-wide strategies”, and Sector-specific feedback”. Frankly, the commenters who supported the Draft Scoping Plan descriptions of these topics are naïve in my opinion and just parroted the talking points of special interest groups. Many valid concerns were raised on these topics.
While the descriptions are mostly unbiased, I also got the impression that comments contrary to the narrative were not taken seriously and will be dismissed. This is most evident in the following slide with the description climate change denial. Denial in this context is a pejorative term equating anyone who does not accept the climate change science narrative of the Climate Act and Draft Scoping Plan as the same as those that do not accept the Holocaust. Drawing a similarity to a scientific theory with the documented horrors of the holocaust is an insult and inappropriate in the presentation. Also consider that one of the descriptions highlights the argument that some said New York’s climate goals would be insignificant if other jurisdictions do not take similar actions. My concern is what happens to this point now? Will the Final Scoping Plan provide a calculation showing the impact of New York’s climate goals relative to other jurisdictions or will the response just be blown off?
The remaining descriptions of the comments addressed the 28,500 email campaign categories. Forty five organizations developed a form letter and had their members submit a form letter using their template. All of these letters represent special interest of one form or other. The campaigns were separated into nine categories: gas transition, climate & environmental justice, multi-topic, green hydrogen, agriculture & forestry, wood burning, nuclear energy, waste incineration, and legislation. I will break down the numbers below but if you wonder what the special interest campaigners were exercised about then I refer you to these summaries.
The slides did list the approximate number of commenters in each of the campaigns. I have summarized the interesting totals below. For example consider the 13,300 gas transition comments that expressed support about doing something about climate change but basically said they were not willing to give up natural gas. There was an email campaign (~ 500 submissions) in the multi-topic category that similarly expressed support for climate change action but said that it “Must strike the right balance between protecting our planet and safeguarding our economy”. I think that could be taken to mean that they are not willing to take hits to the economy they think are inherent in the Climate Act. There was similar support with conditional concerns with the agriculture and forestry commenters. Amazingly to me, if all those comments can be categorized as we don’t support the current content of the Draft Scoping Plan, then half the comments were against. I fully expected that a clear majority of comments would support the Draft Scoping Plan transition plan for the Climate Act so predicted that would be highlighted. That was not the clearcut case and could be the reason that no scorecard was presented.
It is notable that no email campaign addressed the electric vehicle mandate. It is not surprising because all the car companies have signed on to do electric vehicles and the government support for electric vehicle purchases means they can raise prices commiserate with those subsidies. I am convinced however, that most people Upstate have no intention of switching to an electric car as their primary mode of transportation and were simply unaware of the opportunity to comment. I imagine if there was some organization that asked people to submit a comment against the requirement to lose the ability to purchase an internal combustion engine by 2035 that the submittals against that component would be overwhelming.
When I described my predictions, I outlined what I thought should be done if the Council really wants to integrate public comments and predicted that it would not be included. I said 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 with an emphasis on substantive issues. The proposed process for integrating the comments slide makes no mention of a database. The staff will summarize themes which is equivalent to categorizing the comments. The slide says that staff will continue developing actionable recommendations which I guess relates to my substantive issues. However, the slide presentation to the Council did not highlight issues that must be addressed. Maybe that occurred during the discussion but that review will have to wait until the video recording is available and I have to review it.
One final point about the presentation. The initial slide mentioned that 900 comments included attachments and that some of those are still being reviewed and summarized. The only way to provide substantive comments is by using attachments. There was no mention of comments submitted by the New York Independent System Operator (NYISO) or New York State Reliability Council. The staff summary of those comments should be highlighted to the Council members and the fact that no slide highlighted their comments suggests to me that haven’t been reviewed yet.
At some point I should discuss the section of the presentation that described continuing Integration Analysis work. It is a problem for me that this work has been going on apparently absent comment input. I think the NYISO comments would be directly relevant to the Integration Analysis work but there was no suggestion of that. The presentation claimed that benefits out-weighed the costs but I submitted comments that directly contradicted that. I described the games played to be able to conclude that “The cost of inaction exceeds the cost of action “. The reality is that the benefits are imaginary but the costs are real and the Integration Analysis that provides the basis of the Draft Scoping Plan consistently over-states benefits and under-estimates the costs. Shouldn’t the Council know that there were comments on that specific topic or will my comments be ignored because there was only one comment that said that?
Conclusion
There is no indication that any comment that is not consistent with the Draft Scoping Plan narrative will be incorporated into the Final Scoping Plan. Given the schedule and the approach outlined at the meeting, I doubt that the Council will ever hear about those comments, much less discuss why they should be ignored.
The Climate Action Council has to make a case that a net-zero electric system will work and to date they have totally ignored that analysis. Francis Menton recently summarized the issues with such a transition and concluded that it will never work. I have little faith that the current administration is going to address the issues he raises. I only hope that the folks who are foisting this travesty on the state will be in some way held accountable when the plan fails.
Pragmatic Environmentalist of New York 