The Climate Leadership & Community Protection Act (Climate Act) website was extensively revised at the start of 2023. It includes a link for the Scoping Plan Toolkit which is described as “resource to help community and partner organizations” with specific “resources to facilitate conversations about New York’s climate work.” As I was working on an article about the cap and invest program I noticed that there were two fact sheet pdf files for cap and invest: Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF]. This is a short post about the new format of the website and the cap and invest “toolkits”.
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 Website
The Climate Act website was revised at the start of 2023. Now it is a public relations site to sell the Climate Act. It has been revised so that it is more accessible to smart phones with large text fonts and splashy graphics. The main internal links cover “Our Impact”, “Get Involved”, News & Events”, “Resources” and “Partner Toolkit”. I list the links within each of these categories below:
- Addressing Energy Affordability Concerns
- Improving Our Quality of Life
- Protecting Our Environment
- Strengthening Our Infrastructure
- Growing Economic Opportunities
- Ensuring Equity & Inclusion
- Our Progress
- A New Vision of Home Sweet Home
- Getting from A-to-B
- Reimagining Business as Usual
- Transforming Our Energy Sources
- New Careers and Fresh Starts
“News & Events”
- Scoping Plan Toolkit
- Climate Action Council
- Climate Justice Working Group
- Meetings & Events
- Public Comment Process
- Disadvantaged Communities Criteria
“Partner Toolkit” Fact Sheets
- Cap and Invest One Pager
- Cap and Invest vs. Cap and Trade vs. Carbon Tax
- Climate Justice
There is blog post fodder in every one of these links. For example, the lead for the Addressing Energy Affordability Concerns link says “As energy prices rise, we must power our future focused on clean and renewable resources.” Not included in the platitudes and talking points within the link is a reference to the experience of any jurisdiction that has pushed the use of wind and solar resources over fossil fuel that has actually lowered consumer bills. It is all flash and style for pushing the narrative without substance.
Cap and Invest Toolkit Fact Sheets
This post is going to introduce issues associated with the cap and invest toolkits. There are two fact sheets for the cap and invest program: Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF]. When I first started looking at these resources. I found that they both linked to the cap and invest program one pager. I alerted a contact I have known for years because there is no contact on the web pages. The next morning the link to the Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax was changed so someone else caught the problem. I also question the label of the one pager document. The author’s interpretation is that a one pager means two sides of one page. I think the generally accepted implication is to condense the summary to a single page.
I am going to do a more detailed post on the cap and invest plan toolkits but for now I just want to make one point. Both fact sheets extoll the virtues and success of the Regional Greenhouse Gas Initiative (RGGI) cap and invest program. New York utilities have been covered by that program since 2009 and New York agencies never lose the opportunity to claim that it has been a success. I have been involved in the RGGI program process since its inception and have written many articles about the details of the RGGI program.
In early December I evaluated the 2020 RGGI Investment Proceeds report that describes the results of RGGI investments over the entire region. I found that since the beginning of the RGGI program CO2 emissions have been reduced more than 50% but that RGGI funded control programs have been responsible for only 5.6% of the observed reductions. The main reason for the reductions has been fuel switching to natural gas. When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $818 per ton of CO2 reduced.
In late December I did a similar analysis of just the New York investment proceed results. I found that in New York since the beginning of the RGGI program CO2 emissions have been reduced 39% in 2021 but the reduction was 47% until the State shutdown the Indian Point nuclear station. The RGGI funded control programs have been responsible for only 16% of the observed reductions. The main reason for the reductions has been fuel switching to natural gas. When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $565 per ton of CO2 reduced.
I conclude that RGGI is not an effective CO2 emission reduction program and that because the emission reduction efficiency of the RGGI investments is far greater than any social cost of carbon metric yet proposed that the investments are not cost-effective. RGGI success is the eye of the beholder.