The expected costs associated with the Climate Leadership & Community Protection Act (Climate Act) are poorly documented. There are very few instances where the Hochul Administration provides specific estimates of ratepayer costs. As I run across reports that include costs, I will update my scorecard of residential ratepayer costs. This article reviews the Department of Public Service Staff Electric Vehicle Make-Ready Program Midpoint Review and Recommendations Whitepaper (Make Ready report)which provide recommendations for modification to the Make-Ready Program that subsidizes electric vehicle supply equipment and infrastructure.
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 submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. Every indication is that the costs will be astronomical as well. 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.
The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway. At the end of 2022 the Climate Action Council completed a Scoping Plan that makes recommends strategies to meet the targets. The Hochul Administration is developing regulations and proposing legislation to respond to those recommendations in 2023.
Unfortunately, the Scoping Plan is just a conglomeration of control strategies that are projected to provide the emission reductions required. The inadequate documentation does not demonstrate the feasibility of the recommended strategies. Furthermore the costs of the program and potential costs to individual New Yorkers are hidden in a shell game con for hiding the true costs. In the Scoping Plan costs are compared to a Reference Case that includes already “incremented programs”. As a result, the costs that are presented do not include all the costs of the net-zero transition. There has been no attempt to provide the expected ratepayer cost increases.
Climate Act Cost Scorecards
Given the lack of cost information I am starting to keep track of the observed costs of the Climate Act. My initial thought was that I would try to account for all the documented costs to a typical residential customer in a single scorecard. However, the effort involved trying to consolidate disparate cost estimates into this parameter is beyond my capabilities so I am going to track costs in several ways.
I naively thought that all the Department of Public Service rate cases associated with Climate Act related decisions would include typical residential customer information. However, I have found that is the exception rather than the rule. I have set up one scorecard for those rate case decisions that provide these data.
In order to simplify interpretation of the cost numbers provided I am going to use four other scorecards. One way to hide Climate Act costs is with subsidies. I am going to track direct subsidies and indirect subsidies in separate scorecards. I have a scorecard that tracks increased costs for various components of the Climate Act transition plan. Finally, I have a scorecard that tracks the differences between cost estimates in the Integration Analysis with what has been observed.
The format of each scorecard is similar. The specific program or component is listed along with the costs for the specific reference. I try to make an estimate of the total costs. For example, the residential rate cost increases necessary to support 3.5 GW of renewable energy transmission are listed but I also extrapolated the costs for an additional 6.9 GW target in the Scoping Plan. Each entry also includes a reference that provides more details for the costs.
The following section documents one example.
Electric Vehicle Supply Equipment and Infrastructure – Direct Subsidies
This is an example of a direct subsidy. I tried and eventually gave up trying to convert these costs to residential cost impacts. Marie French wrote an article published in Politico’s Weekly NY and NJ Energy newsletter that described the 18-E-0138 proceeding and the mid-point review:
MORE EV CHARGER SUBSIDIES FLOATED: The New York Department of Public Service staff wants to boost a ratepayer-funded program to support electric vehicle charging infrastructure from $701 million to $1.1 billion. A mid-point review of the “make ready” program, which the Public Service Commission approved in July 2020, found uneven progress in different utility territories to achieve the public charger goals of the program. Overall, only 630 fast charger plugs of a targeted 1,500 and only 12,475 of a targeted more than 53,000 Level 2 chargers by 2025 have been completed or committed.
While Con Edison is about halfway to its fast charger and Level 2 charger targets, National Grid is only 16 percent of the way to its Level 2 goal and 44 percent of the way to its fast charger target. Central Hudson is 1 fast charger shy of its program goal but has only hit 16 percent for its Level 2 target. NYSEG/RG&E are far behind.
DPS staff concludes that the incentives in the make ready program are insufficient and proposes boosting the available subsidies. New targets for the number of plugs are also proposed, including a new sub-category for chargers at apartment buildings. The new targets increase the number of public fast chargers to about 6,300 and reduce the number of level 2 chargers to about 43,000. A new $25 million micro-mobility program for disadvantaged communities is also proposed and the staff supports increasing a medium- and heavy-duty vehicle electrification pilot by $30 million to $54 million.
Electric Vehicle Supply Equipment and Infrastructure – Cost Documentation
The Make Ready report lists costs that I put in two of my scorecards. The numbers provided conflict with the Integration Analysis cost estimates:
The Make-Ready Order determined per-plug average costs for L2 chargers to be $11,298 within Con Edison’s service territory, and $6,000 for all other utilities’ territories. The per-plug average costs for DCFCs was determined to be $100,109 in Con Edison’s service territory, and $55,000 for all other utilities’ territories.
The integration analysis that provides the quantitative support to the Scoping Plan lists charger costs in Electric Vehicle Supply Equipment: Per-Vehicle Costs ($2020) table Light Duty Vehicle Battery Electric EVSE category for 2022 $2,716 per charger. It appears that the Make Ready Report estimate of the cheaper residential charging system is four times higher than the Integration Analysis.
The Make Ready program is a direct ratepayer-funded program subsidy but no specific ratepayer costs are described. The announced subsidies are $1.1 billion through 2025. I estimate that the subsidy will increase to $1.3 billion by 2030
Discussion
There is an important aspect of the Make Ready example. The Hochul Administration cost narrative is that the costs of inaction of outweigh the costs of action but that statement has an important caveat. It is misleading because it only includes the costs of the Scoping Plan components and does not include the costs of “already implemented” programs. The already implemented programs include the following:
- Growth in housing units, population, commercial square footage, and GDP
- Federal appliance standards
- Economic fuel switching
- New York State bioheat mandate
- Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
- Funded building electrification (4% HP stock share by 2030)
- Corporate Average Fuel Economy (CAFE) standards
- Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
- Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)
I assume that the Make Ready costs are part of the zero-emissions vehicle mandate. As a result, the $1.3 billion just to support public electric vehicle charging infrastructure is not included in the cost claim narrative. I suspect that detailed analysis of all the costs necessary to for just zero-emissions vehicles would exceed the alleged net benefits of between $115 and $130 billion.
Conclusion
Although trying to keep track of the hidden costs of the Climate Act is likely a Sisyphean task, I am going to give it a shot. At least until I can document that the admitted costs of the Scoping Plan are biased low and incomplete anyway. Any reader contributions are welcome!
Pragmatic Environmentalist of New York 