Capital Tonight – Seggos on the Climate Transition

To her credit Susan Arbetter, the host of Spectrum News Capital Tonight program, has tried to expose viewers to issues related to the Climate Leadership & Community Protection Act (Climate Act).  Unfortunately, she allows speakers from the Hochul Administration to constantly conflate extreme weather with climate change and misleadingly claim that the costs of inaction are more than the costs of action.  In this post I comment on her February 12 interview with Basil Seggos on the climate transition.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  In addition, the magnitude of the necessary costs is coming into focus despite efforts to hide them.  A political reckoning is inevitable in my opinion.

Seggos Interview: Climate transition will be ‘the toughest thing we ever do’

The video of the interview is available but I am going to concentrate on two paragraphs from the cover story on the Capital Tonight webpage:

The cost of the doing nothing on climate will far outweigh the cost of a climate transition for New York, according to state Department of Environmental Conservation (DEC) Commissioner Basil Seggos, who addressed concerns on Capital Tonight. 

“I just want to make sure viewers are clear. People are already paying for the impacts of climate change. That is a certainty. We spent $36 billion to recover from Superstorm Sandy,” Seggos said. “We see a $55 billion bill, potentially, if we don’t do the right things in New York, just on adaptation over the next 10 years.”

The political slogan “the cost of the doing nothing on climate will far outweigh the cost of a climate transition” is repeated as often as possible by representatives of the Hochul Administration.  It is a deeply flawed argument for multiple reasons. 

It is misleading because it refers to the costs in the Scoping Plan that do not include the costs of “already implemented” programs that exist solely to reduce GHG emissions.  In other words, it does not include all the costs to reach net zero Climate Act targets only the costs of programs started after the Climate Act itself. The two biggest programs not included in the cost side of the slogan are the Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030) and the 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).  These programs, among others, are listed in Section 5.3: Scenario Assumptions in New York State Climate Action Council Scoping Plan Appendix G: Integration Analysis Technical Supplement Section I page 130.

The ”cost of doing nothing” does not include benefits of GHG emission reductions.  The basis for the benefits are described in the  Scoping Plan Costs and Benefits white paper documents.  The actual numbers in that document have been updated since its release.  The Plan describes health benefits due to improvements in air quality but observed improvements in recent years are 16 times greater than those projected for the Climate Act.  If the State can show that the health benefits projected have been observed comparable to those observed then these benefits are supportable but there has never been any attempt to validate the estimates. 

The benefits include a couple of tenuous estimates.  The first is for “active transportation”. The active transportation health theory claims that as people are forced out of their personal vehicles some will switch to walking and biking.  Those activities are healthier so there is a benefit.  The increased active transportation benefit of $39.5 billion is based on a first-order approximation based on state-wide numbers but the benefits will likely only occur in certain areas.  As a result, the benefit estimate is far too high.  The second is for energy efficiency interventions benefits in low- and middle-income homes.  The majority of the health benefits claimed are the result of “non-energy interventions”.  The Climate Act intends to transform the energy sector so it is disingenuous to claim health benefits not directly related to energy efficiency programs themselves.  Of the $8.7 billion in benefits claimed $3 billion is due to reduction in asthma-related incidents resulting from better ventilation not directly due to energy efficiency.  The $2.4 billion in benefits from reduced trip or fall injuries and reduced carbon monoxide poisoning benefits are non-energy interventions and should not be claimed as benefits for GHG emission reduction programs. 

The final reason that the slogan is flawed is the biggest.  There are issues with the benefits for the societal avoided cost of GHG emissions known as the social cost of carbon or value of carbon.  The values used are determined by a wide range of value judgements and economic projections.  The Climate Act manipulates emissions to increase benefits and uses a lower discount rate than current Federal guidance resulting in societal benefits of GHG emission reductions that are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions.  The largest manipulation of these benefits is caused by incorrect guidance for calculating benefits.  In particular, the benefits of reductions are counted multiple times.  If only that error is corrected the total benefits do not outweigh the projected costs.

Another Climate Act narrative tactic is to claim that people are already paying for the impacts of climate change.  Seggos said “We spent $36 billion to recover from Superstorm Sandy” implying that climate change was responsible for those costs.  The difference between weather and climate is constantly misunderstood by Climate Act proponents that make this simplistic argument. 

According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”  Seggos consistently claims that extreme weather is proof of climate change but the interview showed he has no meteorological expertise whatsoever.  More than once when described implementation challenges he stated that the state is facing trade winds but the appropriate term is head winds.

If, in fact, Superstorm Sandy was connected to climate change then the weather over extended periods of time should show increased hurricane activity and there should be a trend in disaster losses.  Roger A. Pielke, Jr, specializes in tracking these parameters so I checked his work.

He posted information in June 2022 on hurricane trends on Atlantic hurricane activity.  He noted that:

1. The Intergovernmental Panel on Climate Change, in its latest report, concluded that there remains “no consensus” on the relative role of human influences on Atlantic hurricane activity.

Here is what the IPCC says exactly:

“[T]here is still no consensus on the relative magnitude of human and natural influences on past changes in Atlantic hurricane activity, and particularly on which factor has dominated the observed increase (Ting et al., 2015) and it remains uncertain whether past changes in Atlantic TC activity are outside the range of natural variability.”

One reason for the inability to unambiguously attribute causality to Atlantic hurricane activity is the large interannual and interdecadal variability. 

Pielke, Jr. argues that in order to assess disaster loss trends ”it is necessary to normalize disaster losses by taking into account changes in exposure and vulnerability.”  He explains that:

The UN Sendai Framework recommends looking at disaster losses as a proportion of GDP as a method of normalization.

Since 1990, the toll of disasters as a proportion of the global economy has gone down from about 0.25% of GDP to less than 0.20%. That is good news and indicates progress with respect to the goals of the Sendai Framework.

Some quick questions and answers.

• Can we conclude from this data that climate change is making disasters more frequent or costly? No
• Can we conclude from this trend that climate change signals are not detectable in trends in various extreme events? No
• What can we say about climate change by looking at this graph? Nothing
• What about those journalists and campaigners who claim that economic losses from disasters indicate the detection and attribution of trends in extreme weather? They are wrong
• How would we know if disasters are becoming more costly due to climate change? Follow this methodology

Needless to say the Scoping Plan ignored these recommendations and observations when it justified the Climate Act.  It is also obvious that these inconvenient results are routinely ignored by apologists for the Climate Act.

There is one final aspect of the slogan “the cost of the doing nothing on climate will far outweigh the cost of a climate transition” that needs to be considered.  The implication is that New York’s investments for the climate transition will make a difference.  I recently updated my post Climate Act Emission Reductions in Context that documented how New York GHG relate to global emission increases.  I found CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet.  There is interannual variation, but the five-year annual average has always been greater than 0.79% until the COVID year of 2020.  The Statewide GHG emissions inventory came out in December but the comparable GWP-100 data that I used from Open Data NY through 2021 are not available.  This analysis relies on last year’s data.  New York’s share of global GHG emissions is 0.42% in 2019 so this means that global annual increases in GHG emissions are greater than New York’s total contribution to global emissions.  Our actions will have no effects on the next superstorm because the increase in annual global emissions are greater than our total emissions. Implying other wise is disingenuous.

With all due respect to Commissioner Seggos, his cost benefit rationale for the Climate Act transition or his claim that climate change is affecting costs now do not stand up to scrutiny. Consider that the largest benefit claimed is based on counting benefits multiple times.  If I managed to lose five pounds and keep it off for five years I cannot claim that I lost 25 pounds but that is what the basis for the slogan is doing. The IPCC science directly contradicts the insinuation that hurricane trends are outside the range of normal variability.

Conclusion

Seggos claimed that the climate transition will be ‘the toughest thing we ever do’. I think it might be the worst thing we ever do.   The Climate Act transition plan is poorly documented, results are obfuscated, and there are no transparent cost estimates.  As a result, I do not believe that the Hochul Administration has made a persuasive case that the transition is feasible with regards to affordability and reliability.  I am disappointed that the media does not call them out on this.