Balancing the risks and benefits of environmental initiatives
I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.
For anyone interested in New York energy information the Patterns and Trends documents are a great resource. One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data. For space reasons the report does not list all the numbers but the underlying spreadsheet includes everything. Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind. In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of the year. The latest report available, Patterns and Trends – New York State Energy Profiles: 2003-2017 (“Patterns and Trends”) publication date is March 2021 38 months after the end of the year. I believe that these delays are due to reviews of the data by the Cuomo administration.
New York Historical Energy Sources
Patterns and Trends Section 3: New York State Energy Consumption provides data that can be used to describe the historical trends of electrical energy sources. This section presents data on primary and net energy consumption in New York State by sector and fuel type from 2003 through 2017 in the document but provides data in many cases back to 1990 the base year for the CLCPA. Primary consumption of energy is shown by fuel type in physical units, such as tons, cubic feet, gigawatt-hours (GWh), barrels, and trillion Btu (TBtu). Total primary energy consumption by sector, including residential, commercial, industrial, transportation, and electric generation but we will only consider the electric generation sector in this analysis. This Patterns and Trends section also includes information on other fuels, including wood, municipal waste, solar, and geothermal energy. Electricity generation reported does not include generator station use.
Figure 1 lists the historical trend (%) of the sources of electric generation in New York State (NYS) from 1990 to 2017 using data from Table 3-4b in Patterns and Trends. The data shown combine all the fossil fuel sources into one category, list the data from each of the other categories, and combine the CLCPA renewable sources into a category. The CLCPA defines renewable energy sources as wind, solar, biomass, geothermal, hydro and nuclear. In 1990 NYS obtained 59% of its electricity from fossil fuels, 38% from CLCPA renewables and imported 3% from out of state. Note that nuclear and hydro accounted for 36% of the renewables, municipal waste, biomass and geothermal under the other category provided 1% but there was no wind and solar electricity generation.
Since 1990 there has been an uneven trend of decreasing fossil fuel use down to 30% in 2017. Net imports has increased to 16%. Since 2001 nuclear generation has provided around 30% and in 2017 provided 32%. Hydro has provided between 15 and 18% since 2001. Biomass and geothermal has stayed at 2% since 2008. Solar had yet to show any significant generation and wind provided 3%. The good news is that fossil is only 70% but the bad news is that imported electricity does not all meet the CLCPA renewable definition so we cannot fully assess the status of energy use relative to the CLCPA targets.
The Patterns and Trends document is a valuable resource for NYS energy analyses. Unfortunately, there is a significant reporting lag so the latest available data is three years old. In order to better address feasibility more recent data are necessary. I will follow this article with a feasibility post with that information.
On July 25, 2021 the Syracuse Post Standard reprinted an opinion piece from the Washington Post “We need to stop fiddling while the world burns” that described the World Weather Attribution analysis of the recent record-breaking heat wave in the Pacific Northwest. In order to justify the need for massive transformations of the energy system such as New York’s Climate Leadership and Community Protection Act stories like this that claim that the heat wave would have been “virtually impossible without human-based climate change” receive much publicity. However, upon close examination the claims are hype and exaggeration that do not prove the need to “stop fiddling”. The fact is that the reason for the heat wave is mostly extreme weather caused by natural variability with a little bit of climate change thrown in.
The difference between weather and climate is constantly mistaken by CLCPA advocates and the July 22 Climate Action Council meeting presentation included a slide that prominently highlighted the Pacific NW heatwave. This has become such a frequent mis-representation that I have a page that references my evaluations of climatic effects that turned out to be weather events and other similar analyses by other authors.
In this instance there is no need for me to do an evaluation of how climate change affected this extreme weather event. Dr. Cliff Mass is a meteorology professor at the University of Washington whose has spent his career developing an understanding of the weather and climate of the Pacific NW. In addition, he is currently doing research running high resolution, state-of-the-science regional climate models of the region. I do not believe that there is anyone more qualified to address this event and its relationship to climate change.
In the first post, Dr. Mass described the heat wave as follows:
The maximum temperatures during the heatwave were as high as 30-40 degrees Fahrenheit above normal. Seattle had a high of 108F, 35F above the normal high of 73F. Quilluyte on the Washington Coast zoomed to 109F compared to a normal high of 65 (44F above normal). Throughout the region, all-time temperature records were broken, representing the hottest day on record at many locations.
He believes that the “Pacific Northwest is warming and human emission of greenhouse gases is probably the origin of much of it” but goes on to explain the specific reasons for the record setting temperatures. He showed how a persistent high-pressure ridge developed that brought warm air to the area. The already warm air became “supercharged” because the wind flows caused downslope winds which compress the atmosphere markedly increasing the temperatures. In both cases the exact conditions needed to cause the high impacts had to align at the same time. It was a very rare and extreme weather event. Dr. Mass believes that climate change has increased temperatures in the area 1 to 2 F so that effect is added to the observed temperatures. As a result, he believes that climate change is only responsible for that amount of the observed 30-40 degrees observed above normal.
The World Weather Attribution analysis of the heat wave claimed that “Based on observations and modeling, the occurrence of a heatwave with maximum temperatures as observed in the area was virtually impossible without human-caused climate change”. In the second post, Dr. Mass states:
This claim is not supported in the document or by the rigorous science, and, in fact, the material in the attribution report contradicts this assertion. I will provide substantial evidence that the heatwave attribution report, which has not been submitted for peer-review, is profoundly flawed, with serious technical and interpretative errors.
Dr. Mass points out that their rationale that global warming was the main factor was riddled with contradictions that show no evidence that their conclusion was true. In his technical explanation of the flaws in the report he examined local data trends and climate model results. Dr. Mass evaluated local trends of daily high temperatures and found that their analysis was incorrect. They used a climate model that was not refined enough to capture the factors that affect local weather conditions and improperly used an inaccurate emissions estimate. Finally, he showed that their evaluation was inconsistent with their conclusion. He sums up: “If anything, much of the material in the report is highly suggestive of a random, black swan event that is slightly enhanced by greenhouse gas warming”. Exactly Dr. Mass’ conclusion.
In his final article he explains “why their basic framing and approach is problematic, leading readers (and most of the media) to incorrect conclusions” by way of two examples. He describes a physically meaningful interpretation with an example where the essential event would have happened without any effect from global warming. He notes that this is “a good example of the golden rule of climate attribution: the more unusual and extreme the event, the greater the proportion of the event is due to natural variability rather than global warming”. In contrast the World Weather Attribution analysis focuses only on the headline interpretation. They ignore the physical situation and actual impacts and the fact that natural variability is dominating the situation. Instead, they only look at the event itself. In this case they note that temperatures were up to 40 F higher than normal and say this would not have happened without global warming. That is true but it ignores the fact that global warming was only responsible for 2 F and 38 F would have been a record-setting heat wave. This miscommunication leads people to think that global warming was the primary driver rather than natural variability.
He concludes this article with the following:
Many of the climate attribution studies are resulting in headlines that are deceptive and result in people coming to incorrect conclusions about the relative roles of global warming and natural variability in current extreme weather. Scary headlines and apocalyptic attribution studies needlessly provoke fear. Furthermore, incorrect and hyped information results in poor decision-making.
We need to worry about climate change and take steps in both mitigation (reduce greenhouse gas emissions) and adaptation. But hype and exaggeration of its impacts only undermine the potential for effective action.
I don’t agree with all of his projections for the future because I don’t trust climate models based on my model verification work that found it was possible to get the right answer for the wrong reason. As a result, I believe it is better to emphasize adaptation over mitigation because the effects of natural variability on extreme weather have devastating impacts which a more resilient society can handle better. However, we agree that hype and exaggeration of the causes of extreme weather undermine the most effective policies to reduce extreme weather impacts.
The hype and exaggeration matters to New Yorkers because the politicians who passed New York’s Climate Act based their rationale for mitigating greenhouse gas emissions on the misinterpretation of similar extreme weather events driven primarily by natural variability as evidence that climate change is affecting us now. As a result, the law’s emission reduction targets will squander state resources that would be better spent on making society more resilient to extreme weather rather than using today’s inefficient, expensive and untested renewable energy “solutions”.
I wanted to mark the occasion of this, my 300th post, with a bit of retrospective since I started posting on this blog on January 11, 2017.
I am a retired electric utility meteorologist with over 40 years-experience analyzing the effects of meteorology on environmental impacts. Over that time, I have dealt with a wide range of environmental issues and researched many relevant topics to New York’s environmental and energy sectors. As part of that work, I had to document the results and potential impacts of many topics that I felt were important. When I retired, I decided to write about some topics that I felt were not receiving much attention and started blogging.
There is a massive industry associated with environmental causes that produce many opportunities for articles critical of the environmentalist narrative. Coupled with New York State’s Climate Leadership and Community Protection Act (CLCPA) it seems that every day there is something that I want to write about. In addition, the current state of New York politics precludes meaningful criticisms from industry so I can say things that companies cannot. Nonetheless I am always careful to note that the opinions expressed in my blog articles do not reflect the position of any of my previous employers or any other company I have been associated with, the comments are mine alone.
The goal in my blog is to describe environmental issues from a pragmatic viewpoint. Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues. Unfortunately, public perception is too often driven by scary one-sided stories that have to be rebutted by getting into details. I have tried to show the complicated “other” side of environmental issues that gets overlooked during policy discussions too often. My background as a scientist and my earlier responsibilities to provide technical comments on new or revised regulations means that I tend to get bogged down in technical details that are, too be kind, pretty wonky. I have tried to tone down the technical aspects but have not been entirely successful.
Although my posts cover a wide range of topics that interest me there are two primary topics covered. Most of my articles (109) have addressed the CLCPA implementation process. I truly believe that this “solution” will be far worse than the impacts of the problem they are trying to address and that does not consider the enormous costs. I have also written 36 articles on the Regional Greenhouse Gas Initiative (RGGI). This greenhouse gas control program is frequently described as a success but I have not been able to resist pointing out the flaws in that belief.
The final question I have asked myself is whether my obsession with this blog has been a success and to me success is having people read the blog. According to the WordPress statistics, the views of the blog have been steadily increasing and there have been over 16,500 visitors. There is an option for people to like a post and those have been going up. Comments have been a bit of a disappointment especially because many of the comments are simply approvals of references to previous posts. There are 53 people who follow the blog too.
So where are the people coming from to find the blog. Very early on Judith Curry included this blog on her blogroll and a large percentage of the visitors visited since then. Tom Shepstone started reposting my articles at his Natural Gas Now blog starting 12/28/18 and he has spread my message in nearly 100 reposts. My thanks to both of them for bringing visitors.
I have done some self-promotion as well. I have also done blog posts for Judith’s site and Watts Up With That and there usually is a flurry of visitors after those posts. Francis Menton posted blog articles on my articles about the CLCPA implementation process and both were re-printed on Watts Up With That. The comments on my work in those posts dwarf the responses on the blog itself and I am sure the total views were larger too. Most gratifying is the occasional contact from people whose work I respect offering advice, encouragement, and praise. I have also heard that there are industry people who follow the blog.
The blog statistics note the number of people who visit based on internet searches. Unfortunately, I don’t know what they are searching for. I suspect it is a source of frustration to the state that when searching for specific CLCPA items my posts generally turn up. Most popular article by far is one on the proposed rebuilding of Interstate 81 through Syracuse and I would love to know how nearly 3,000 people found it.
In the future, I plan to develop a simple summary of the issues with the CLCPA that I want to publicize as much as possible. The layman’s version of that document will be backed up by plenty of technical documentation from the blog. I am also trying to provide references to the work of others who agree with my concerns relative to the “solutions” for the existential climate crisis.
In conclusion this has been a rewarding experience for me. I devoutly believe that it is important to keep busy during retirement and this blog keeps me busy. Just when I get discouraged and think about quitting, some insane proposal or article comes up that provides more than enough incentive to keep writing. My thanks to everyone who has read my work.
On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Since the law was enacted the process of developing strategies to meet those targets has been underway. My posts describing and commenting on the strategies are all available here. In order to meet the emission reduction targets for the transportation sector, electric vehicles are a necessary component. This post comments on the New York State Energy Research & Development Authority (NYSERDA) recent email giving four reasons you should consider an electric vehicle.
I recently wrote a post on a similar NYSERDA email about heat pumps and the Energy Efficiency & Housing Advisory Panel scoping plan recommendations to the Climate Action Council. I noted that in the panel presentation the first mitigation strategy is an initiative to modify building codes and standards for new construction, including additions and alterations, to require solar photo-voltaic (PV) panels on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness. An all-electric home must use electricity for heating and heat pumps are the proposed solution. My post showed that the NYSERDA email titled “Myth Buster: The Heat Pump Edition” was propaganda.
Propaganda is defined as material disseminated by the advocates of a doctrine or cause. There are many propaganda techniques including “card stacking”. This technique is a feature of the CLCPA:
It involves the deliberate omission of certain facts to fool the target audience. The term card stacking originates from gambling and occurs when players try to stack decks in their favor. A similar ideology is used by companies to make their products appear better than they actually are.
On May 10, 2021 the Transportation Advisory Panel presented their strategies to the Climate Action Council. An outline of their recommendations is also available. As shown in the following slide from the recommendations the first mitigation strategy initiative is to transition to 100% zero-emission light duty vehicle sales.
The recommended mitigation strategy overview noted that a potential risk or barrier to success was “Lack of consumer awareness/interest and consumer concerns about technology & charging/fueling”. The strategy suggests a “Coordinated and cooperative marketing campaign with industry partners” as a possible mitigant.
I think garnering support for this initiative is a major challenge for proponents. Clearly a marketing campaign is necessary to dupe the public into this ill-advised strategy. As shown below, I believe the rationale for purchasing an electric vehicle in their marketing campaign is pretty weak and certainly not enough to make me consider getting one.
Four Reasons to Consider an Electric Vehicle
The following is the text from a NYSERDA email titled “Considering an electric vehicle (EV)? Here are four reasons you should”. It also is available in a weblink.
There’s no denying that over the past several years the demand for electric vehicles (EV) has increased. In New York State, driving electric is a great opportunity for vehicle owners to make a positive environmental impact, lowering their carbon footprint while helping the State reach its ambitious clean energy and climate action goals.
Transportation accounts for 42% of New York State’s greenhouse gas emissions, meaning that every EV that replaces a gas-powered vehicle will help make a difference.
Making the switch to an electric vehicle is a big decision. The more knowledge you have, the more informed your choices will be. If you’re still on the fence about making the switch, here are four additional things to consider:
1: Electric vehicles will save you time and money.
Compared to gasoline-powered cars, EVs are more energy efficient and cost about 50 to 70% less to operate per mile. EV motors don’t need oil changes, you’ll be making fewer visits for regular maintenance and repairs. And since your car will run on electricity, not gas, you won’t need to make trips to the gas station.
2: Electric vehicles are clean, quiet, and fun to drive
There is no loud engine, but electric vehicles deliver fast acceleration and surprising pick up that make them exceptionally fun to drive. EVs also boast a variety of different technological advantages, including the ability to preheat your car without garage emissions, or to turn up the bass on your speakers without engine distortions.
3: There are tax credits and rebates available to help you purchase your EV.
With an electric car charger provided by your vehicle’s manufacturer, you can simply plug into a standard home outlet to charge your car. You can also upgrade your home to a Level 2 charger, which requires an electrician to install but increases the speed of charging up to 10x compared to a standard outlet. And if you need to charge your EV while you’re out and about, rest easy: there are thousands of available charging stations throughout the State that are easy to find through mobile apps and through the NYSERDA website.
4: There are tax credits and rebates that can be put toward purchasing an EV.
Use the Drive Clean Rebate to take up to $2,000 off the price of an electric car at the time of purchase. You can also combine that rebate with the existing federal tax credit for electric cars, which provides up to $7,500 for the purchase of a new electric car.
I will address the propaganda in the components of the NYSERDA email below. My comments will rely heavily on Dr. Jay Lehr’s excellent overview of the many reasons that electric vehicles will never replace the internal combustion engine.
NYSERDA claims that electric vehicles will save you time and money because they are “more energy efficient and cost about 50 to 70% less to operate per mile” than gasoline powered vehicles. This ignores the fact that electric vehicles are significantly more expensive than comparable internal combustion automobiles. There also are buried assumptions about the costs of electricity relative to gasoline that can be used to game the answers to provide this rationale. Another claim is that “since your car will run on electricity, not gas, you won’t need to make trips to the gas station”. What happens when you want to take a trip that exceeds the battery range is ignored. A gasoline powered car can re-fuel in a matter of minutes whereas an electric vehicle charger takes hours if you can find a charging station that is not being used. Lehr also points out that the cost of battery replacement and lack of a used car market should also be considered when comparing costs.
Electric vehicle proponents love to claim that they are clean, quiet, and fun to drive. Although electric vehicles to have lower emissions the life-cycle emissions and supply chain implications of the batteries needed need to considered for this claim. NYSERDA claims that “electric vehicles deliver fast acceleration and surprising pick up that make them exceptionally fun to drive”. Reality is that most people use their vehicles as a tool and having fun is a low priority. The email goes on to claim that they “boast a variety of different technological advantages, including the ability to preheat your car without garage emissions, or to turn up the bass on your speakers without engine distortions”. The first claim about garage emissions suggests this was written by someone who has a garage. Based on my neighborhood more than half the cars are not stored in a garage in the winter. The final claim is absurd. Who in the world decides to buy a car based on being able to turn up their bass speakers?
One of reasons that electric vehicle ownership is more expensive is the desirability of a charging system that can provide a full charge in a short time. The third component notes that you can choose between the electric car charger provided by your vehicle’s manufacturer that uses a standard home outlet to or upgrade your home to a Level 2 charger, “which requires an electrician to install but increases the speed of charging up to 10x compared to a standard outlet”. Another notable observation in my neighborhood is the number of vehicles per home. Most have at least two and anyone with adult children living at home has more. Of course, the concern about where to charge at home in my suburb pales in comparison to any city where car owners have to park on the street. NYSERDA goes on to claim that “if you need to charge your EV while you’re out and about, rest easy: there are thousands of available charging stations throughout the State that are easy to find through mobile apps and through the NYSERDA website”. I believe it is fair to say that European electric vehicle implementation is ahead of New York so the “horror trip” of a retired German couple who needed 26 hours to make a 765 Km or 475 mile trip in an electric vehicle makes me leery of this NYSERDA claim.
Finally, NYSERDA notes that you can use the Drive Clean Rebate to take “up to $2,000 off the price of an electric car at the time of purchase” and that you can also combine that rebate with the existing federal tax credit for electric cars, which provides up to $7,500 for the purchase of a new electric car. There are around 9.4 million standard vehicles registered in New York. If every one of those vehicles were to be replaced, this subsidyt would cost $18.9 billion so I have to wonder if this money will be available for everyone.
When I explain the CLCPA implementation strategies most people do not grasp that this abstract concept is going to have big impacts on personal choice and affordability. Moreover, as details on the plans are fleshed out it is becoming increasingly obvious that there are serious environmental consequences that are being ignored in the process.
In my opinion the majority of New Yorkers will object to electric vehicles primarily because of personal choice. In my case I rely on my personal vehicles as a tool to my way of life and I expect that my concerns are similar to many others. I do not choose my vehicles based on whether it is fun to drive. Several times a year I use my car to take a trip beyond the range of current electric vehicles. While I try to avoid driving in bad winter weather there are times it cannot be avoided and a car that might lose power quickly if I get marooned is a danger to me and my family. While I could afford an electric vehicle, I see no reason to pay more for a vehicle that might be an interesting toy but has flaws for my personal use.
The fact is that purchasing a new vehicle, much less a more expensive electric vehicle, is beyond the means of many people. Worse is that there are other costs involved with widespread electric vehicle use. Dr. Lehr notes that “On most suburban streets the electrical infrastructure would be unable to carry more than three houses with a single Tesla. For half the homes on your block to have electric vehicles, the system would be wildly overloaded.” As a result, the suburban electric distribution system will have to be upgraded and everyone will have to pay for those costs. Experience elsewhere shows that, for example, upgrade costs to the electric system for the United Kingdom are enormous and will increase costs for everyone. Therefore, electric vehicles are toys for the rich that will be subsidized by the poor.
Among the environmental consequences not included in the CLCPA implementation process are the impacts of exotic materials needed for the transition. A recent report by the International Energy Agency included a comparison of the minerals needed for electric vehicles as opposed to conventional cars. Assuming that a million cars are sold per year in New York in 2035 when the mandate to sell only electric vehicles are sold in New York that means that an additional 34,505 tons of copper, 8,904 tons of lithium, 43.409 tons of nickel, 15, 583 tons of manganese, 14,470 tons of cobalt, and 70,122 tons of graphite will be needed each year. If all other jurisdictions enact similar mandates the amount of rare earth minerals required will be enormous. The newly released book “Clean Energy Exploitations” by Ron Stein and Todd Royal explains how the development needed to provide these materials will exploit the most vulnerable people while destroying their environment.
I conclude that NYSERDA’s rationale for purchasing an electric vehicle is out of touch with the public. I think this strategy is ill-advised due to its hidden environmental impacts and cost shifting from higher-income drivers to lower-income consumers. I hope that when the public becomes aware of these impacts that there will be sufficient push-back to drop the electric vehicle mandates.
Update 7/27/21: Immediately after publishing this I found another summary of the problems of EV deployment that is worth reading. “Electrifying parts of our transportation system may result in incremental reductions in greenhouse gas emissions,” Robert Bryce argues. “But a look at history, as well as an analysis of the supply-chain issues involved in manufacturing EVs, the resource intensity of batteries, and the increasingly fragile state of our electric grid – which is being destabilized by bad policy at the state and national levels – shows that a headlong drive to convert our transportation systems to run on ‘green’ electricity could cost taxpayers untold billions of dollars, increase greenhouse gas emissions, be bad for societal resilience, make the U.S. more dependent on commodity markets dominated by China, make us less able to respond to extreme weather events or attacks on our infrastructure, and impose regressive taxes on low and middle-income Americans in the form of higher electricity prices.”
On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have commented on the advisory panel implementation recommendations presented to the Climate Action Council this year. This post describes the first Climate Justice Working Group presentation to the Climate Action Council. Their presentation provided an overview of their expectations and specific comments on two of the advisory panel recommendations. There is a recording available of the meeting here.
Section 75-0111 of the CLCPA mandates that the Department of Environmental Conservation establish a Climate Justice Working Group. I provided background information on the requirements and the membership in an earlier post. The post also includes documentation describing the education and affiliation of the members of the working group.
According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide. My posts describing and commenting on the strategies are all available here.
I think there is a controversy regarding the scope of this working group’s charge. The CLCPA states that each advisory panel is required to coordinate with the climate justice working group while developing their enabling strategies. There also are requirements that the draft and final scoping plan have to be developed in consultation with the climate justice advisory group. I interpret that to be a consulting role but it is apparent that this working group believes that they have the responsibility to be the final arbiter whether the advisory panel enabling strategy recommendations adequately address climate justice. As noted in my previous post, there is little technical expertise on this panel to support that role. More importantly, their vision excludes any consideration of feasibility or competing interests.
Climate Justice Framework
My words cannot fully capture the tenor and content of the presentation by Elizabeth Yeampierre, the Executive Director of UPROSE. It would be worth your while to listen to her seven-minute lecture to the Climate Action Council starting at 8:00 in the meeting recording. I say lecture because my impression was that she believes that the climate justice working group has a mission that is not open to compromise, that the solutions have to come from the communities because they are most impacted, and those solutions have to not only address climate change but also co-pollutants. Unfortunately, the basis for this climate justice framework is technically flawed and does not recognize that there is no zero-risk way to provide reliable, abundant, and affordable energy.
The rationale for the climate justice framework is that climate change is truly an existential threat. According to Yeampierre, the next Intergovernmental Panel on Climate Change report is going show that there are thresholds for climate breakdown that will doom humanity because humans cannot evolve or develop new ecosystems to handle drastic climate shifts. However, humans have adapted their ecosystem to live across an incredible range of temperatures. At the cold end of the spectrum the humans in the remote village of Oymyakon in eastern Siberia have adapted to an ecosystem where the record low temperature is -96 OF degrees below zero Fahrenheit and the record high is 94.3 OF. The average monthly temperature in January is -51.5 OF and in July is 58.8 OF a range of 110 Fahrenheit degrees. At the hottest extreme, Mecca, Saudi Arabia has had a record high temperature of 121.6 OF and record low of 51.6 OF. The average monthly temperature in January is 75 OF and in July is 96 OF. The 2.4 million residents of Mecca have adapted their ecosystem to live in a city whose annual average temperature is 87.3 OF. I rate this claim as bogus.
Yeampierre goes on to point out that we need to act now because of the recent heat waves in the Pacific Northwest. I believe that the definitive take down of that claim has been prepared by University of Washington meteorologist Dr. Cliff Mass. The weather and climate of that region is his particular specialty and he explains that the “specific ingredients that led to the heatwave include a high-amplitude ridge of high pressure and an approaching low-pressure area that “supercharged” the warming” and showed that “global warming only contributed a small about (1-2F) of the 30-40F heatwave and that proposed global warming amplification mechanisms (e.g., droughts, enhanced ridging/high pressure) cannot explain the severe heat event”. Again, her rationale for drastic action has no basis in fact.
In my opinion, the following justice lens diagram describes the Green New Deal which not only calls for public policy to address climate change but to also achieve other social goals and resource efficiency. The diagram shows the plan to move from today’s “extractive” economy to a future “living” economy. While I could certainly do a post just on this diagram, I will only summarize it below for the context of the Climate Justice Working Group.
On the left side of the diagram is today’s extractive economy where work’s purpose is exploitation. The worldview is consumerism and colonial mindset. Resources are to be extracted – “dig, burn, dump”. Governance is militarism.
The right side of the diagram describes the living economy where work and cooperation produce ecological and social well-being. According to this, resources have to be regenerated, the worldview is caring and sacredness, and governance is by “deep” democracy.
The center of the diagram describes the plan to convert to the living economy. Solutions that are “visionary and oppositional” will stop the bad and build the new. If we “starve and stop” to “divest from their power” we can “feed and grow” to “invest in our power” through a values filter. This filter moves capital by shifting economic control to communities, democratizing wealth and the workplace, advancing ecological restoration, driving racial justice and social equity, making most production and consumption locally based and retaining and restoring cultures and traditions. All this occurs when the rules are changed to “draw down money and power”.
I really don’t think that the majority of the politicians that voted for the CLCPA considered that the law to mitigate greenhouse gases to address climate change was also a mandate to move to a socialist utopia as described in this diagram. I am certain that the majority of the voters would not endorse this plan. The real question is how far is the Cuomo Administration going to go down this path to appease the environmental justice demographic but not alienate the rest of society.
In Yeampierre’s naïve view of the energy sector front line communities must defend lands and rivers from mines, power plants, mega-projects and industrial agriculture by expanding agro-ecology and transformative economies while building community-controlled energy and food systems. This post is only going to address energy systems which she believes should be dominated by renewables like wind and solar. The reality is that in order to convert to wind and solar the extractive impact on lands and rivers will be enormous because the rare earth metals required for those technologies require extensive mining. Because wind and solar are diffuse, vast tracts of land will be blanketed with turbines and panels. When those turbines and panels reach the end of their useful life they will have to be decommissioned and the materials disposed in landfills. My point is that when looked at holistically the probable impact of renewable energy on communities will be larger but, for the urban environmental justice activists the impacts will be moved from their communities elsewhere out of sight and out of mind.
The urban environmental justice activists most hypocritical position regards health impacts. Yeampierre advocates for a zero-risk approach to air pollution. It is not enough to meet (with the exception of ozone in New York) the National Ambient Air Quality Standards (NAAQS) that have protected the health and welfare in the United States for decades. The fact that the concentrations of all the air pollutants have dropped dramatically since the Clean Air Act is irrelevant because there still are elevated levels in disadvantaged communities relative to elsewhere even if those levels are less than the air quality standards. The activists argue that, for example, power plants in urban areas have to be replaced by renewable energy and energy storage based on epidemiological statistics that claim excess health impacts from air pollution amongst other confounding factors. That position is hypocritical because the extraction of the rare earth metals necessary for energy storage and renewable energy is done almost exclusively overseas where the health and environment protections are much weaker and labor protections nearly non-existent. As a result, there are real health and welfare impacts directly attributable to their solution as opposed to the statistical artifacts that support their supposed problem.
There also is hypocrisy associated with their description of the extractive economy. The unfortunate fact is that child labor is involved in the African mining industry. It is sad and telling about their objectives that the Climate Justice Working Group has not called for New York renewable energy and energy storage facilities to require that their mineral suppliers are certified by the Responsible Mineral Initiative or something similar.
Working Group Observations on Enabling Initiatives
She explained that the working group decided to present comments on the enabling initiative recommendations from two panels, transportation and housing & energy efficiency, because they represent opposite ends of the spectrum in terms of how well the panels incorporated environmental justice priorities. In other words, transportation did not address the pre-conceived notions of a “climate just” transportation system but the housing and energy efficiency checked all the boxes for their demands.
I annotated the slide used in her presentation with my italicized comments below:
Recognize that goals/benchmarks/accountability is essential
The recommendations need clear guidance on how benefits/investments will be defined, measured, tracked, and shared over the long term
Scoping plan must ensure data is available to accurately measure the success of implementing the CLCPA
I agree with this comment.
Better scrutinize every action for justice
Some of the recommendations presented false market-based solutions
The EJ community has historically been opposed to market-based solutions because they believe that they don’t prevent localized areas of high pollution. In the case of greenhouse gas emissions that is not a relevant concern so their problem is associated with co-pollutants. The EJ community’s air pollution goal is zero risk, i.e., zero emissions.
Provide greater clarity, reasoning, and purpose
Some goals such as the doubling of municipal-sponsored public transportation appear arbitrary without an analysis on the basis of the target
None of the enabling initiatives included any substantive documentation. As a result, I agree that more detail is needed to justify the enabling initiative recommendations.
Policies with significant implications like a feebate deserve more than a ‘handwave’. It sounds like ‘free money’. How does it actually work in practice?
I agree with this comment.
Provide explanation of how the social cost of carbon was incorporated
As far as I can tell the social cost of carbon has not been incorporated yet. It is another one of those pesky details that should be in the as yet unreleased documentation.
Edit jargon to plain speak, and remove vague, squishy language and strive to provide key details
In my opinion, the presentations by this working group exemplified vague jargon and a lack of details. Moreover, oftentimes understanding a technical topic requires knowledge of the jargon as detailed in a following section.
Fill in the gap of connectivity between regions of the state that rely on public transportation by prioritizing high speed rail and long-range bus service
I don’t think the state can afford high speed rail and I am sure that the effect on travel in the only corridor (New York – Albany – Buffalo) where it might be feasible would not provide any meaningful reduction in GHG emissions.
Refine transit-oriented development strategy to elevate its estimated GHG reduction impact by 2050 from medium to high by placing the most emphasis on vehicle mile travel reduction.
Transit-oriented development refers to mixed use (residential, commercial and business) development along public transit lines to reduce the need for personal vehicles. Theory is fine but in practical terms I don’t see this as meaningful solution away from New York City.
Deemphasize vehicle electrification as the topmost solution as it fails to address single occupancy vehicle associated issues. This hinders our ability to address the root cause of runaway transportation emissions, and its related link to systemic issues such as racism and poverty
Apparently, the environmental justice advocates have issues with single occupancy vehicles. In the suburbs and in rural areas single occupancy vehicles are a necessity. In order to convince those residents that there is a link to systemic racism and poverty issues there has to be a dialogue with the opportunity to challenge some of the presumptions but that approach was explicitly rejected by Yeampierre in her overview of climate justice.
The McHugh-Grifa presentation also used the transportation presentation as examples of some of the points made for the bullet points above. One of her concerns was that the transportation panel recommendation outline presentation was filled with jargon and vague or squishy language and gave some examples. For example, in slide 20, component for delivery, “make ready costs for support facilities”, she complained that “I have been doing this work for a while and I just don’t understand what that means”. Apparently in her background in music education, she never got around to the obvious issue that if you electrify public transit buses, the transit garages aka support facilities have to be set up to recharge the batteries and service entirely different bus components. In my conversations with an expert in this field he has pointed out many nuances and complications to this challenge that he has said that even the state’s bus electrification alleged experts don’t understand. While I agree that the outline doesn’t do an adequate job providing documentation for the recommendations, I also have to point out that the presentation was never intended to educate members of the public who have no background in this sector simply because of space limitations.
It got worse. She complained of three problematic themes in the transportation recommendations that were not clear enough. The first theme was that the recommendations only focused on “encouraging and incentivizing” behaviors rather than “concrete and enforceable policy change that would advance the systemic transformation of our transportation system that the climate crisis demands”. In the context of single occupant vehicle use that translates to a vehicle mile traveled policy limit which I believe will bring out yellow vest protests the instant it is proposed. The second theme was the need for clear metrics coupled with enforcement mechanisms as exemplified by the apparent failure of the transportation sector recommendations to meet the expected reductions targets. I suspect that the transportation panel had some concerns that the reality of the changes to the transportation system needed relative to what is politically palatable led to the lack of specific enforcement mechanisms. The last theme concerned public engagement. Recall that a key premise of the climate justice framework is that decisions should be made by the communities. Absent any technical expertise that is a recipe for disaster.
Just when I thought it could not get any more absurd, McHugh-Grifa complained that the transportation recommendations did not consider the potential effect of climate refugees. She said that:
As climate conditions worsen, we in our region anticipate that we will see an increase in climate migrants and refugees that move to our area from other parts of the states and countries. There is no indication that the transportation panel has taken these kinds of population shifts into account or is considering how the transportation needs of any given region may change over the coming decades
I agree that climate refugees will be a problem in New York but it will not be because of people moving into the state. Instead, if these draconian policies come to pass, there will be a mass exodus out of state.
Response to Transportation Advisory Panel Recommendations
Transportation is a key climate justice concern. However, I think that in general the working group and for that matter the transportation advisory panel vision for transportation is out of touch with the reality of transportation in the suburbs and rural areas. For example, McHugh-Grifa stated that doubling the service would still be inadequate. That brings up the question just how much of an improvement to service would be necessary to entice people away from their personal cars. For example, I cannot conceive of any scenario where I would use public transit to go grocery shopping. As disappointing as it may be for public transit advocates, the fact is that outside of New York City housing has evolved around the use of automobiles. Changing that dynamic would require massive transformation of the rest of the state’s infrastructure.
The specific response to the transportation recommendations was presented by Eddie Bautista, Executive Director of the NYC Environmental Justice Alliance, who has a B.A. from N.Y.U. and an M.S. in City and Regional Planning from Pratt Institute. His presentation starts at 28:20 in the meeting recording.
Bautista claims that environmental and climate justices groups across the county are opposed to emissions trading programs like cap and trade. He consistently refers to a single study that claims that these programs not only don’t reduce hot spots but they exacerbate them. The paper “Carbon trading, co-pollutants, and environmental equity: Evidence from California’s cap-and-trade program (2011-2015)” appears to be consistent with his claims. Note, however, that a subsequent study that looked at a longer comparison period that “emissions from sources subject to the cap declined 10% between the program’s launch in 2013 and 2018”. Because GHG emissions are a function of weather and economic conditions there is large annual emissions variability which I believe accounts for the differences between these analyses. Moreover, the complaint that cap-and-trade programs do not eliminate pollution hot spots demonstrates a fundamental misunderstanding of air pollution control strategies. Cap and trade programs are designed to address regional pollution problems like acid rain, ozone and global warming. For those regional pollutants, concentrations are only a concern over large areas and impacts are not localized. The Clean Air Act established air quality limits to address air pollution hotspots and every source has been evaluated to determine if it affects compliance with those limits. With the exception of ozone, New York meets all those air quality limits. Because ozone is a secondary pollutant, emissions from neighborhood power plants cannot create localized hot spots. As noted with respect to Yeampierre’s presentation, it appears that the only environmental justice acceptable level for air pollution is zero.
I annotated the slide used in his presentation with my italicized comments below:
Transportation Climate Initiative (TCI) flaws
Best available evidence shows cap and trade systems do not eliminate air pollution hotspots, and often exacerbate them
This is a fundamental misunderstanding of air pollution control strategies as described in detail above.
Like RGGI, funds generated by TCI are vulnerable to budgetary raids by the Executive and Legislature
I agree with this comment
Reforms to cap and trade are unlikely to remedy pollution disparities given the program’s inability to surgically reduce mobile source emissions which are more complex to regulate than stationary sources
Because cap and trade programs were not specifically designed to address local impacts from any sources this is true.
The inherent design flaws of cap and trade result in environmental racism
My impression is that environmental racism refers to any disproportionate impact and that the only acceptable solution is no impact whatsoever.
The inadequate involvement of EJ groups in the policy process reflects a profound failure of democracy, and bolsters the case for abandoning sector specific carbon pricing policies for a comprehensive carbon fee like that in the CCIA.
New York agencies did an extensive outreach process relative to involvement in the Transportation Climate Initiative. I attended several of their meetings and environmental justice advocates were always in attendance and, frankly, it seemed that the majority of attendees were from that segment of society at least at one of the meetings. I think this is a harsh and unwarranted criticism of the Transportation Climate Initiative stakeholder process.
Denial of Home Occupant Justice
Protect low and middle income renters by amending the provision on new market rate housing within Transit Oriented Development that is currently limited to home ownership to include renting and rent to own options
No comment – way down in the weeds
Clean Fuels Standard Concerns
Allowing high carbon fuel producers to meet their credit obligations by paying clean producers for their energy is a weak way to enforce the standard -as it lets them offset instead of eliminate their emissions -which by itself won’t guarantee that emission reductions and investments in overburdened communities occur at the necessary speed and scale required by the CLCPA
The Transportation Climate Initiative was not designed to meet New York CLCPA net zero societal GHG reduction targets. Instead, they were looking at moderate reductions and this offset option was part of that strategy. The real question is whether this initiative has value as part of the CLCPA control strategy because these points are valid.
Clean air necessitates an ‘electrify everything’ approach.
No comment, see below
Allowing vehicles to combust lower carbon liquid fuels that still emit criteria pollutants won’t eliminate air pollution hotspots
This comment is correct
The second slide had two topics. Bautista covered the electrify everything that moves topic and at 38:50 of the meeting recording, McHugh-Grifa discussed the hone in on equitable vehicle miles traveled reductions and the extra support for communities facing barriers topics. She concluded that we need systemic change so we “respectfully request the transportation panel give it another go, ideally with more input from EJ groups or at least more commitment to incorporate the feedback from EJ groups that they have already received”.
Electrify Everything that Moves
Adopt ZEV for medium and heavy-duty vehicles and carve out explicit targets for trucks and bus conversion that prioritize diesel emission reduction in air pollution overburdened communities
As noted previously, widescale implementation of electric vehicles has severe environmental consequences elsewhere
As important, advocates for electric vehicles ignore all the downsides that make this technology a non-starter for many.
Mandate rapid phase in of the conversion of the state’s fleet to ZEVs
While it may be easy to mandate that the state fleet to convert, the question becomes where is the money going to come from.
Rapidly expand policies to encourage uptake of EVs –like incentives and enhancement/expansion of charging infrastructure
When I attended the TCI stakeholder meetings at least one speaker extolled the virtues of electric cars. Based on my reading I believe that you can make the case for one as the second car in the family which could be used most of the time. The problem is that there are many instances where an EV does not make sense, e.g., the occasional long trip where in route charging would be necessary.
Hone in on Equitable VMT Reduction
Establish a New York State-supported Equitable (Fair & Affordable) Transit-Oriented Development (E-TOD) effort via the Regional Economic Development Councils or through a New York Statewide E-TOD Program.
Include at least 20% affordable housing minimum for all new TOD
Amend Municipal Home Rule Law to explicitly allow fees on new development to offset public transportation service costs
Require at least 50% of transportation sector climate monies to be spent on non-car programs
As noted before, I don’t think TOD is a viable alternative outside of the NYC metropolitan area so this strategy has limited value
Extra Support for Communities Facing Barriers
Within the Consolidated Funding Application (CFA) of the Regional Economic Development Councils, mandate prospective developers and employers to identify how their prospective projects (and related NYS funding requests) consider public transportation options for low-income workers.
Incentivize hiring of disadvantaged workers in transit manufacturing by enabling companies to get a credit for setting aside a certain proportion of their workforce for hiring them
Response to Energy Efficiency (EE) and Housing Recommendations
The Climate Justice Working Group made the point that this panel’s presentation was done better than the transportation panel and that they handled the climate justice considerations better. The response to the EE and Housing recommendations was presented by Rahwa Ghirmatzion, Executive Director of PUSH Buffalo who studied English literature and economics at University of Buffalo starting at 40:48 in the meeting recording. Because this article is already too long and because I don’t take exception to much of their comments on this panel’s recommendations my review will be much shorter.
Ghirmatzion made a good point that the recommendations did not acknowledge New York’s energy affordability goal that households should not be paying more than 6% of their income on energy costs. The point was also made that the baseline for state goals should be made available with a system to track progress relative to those goals. I agree completely.
Her presentation discussed the need to support the transition to electric heating/cooling/cooking quickly. The working group is convinced that people in disadvantaged communities want a “safety net style guarantee of renewable energy to every household”. I have a hard time reconciling those initiatives that I believe will markedly increase energy costs with EJ advocacy support for them. Given that there have been programs available for years where consumers can sign up for wind and solar power supply programs but participation has been abysmal, I believe that most ratepayers really only care how much it costs. How can the advocates push for programs that will increase costs?
In the second slide of the response to the EE and Housing panel, Ghirmatzion recommended additional actions. Of particular note was the suggestion to calculate costs and benefits holistically with considerations of the health impacts associated with poor indoor air quality and insufficient thermal comfort as well as the cumulative cost burden related to housing, energy, transportation, and healthcare. Those are very good points. There has been very little information on costs provided to date and total costs are the key. One final point regarding the suggestion to tweak energy efficiency programs. Energy efficiency has been part of New York energy programs for decades. I have doubts that there is much more that can be done and have yet to see an evaluation of effectiveness relative to the goals.
Because of the length of this post, I am not going to discuss the questions and answers session starting at 48:00 in the meeting recording.
However, I have to mention Yeampierre’s response to the question at 1:35:44 about replicable solutions that could be expanded to further climate justice goals. Her response at 1:36:49 illustrates my concern about lack of expertise leading to wasted time and effort related to the approach of advocacy panels setting policy. She argues that current projects that use the industrial waterfront have been successful and suggests that using the waterfront as a delivery hub could be appropriate. She suggested that this could be a way to connect to economically depressed farmers upstate by way of refrigerated barges to the waterfront to distribute healthy food. This is a non-starter. There is a reason that barges are used for bulk commodities that do not have delivery time constraints – they are slow. Healthy food is fresh food and the range of suppliers within even a day of the New York City waterfront is so small that they could not possibly supply any meaningful fraction of the needs of the City.
I don’t think anyone disagrees with the concept that disproportionate environmental impacts on disadvantaged communities are a bad thing and should be addressed. Unfortunately, the Climate Justice Working Group approach to this is fatally flawed. On one hand their overview of climate justice did not include the concept of compromise so their comments on the panel recommendations were not constructive criticisms, they were demands for change. Their criticism of the lack of detail in the recommendations is warranted but I don’t think the background and education of the working group is sophisticated enough to understand the nuances and unintended consequences of all the panel recommendations anyway. On the other hand, their apparent goal is elimination of all environmental impacts to disadvantaged communities. The reality of environmental regulation is that trade-offs and compromises are necessary because zero-risk policies are impossible to implement. More importantly, pushing for minimal risks in one location means that risks are increased elsewhere as I explained relative to the rare earth metals used for energy storage.
In my opinion, the Climate Justice Working Group’s rationales and recommendations are driven more by special interests and emotion than fact. The summary article on the Pacific NW heatwave by Dr. Mass included a section on the politicization and miscommunication of science that was evident in this presentation. I entirely endorse some of the comments he made:
“Hyping global warming puts unrealistic and unnecessary fear into the hearts of our fellow citizens.”
“Global warming is an issue we can deal with, but only if truthful, factual, and science-based information is provided to decision-makers and the nation’s citizens.”
Politicians have “put political agendas ahead of truth and we are all the worst for it”.
In this instance I am willing to give the environmental justice advocates a pass on science accuracy especially given that the CLCPA and the state spokesmen have consistently hyped unrealistic global warming fears. The bigger concern is the attitude of the Climate Justice Working Group vis-à-vis to any modification of their demands. Because some of those demands are based on scientific mis-understandings and ignore worse unintended consequences it is not in the best interest of society as a whole, as compared to their narrow constituency, to implement all of their demands.
Contrary to their belief the CLCPA says their role is to consult with the advisory panels and Climate Action Council not be the final arbiter of the enabling strategies of the scoping plan. My impression is that they have adopted a “take it or leave it” position regarding their recommendations. It will be interesting to see if the Climate Action Council adopts a scoping plan that addresses the science or bows to the emotion-based approach of the Climate Justice Working Group.
The CLCPA targets are ambitious: relative to a 1990 baseline there is a mandate for a 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050 as well as a requirement for 100% carbon-free electricity by 2040. There is no requirement for an assessment of technology and cost feasibility. In order to develop the plans to meet these targets the CLCPA set up ten groups to develop the plan to meet the greenhouse gas emission reduction targets of the law: the Climate Action Council, six advisory panels, and three working groups.
The Climate Action Council (§ 75-0103) consists of 22 members: 12 agency heads, 2 non-agency expert members appointed by the Governor, 6 members appointed by the majority leaders of the Senate and Assembly, and 2 members appointed by the minority members of the Senate and Assembly. Given that 14 members are appointed by the Governor and six more members are appointed by the Democratic majority that passed the legislation there isn’t any pretense for unbiased recommendations.
Climate Action Council Advisory Panels (§ 75-0103, provide recommendations to the council on specific topics, in its preparation of the scoping plan, and interim updates to the scoping plan, and in fulfilling the council’s ongoing duties. The law established advisory panels on transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, and agriculture and forestry and another panel on waste was added last fall. The panels are also supposed to provide input to the state energy planning board’s adoption of a state energy plan which will incorporate the recommendations of the council. Ostensibly the members of these panels were supposed to be subject matter experts but the reality is that the majority of members did not understand the complexities of the subjects of their panel and were more interested with social justice concerns and their personal advocacy agendas.
Consider, for example, the makeup of the power generation advisory panel. Because electrification of everything is a key implementation strategy, it can be argued that this is the most important panel. The CLCPA states that the “council shall convene advisory panels requiring special expertise”. It is no simple matter understanding how the New York electric system works and I believe that it requires a hard science education or electric sector experience. In my opinion, only five of the fourteen Power Generation panel members have the special expertise necessary. The draft and final enabling initiatives produced by this panel have been described as showing that New York has no idea whatsoever how to “decarbonize” its electric grid.
The Council and the advisory panels were populated mostly by people with overt agendas for greenhouse gas mitigation means that the scoping plan for decarbonizing the NY system will be based more on ideology than reality. Unfortunately, it gets worse because the CLCPA includes three working groups that make not attempts whatsoever to incorporate alternate considerations. The Just Transition, Environmental Justice, and Climate Justice Working Groups were all included in the CLCPA to cater to specific political demographics with only peripheral consideration of the alleged goal to address the “existential” threat of climate change.
The first group, Just Transition Working Group (§ 75-0103), was included to appease organized labor because the closure of fossil-fired power plants will have direct effects on union jobs. This panel is supposed to:
Prepare and publish recommendations to the council on how to address: issues and opportunities related to the energy-intensive and trade-exposed entities; workforce development for trade-exposed entities, disadvantaged communities and underrepresented segments of the population; measures to minimize the carbon leakage risk and minimize anti-competitiveness impacts of any potential carbon policies and energy sector mandates.
They are also charged with preparing a report that includes: the number of jobs created to counter climate change, which shall include but not be limited to the energy sector, building sector, transportation sector, and working lands sector; the projection of the inventory of jobs needed and the skills and training required to meet the demand of jobs to counter climate change; and workforce disruption due to community transitions from a low carbon economy. Note that there is no explicit requirement to determine the number of jobs lost directly due to the CLCPA or indirectly when businesses have to flee the state because of higher energy costs.
This post addresses the other implementation working group, the Climate Justice Working Group (§ 75-0111). The advisory panels are required to “coordinate with the climate justice working group”. The draft scoping plan that outlines how the CLCPA targets will be achieved “shall be developed in consultation with the climate justice working group”. Not surprisingly the final scoping plan has to also be “developed in consultation with the climate justice advisory group”. The group is also responsible for defining “disadvantaged communities” and will meet annually thereafter to review the criteria and affected communities.
The final working group established by the CLCPA is a permanent organization. The Environmental Justice Working Group (§ 75-0101). During the implementation phase each advisory panel is required to coordinate with the environmental justice advisory group and both the draft and final scoping plan are to be developed in “consultation with the environmental justice advisory group”.
The Climate Justice and Environmental Justice working groups have explicit charges. As noted, they are both supposed to coordinate with the advisory panels during the development of the draft and final scoping plans. The Department of Environmental Conservation (DEC) may establish an alternative compliance mechanism to be used by sources subject to greenhouse gas emissions limits to achieve net zero emission and are required to “consult with the council, the environmental justice advisory group, and the climate justice working group. In addition, the Climate Justice working group has specific requirements.
The CLCPA has an 85% emission reduction target but it also is “net zero”. The emissions from the remaining 15% are supposed to be offset by §75-0101,10 “Greenhouse gas emission offset projects”. These projects include: “natural carbon sinks including but not limited to afforestation, reforestation, or wetlands restoration; greening infrastructure; restoration and sustainable management of natural and urban forests or working lands, grasslands, coastal wetlands and sub-tidal habitats; efforts to reduce hydrofluorocarbon refrigerant, sulfur hexafluoride, and other ozone depleting substance releases; anaerobic digesters, where energy produced is directed toward localized use; and carbon capture and sequestration; ecosystem restoration” The final type of emission offset projects are those recommended by the council in consultation with the climate justice working group that “provide public health and environmental benefits, and do not create burdens in disadvantaged communities”.
In order to engender support for the Climate Act, legislators included §75-0115, community air monitoring program. This mandate requires DEC to prepare a program demonstrating community air programs in consultation with the climate justice working group. It is currently fashionable for environmental justice advocates to claim that the current air monitoring network established by the Clean Air Act to protect human health is inadequate. The “solution” is to do hyper-local air quality monitoring. I wrote a post on this topic concluding that inadequate monitoring technology and quality control specifications make the results from these systems barely credible.
Nonetheless, the CLCPA includes a second associated mandate that requires DEC, in consultation with the climate justice working group, to develop a strategy to reduce emissions of toxic air contaminants and criteria air pollutants in disadvantaged communities affected by a high cumulative exposure burden. I believe that the basis for this strategy will rely at least in part on the results from the community air monitoring program. One of the primary targets of this campaign against sources in disadvantaged communities are peaking power plants and I have written a series of posts on this topic. As far as I can tell, ozone and inhalable particulate health impacts provide the basis for the claims that these power plants are dis-proportionally affecting environmental justice communities. The fact that both are secondary pollutants that do not directly affect the neighborhoods around these power plants has been ignored to date.
The point should be made that participation on these panels is a burdensome chore. Over the past year, participants have had to endure many meetings and working sessions as well as reviewing information in preparation for the meetings. Many of the participants work for companies that will directly benefit from the transition like renewable energy developers and many more work for non-governmental advocacy organizations whose primary purpose is to foist the clean energy transition on the public in the name of solving the “existential” crisis of climate change. It is not immediately clear why environmental and social justice advocates would be willing to invest their time in this process. Cynic that I am I believe that following the money is a primary motivator.
Section § 75-0117, Investment of funds of the CLCPA mandates that:
State agencies, authorities and entities, in consultation with the environmental justice working group and the climate action council, shall, to the extent practicable, invest or direct available and relevant programmatic resources in a manner designed to achieve a goal for disadvantaged communities to receive forty percent of overall benefits of spending on clean energy and energy efficiency programs, projects or investments in the areas of housing, workforce development, pollution reduction, low income energy assistance, energy, transportation and economic development, provided however, that disadvantaged communities shall receive no less than thirty-five percent of the overall benefits of spending on clean energy and energy efficiency programs, projects or investments and provided further that this section shall not alter funds already contracted or committed as of the effective date of this section.
The point has often been made that the 40% goal is the floor and that more is appropriate. Of course, the primary discussion is just what programs should be funded and the Climate Justice Working Group is positioning itself to be the final arbiter of those decisions.
Unfortunately, the reality is that the CLCPA is supposed to be a greenhouse gas mitigation program and that funding of any project that does not directly lead to emissions reductions dilutes the cost-effectiveness of the investments. For example, the investments made with the proceeds of the Regional Greenhouse Gas Initiative have only been responsible for 5% of the observed reductions at a $858 per ton reduced rate because monies have been diverted like this mandate and because clean energy and efficiency programs are not very cost effective. Coupled with the facts that mitigation efforts are going to be expensive and the CLCPA does not incorporate a funding mechanism, this mandate will make reaching the targets even more difficult.
The climate justice working group has been created within DEC. There are representatives from: environmental justice communities, DEC, the Department of Health, the New York State Energy and Research Development Authority, and the Department of Labor.
Environmental justice community representatives shall be members of communities of color, low-income communities, and communities bearing disproportionate pollution and climate change burdens, or shall be representatives of community-based organizations with experience and a history of advocacy on environmental justice issues, and shall include at least three representatives from New York city communities, three representatives from rural communities, and three representatives from
upstate urban communities.
I think the biggest responsibility of the working group is to develop the criteria that define disadvantaged communities. The working group is supposed to work with DEC and the departments of health and labor, the New York State Energy and Research Development Authority, and the environmental justice advisory group to “establish criteria to identify disadvantaged communities for the purposes of co-pollutant reductions, greenhouse gas emissions reductions, regulatory impact statements, and the allocation of investments”.
The CLCPA establishes guidelines for the disadvantaged communities criteria. In general, there are supposed to be identified based on geographic, public health, environmental hazard, and socioeconomic criteria. Of course, the devil is in the details but those criteria “shall include but are not limited” to:
Areas burdened by cumulative environmental pollution and other hazards that can lead to negative public health effects;
Areas with concentrations of people that are of low income, high unemployment, high rent burden, low levels of home ownership, low levels of educational attainment, or members of groups that have historically experienced discrimination on the basis of race or ethnicity; and
Areas vulnerable to the impacts of climate change such as flooding, storm surges, and urban heat island effects.
Once the draft guidelines are prepared there are requirements for hearings, a public comment period and “meaningful opportunities for public comment for all segments of the population that will be impacted by the criteria, including persons living in areas that may be identified as disadvantaged communities under the proposed criteria”. Once the criteria have been established the group will meet no less than annually to review the criteria and methods used to identify disadvantaged communities. They “may modify such methods to incorporate new data and scientific findings”. Finally the climate justice working group shall annually “review identities of disadvantaged communities and modify such identities as needed”.
I researched the background of the nine at large members and four members from state agencies and summarized that information here. There is a significant spread of the quality of the at large members. Several are nationally recognized experts on environmental justice issues. Others have extensive experience advocating for environmental justice. Those people all are working at well known organizations. On the other hand, a few have little environmental justice background and seem to have been chosen to fulfill the geographical requirements.
With regards to the geographical requirements for three each representing New York City, Upstate Urban and Rural communities I don’t think rural disadvantaged communities are represented well. In the first place two represent the Adirondacks. That area is a special case with unique constraints for communities within the Adirondack State Park. No one comes from the communities in Appalachia and I think the needs and interests of those disadvantaged communities should have been represented.
There is another important point. While the background of many of the members is well suited for the charge to advise the Climate Action Council with respect to climate justice issues for disadvantaged communities, I did not see any member with appropriate technical education or experience to critique the technical enabling strategies of the advisory panels with one exception. There are some members with planning experience that could provide meaningful comments to the land use and local government advisory panel. As a result. I don’t think that technical criticisms from this working group on the advisory panel enabling strategy recommendations should carry much weight.
Similar to all the other panels and working groups, the membership of the Climate Justice Working Group is a mixed bag. Some are clearly experts in their fields. However, that does not necessarily mean that their opinions on all topics are meaningful. Moreover, given that advocacy appears to have been a primary criterion for membership the passion for their “cause” should be considered in the context of society as a whole.
At the time of this writing there isn’t much to draw any conclusions on the value of their recommendations. They have commented on a couple of advisory panel enabling strategies which I will discuss in an upcoming post but they have not proposed criteria for the definition of disadvantaged communities. Because at least 35 to 40% of the CLCPA project funding will be targeted to those communities that definition is important. Cynically, I believe that designs on that funding is a prime driver of the rationale to become a member.
In my post on the Energy Efficiency & Housing Advisory Panel scoping plan recommendations to the Climate Action Council I noted that in their presentation the first mitigation strategy is an initiative to modify building codes and standards as shown in the following slide. The plan is to amend the state codes for new construction, including additions and alterations, to require solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness. They propose to adopt these all-electric state codes for single family residences by 2025 and for multifamily and commercial buildings by 2030. The presentation notes that by 2030, more than 200,000 homes per year will be upgraded to be all-electric and meet enhanced energy efficient standards.
I think garnering support for this initiative is a major challenge for proponents. New York homeowners have extensive experience dealing with winter weather and heating their homes. Selling the changeover to an electric heating system will be a heavy lift particularly for anyone who has lived through a multi-day wintertime electric outage.
The panel recognizes this and included education as a possible mitigant many times throughout their recommendations. For example, one of the components required for delivery for Energy Efficiency & Housing Advisory Panel Enabling Initiative #4: Public Awareness and Consumer Education is to:
Support and scale up multilingual public and consumer education efforts through a large-scale, coordinated awareness, inspiration and education campaign; traditional and broad reaching media, digital communication, “influencer” style campaigns, user-generated campaigns, out of home displays, magazines, mailers, virtual tours; resources for installers, distributors, home-visiting workforce, other supply chain actors to educate consumers, customer-facing resources and tools.
When I read this I cringed because there are so many instances when the climate-related proclamations from the state are not just a little wrong they are off-scale wrong and can only be call propaganda. Propaganda is defined as material disseminated by the advocates of a doctrine or cause. There are many propaganda techniques including “card stacking”. This technique is a feature of the CLCPA:
It involves the deliberate omission of certain facts to fool the target audience. The term card stacking originates from gambling and occurs when players try to stack decks in their favor. A similar ideology is used by companies to make their products appear better than they actually are.
In this post I will present an email I recently received from the New York State Energy Research & Development Authority describing the use of heat pumps for home heating and cooling in the following section. I will then discuss aspects of the email that make heat pumps appear better than they actually are.
Even when the CLCPA was still a proposal it was obvious that electric heating would be necessary to meet the greenhouse gas emission reduction targets proposed. I wrote a post titled Air Source Heat Pumps In New York over two years ago that explains how heat pumps work and describing a research study that showed the problems with heat pumps in cold climates that make them worse than the NYSEDA description. I will summarize the technology and the fundamental problem here but if you are interested in more details, I refer you to my previous post.
According to the Department of Energy heat pumps are very efficient because they move heat rather than converting it from a fuel like combustion heating systems do. Air source heat pumps move energy from the air and ground source heat pumps move energy from underground water. Note that because ground source heat pumps require digging, air source heat pumps are the preferred retrofit technology. Unfortunately, there is a big problem with air source heat pump systems and improperly designed ground source heat pumps. In particular when the weather gets really cold there is insufficient energy in the air or underground water to provide adequate heat when it is transferred.
Myth Buster: The Heat Pump Edition
The following is the text from a NYSERDA email titled “Myth Buster: The Heat Pump Edition”. It also is available in a web link.
With the beautiful days of summer upon us, there’s no better time to reevaluate your home’s current heating and cooling options than right now.
If your current system is reaching its end-of-life or if you’re just looking for ways to save energy and money while keeping your home as comfortable as possible this summer, you may want to consider a heat pump as an alternative heating and cooling option. Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.
You’ve probably heard a few things around heat pumps and the New York State climate that may have you scratching your head, but we’re here to help dispel four of the most common myths around heat pumps to help put your mind at ease.
Myth #1: Heat pumps don’t work in cold climates.
This is one of the most common myths we hear about heat pumps – that they’re only effective in warm environments. The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit. Even in subzero temps, high quality heat pump units can heat up quickly and provide even, comfortable heating without cold spots throughout your home and without the need for supplemental heat.
Myth #2: Heat pumps create heat.
Heat pumps don’t actually create heat — they simply move it from one place to another. Even during the winter, there is some degree of heat that still exists in the air or the ground. Heat pumps remove this heat and transfer it into your home.
Myth #3: Heat pumps are useless during the summer months.
Although they are called “heat pumps,” these systems are actually two-in-one, capable of heating and cooling. During the summer, heat is drawn out of the home, and, through the use of a reversing valve, which essentially flips the flow of coolant through the system, allows air to be cooled before re-entering the home.
Myth #4: There is only one kind of heat pump.
When it comes to heat pumps, you actually have two primary options – a ground source heat pump or an air source heat pump. Also known as a geothermal heat pump, ground source heat pumps draw air from the ground and transfer it evenly into your home, and reverse the process during the summer. Air source heat pumps extract heat from the air outside and distribute it evenly into your home. As with geothermal heat pumps, the process is reversed during warmer months.
I will address the propaganda in the components of the NYSERDA email below.
In the introduction, NYSERDA claims “Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.” A moment’s thought raises the question: how can the type of heating system affect hot and cold spots? In order to make a heat pump viable, the structure has to be very well insulated and any air infiltration reduced as much as possible. That kind of structure will reduce the number of random hot and cold spots. As I understand it, the retrofit approach is to replace a fossil-fired furnace with a heat pump replacement. Any random hot and cold spots from issues with the existing duct system won’t be addressed by a heat pump per se. To address those issues the heating system ductwork would have to be replaced. Moreover, in order to make the heat pump viable the insulation and infiltration issues need to be addressed.
The first myth addressed is “Heat pumps don’t work in cold climates”. The American Council for an Energy-Efficient Economy published a paper that illustrates the cold climate region problem with air source heat pumps: Field Assessment of Cold Climate Air Source Heat Pumps (ccASHP). The report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps were directly compared to propane and heating oil furnaces. The report notes that “During periods of very cold temperatures when ccASHPs do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.” The NYSERDA document does not mention the need for a backup system and, frankly, it is not clear how retaining a fossil-fired backup system will be allowed by the CLCPA. As a result, the backup system will be highly inefficient radiant electric heat.
Figure 2 from the document graphically shows the problem. In this field study homes were instrumented to measure the heat pump and furnace backup usage. Backup furnace usage was relatively low and the heat pump provided most of the heat until about 20 deg. F. For anything lower, heat pump use went down and the furnace backup went up. Below zero the air source heat pumps did not provide any heat and furnace backup provided all the heat. NYSERDA claims “The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit”. Obviously when the temperature is lower than -13 aka when you want heat the most, an air source heat pump is worthless.
The second myth is “Heat pumps create heat”. I have no issue with the response itself but the comment “Even during the winter, there is some degree of heat that still exists in the air or the ground” does not address the flaw described earlier. In particular, there always is some heat in the air but the question is when does the amount of heat become so low that extracting usable heat is not viable.
The third myth is “Heat pumps are useless during the summer months”. This is a great advantage to this technology because they can be used in reverse in the summer to provide air conditioning. In more southerly locations this makes the technology a good choice as long as there is backup heating capability for the rare cold snap.
The last myth is “There is only one kind of heat pump”. I have no issue with this response.
To sum up my discussion, I believe that there are two problems with the plan to deploy air source heat pumps. While air source heat pumps might work most of the time the fact is that when the need for heat is greatest in New York, they won’t provide sufficient heat so a backup system is needed. I believe radiant electric heat will be the preferred option for air source heat pump conversions. When the CLCPA mandate for all electric heating is implemented along with electric vehicles I am sure that local electric distribution systems will have to be upgraded at considerable expense. Ultimately the problem is that these worst-case conditions for heat correspond to the worst annual wind and solar resource availability. Where is the energy for this heating boondoggle going to come from?
In several different proceedings I have voiced my concerns about air source heat pump technology in Upstate New York when temperatures are below zero. In those comments I referenced the results from Field Assessment of Cold Climate Air Source Heat Pumps. I recommended that NYSERDA do a similar analysis using the newer technology that allegedly eliminates the issues raised in the study. The response has been crickets. Until such time that there is a follow up study that supports NYSERDA’s claims and refutes the results of this study, I don’t believe any heat pump propaganda from NYSERDA.
There is another aspect to the plan to electrify home heating. I don’t think the system is going to work well during typical cold snaps and I have serious doubts about the worst-case polar vortex outbreaks. Unfortunately, the very worst case is an electric outage in the winter. I survived a multi-day electric outage in the winter using a gasoline powered generator to provide power to my natural gas furnace. The Department of Energy heat pump description noted that heat pumps move heat because they move heat rather than converting it from a fuel like combustion heating systems do. That overlooks the ability of combustion heating systems to store fuel for use when needed. That is a critical resource for electric outages that proponents of heat pumps ignore.
At the end of the day, I think there will be tremendous pushback when the all-electric heating requirements are rolled out. For me personally, the requirement for an all-electric home is a deal breaker for remaining a resident of the state. I don’t think I am the only one.
This is the fourth installment of my annual updates on the Regional Greenhouse Gas Initiative (RGGI) annual Investments of Proceeds update. This post compares the claims about the success of the investments against reality. As in my previous posts I have found that the claims that RGGI is a success are unfounded.
I have been involved in the RGGI program process since its inception. I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. 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.
RGGI is a market-based program to reduce greenhouse gas emissions. It has been a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector since 2008. New Jersey was in at the beginning dropped out for years and re-joined in 2020. Virginia joined in 2021. According to a RGGI website: “The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.”
The latest update was released on June 28, 2021. The Investment of RGGI Proceeds in 2019 report tracks the investment of the RGGI proceeds and the benefits of these investments throughout the region. According to the report, the RGGI states invested $217 million in auction proceeds and expect lifetime benefits of the RGGI investments made in 2019 to include $1.3 billion in lifetime energy bill savings and 2.5 million short tons of CO2 emissions avoided. The report notes that energy efficiency investments made up 40% of the 2019 total. Greenhouse gas abatement programs, which include carbon-reducing beneficial electrification projects, received 15% of 2019 investments and 18% of investments were directed to clean and renewable energy programs, with direct bill assistance receiving 19%. Not directly mentioned but available in the data are the estimates that administrative costs took up 6% of the proceeds and RGGI Inc a little over 1%.
In my article on the 2018 proceeds report, I argued that RGGI mis-leads readers when they claim that the RGGI states have reduced power sector CO2 pollution over 50% since 2005. I argued that the implication in the 50% claim is that the RGGI program had something to do with the observed reduction but the reduction between 2005 and the start of the program was 26% so clearly something else has been going on.
The important question is why did the emissions go down. I believe that the real measure of RGGI emissions reductions success is the reduction due to the investments made with the auction proceeds so I compared the annual reductions made by RGGI investments. The biggest flaw in this report is that it
does not provide the annual RGGI investment CO2 reduction values accumulated since the beginning of the program. In order to make a comparison to the CO2 reduction goals I had to sum the values in the previous reports to provide that information. The table Accumulated Annual Regional Greenhouse Gas Initiative Benefits Through 2019 lists the annual avoided CO2 emissions generated by the RGGI investments from five previous reports. The accumulated total of the annual reductions from RGGI investments is 3,259,203 tons while the difference between total annual 2005 and 2019 emissions is 83,494,425 tons. The RGGI investments are only directly responsible for 3.9% of the total observed annual reductions over the 2005 to 2019 timeframe! I believe that the average of the three years before the program started is a better baseline and using that metric there was a 63,756,767 annual ton reduction (50%) to 2019 and RGGI investments accounted for 5%. Better but still pathetic.
Although proponents claim that this program has been an unqualified success I disagree. Based on the numbers there are some important caveats to the simplistic comparison of before and after emissions. The numbers in the previous paragraph show that emission reductions from direct RGGI investments were only responsible for 5% of the observed reductions. In a detailed article I showed that fuel switching was the most effective driver of emissions reductions since the inception of RGGI and responsible for most of the reductions.
There is another aspect of this report that is mis-leading and after arguing with RGGI and New York State about the issue, I have concluded that the deception is intentional. In particular, I believe that a primary concern for GHG emission reduction policies is the cost effectiveness of the policies and I have argued that this report should provide the information necessary to determine a cost per ton reduced value for control programs for comparison to the social cost of carbon. If the societal benefits represented by the social cost of carbon for GHG emission reductions are greater than the control costs for those reductions, then there is value in making the reductions. If not, then the control programs are not effective.
In order to compare the cost effectiveness of the RGGI investment proceeds to the social cost of carbon, annual CO2 reductions must be used because the social cost of carbon is an estimate, in dollars, of the present discounted value of the benefits of reducing annual emissions by a metric ton. (note that my numbers do not include the relatively small conversion to metric tons for a proper comparison to the social cost of carbon.) The Proceeds report always includes a caveat that the states continually refine their estimates and update their methodologies, but the annual numbers are not updated to reflect those changes. Ideally to get the best estimate of the annual numbers the RGGI states should provide the revised annual numbers for each year of the program.
Because that is not the case, I have had to rely on the original annual numbers provided in previous editions of the report. As noted previously, I had to sum the values in the previous reports to provide that information as shown in the table Accumulated Annual Regional Greenhouse Gas Initiative Benefits Through 2019. The accumulated total of the annual reductions from RGGI investments is 3,259,203 tons through December 31, 2019. According to Chart 5 in the Proceeds report, RGGI investments total $2.796 billion over that time frame. The appropriate comparison to the social cost of carbon is $2.796 billion divided by 3,259,203 tons or $858 per ton reduced.
The Proceeds reports only provide the avoided tons of CO2 over the lifetime of the RGGI investment funded control programs. Dividing the $2.796 billion by the lifetime avoided CO2 emissions yields a value of $65. The Biden administration is re-evaluating the social cost of carbon values but for the time being has announced an initial estimate of $51 per ton which is close to the lifetime avoided value.
The 2019 RGGI Investment Proceeds report tries to put a positive spin on the poor performance of RGGI auction proceeds actually reducing CO2. The alleged purpose of the program is to reduce CO2 from the electric generating sector to alleviate impacts of climate change. Since the beginning of the RGGI program RGGI funded control programs have been responsible for 5% of the observed reductions. The report does not directly provide the numbers necessary to calculate that estimate which I have come to believe is deliberate.
Another example of deliberate obfuscation is the publication of lifetime avoided emissions but not the cumulative annual emission reductions for RGGI-funded control programs. The value of GHG emission reduction programs is “proven” if the cost per ton is less than the social cost of carbon. However, the social cost of carbon value is for an annual reduction of one ton. When the report only publishes the lifetime avoided emissions it is easy to assume that the total investments divided by the lifetime avoided emissions provides a value that can be compared to the social cost of carbon especially when no caveat is included warning of this problem. As a result, a naïve conclusion would be that RGGI investments are providing $65 per ton for emission reductions when in fact the investments cost $858 per ton reduced. That order of magnitude difference has been glossed over in response to my comments on this issue. I think it is obvious that proper accounting provides an inconvenient result.
The DEC updates to their Value of Carbon Guidance are available atValue of Carbon Guidance and updated supplemental materials. The most notable change is that DEC settled on a 2 percent discount rate as the central value, but will also report impacts at one and three percent. All calculated values are updated in the new version as a result of this action.
In my previous post I noted that the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal. I believe that the guidance approach is wrong because it applies the social cost multiple times for each year of an emission reduction. I submitted comments and recommended that the Guidance be revised. When I reviewed the recent revisions, I noted that the there was no change to the guidance so I sent a follow up email asking whether my concern had been discussed. My correspondence with DEC on this topic is available here.
In brief my concern is that the Guidance section entitled “Estimating the emission reduction benefits of a plan or goal” includes the following example:
The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $123 per metric ton. The value of the reductions in 2021 are equal to $123 times 5,000 metric tons, or $635,000; in 2022 $124 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.
I explained that it is inappropriate to claim the benefits of the annual reduction over any lifetime or to compare it with avoided emissions. Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $123 or $6,150,000, but the guidance approach estimates a value of $36,410,000 using this methodology. The social cost calculation sums projected benefits for every year subsequent to the year the reductions are made out to the year 2300. Clearly, using cumulative values for this parameter is incorrect because it cumulatively counts those benefits repeatedly. I also contacted social cost of carbon expert Dr. Richard Tol about the use of lifetime savings and he stated that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”. Note that Dr. Tol is using the social cost of carbon nomenclature rather than value of carbon label.
I received the following response:
We did consider your comments and discussed them with NYSERDA and RFF. We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level.
When applying the Value of Carbon, we are not looking at the lifetime benefits rather, we are looking at it in the context of the time frame for a proposed policy in comparison to a baseline. Our guidance provides examples of how this could be applied. For example, the first example application is a project that reduces emissions 5,000 metric tons a year over 10 years. In the second year you would multiply the Value of Carbon times 10,000 metric tons because although 5,000 metric tons were reduced the year before, emissions in year 2 are 10,000 metric tons lower compared to the baseline where no policy was implemented. You follow this same methodology for each year of the program and then take the net present value for each year to get the total net present value for the project. If you were to only use the marginal emissions reduction each year, you would be ignoring the difference from the baseline which is what a benefit-cost analysis is supposed to be comparing the policy to.
The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action.
DEC believes that their comparison of policies under consideration relative to the no-action baseline is appropriate but they ignore the ultimate purpose of the value of carbon. At the end of the day, it should be used to determine whether the control policies instituted to meet the reduction targets of the CLCPA provide social value by reducing GHG emissions at a control rate ($ per ton) that are less than the projected social costs. Instead, the integration analysis will compare not only the emission reductions per year but also the avoided emissions relative to a no-action baseline over the time frame of the policy.
The calculation of avoided emissions is a public relations ploy along the lines of the claim that an emissions reduction policy is equivalent to taking so certain number of cars off the road. It may be a very nice number but what is it good for? Consider, for example, the CLCPA target of a 40% reduction in greenhouse gas (GHG) emissions from 1990 levels by 2030. In order to evaluate compliance with that target the state will calculate emissions in 2030 and compare them to 1990 levels. Evaluation of the CLCPA targets includes no consideration whatsoever of avoided emissions or cumulative reductions.
More importantly, in the context of the value of carbon, it is absolutely incorrect to use avoided emissions or lifetime reductions. DEC’s Value of Carbon guidance defines the social cost of carbon as:
An estimate, in dollars, of the present discounted value of the future damage caused by a metric ton increase in emissions into the atmosphere in that year or, equivalently, the benefits of reducing emissions by the same amount in that year. It is intended to provide a comprehensive measure of the net damages—that is, the monetized value of the net impacts—from global climate change that result from an additional ton of emissions.
Glaringly, there is no mention of avoided emissions or cumulative reductions.
If the societal benefits of GHG emission reductions are greater than the control costs for those reductions, then there is value in making the reductions. If that is not the case then New York should re-think its mitigation targets and policies and concentrate on “no regrets” policies such as adaptation and resiliency investments. If New York wants to make a contribution to climate change mitigation, then money should be invested in research and development to produce mitigation measures that are cheaper than the social costs.
It is obvious listening to the Climate Action Council meetings that the “plan” is to prove the value of the advisory panel emission reduction recommendations by calculating the social costs and comparing them to the reduction costs. Obviously, this is “thimble and the pea” time and the CLCPA hucksters will be inflating the benefits at every opportunity and discounting the costs at the same time. DEC’s response to my comment concluded that “The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action”. In the first place the concept of a value on carbon is contrivance designed to justify mitigation policies. Secondly the DEC values of carbon proposed exceed the Federal values to further inflate the “benefits” by choosing assumptions that get higher values. To top it all off, now we know that the CLCPA integration analysis will use the values of carbon incorrectly to further inflate the benefits.
Another theme in the Climate Action Council meetings is constant reference to their allegiance to the “science”. In this instance the science says apply the value of carbon only to emission reductions and not to avoided emissions or cumulative emission reductions. That fact is inconvenient so the real “science” is ignored.
I am a numbers guy and I am terrified by what appears to be the general perception that numbers don’t matter when it comes to an emotional issue or pre-conceived idea. This post explains what I mean by numeracy and offers examples of the problems I worry about related to climate.
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.
One of my responsibilities over my career was reporting data from meteorological monitoring stations to regulatory agencies primarily concerned with air pollution transport. The first problem is that the monitors had to be located where they measured the wind speed and direction that represented the flow in the area. Ideally the site had to be located in an open field with no nearby obstructions that could affect the wind direction. Once the wind vane was up and running it was not enough to just report all the data collected. There is a vital quality control check to make sure the data are realistic. To do that I developed a program to review the data for oddities. For example, if the wind direction did not vary at all for several hours that period would be flagged for further review. If the temperature was below freezing and there was precipitation at the monitor then I would check the local weather station for freezing rain. If that was observed then it was clearly appropriate to flag the data as missing and note in the data submitted to the regulatory agency that there was freezing rain. The regulatory agency could easily check that decision and in the end, everyone was confident that the data submitted accurately represented the air pollution transport conditions in the area.
Another responsibility of mine was to report data from continuous emissions monitoring systems (CEMS) from power plants. Coming from my background it seemed logical that the data should be reviewed in a similar fashion as the meteorological data. The problem is that there are physical relationships between weather parameters that make it much easier to flag problems. Eventually I developed a system to review the data in a reproducible manner basically by looking for outliers and trends in the data. My process flagged data that needed to be checked. It was possible to compare the raw data against operating information and other information to see if the outlying data were just odd or incorrect. The analysis did not say that the data were wrong only that they needed to be reviewed and validated.
In some cases, the numbers were measured correctly but were not representative. For example, during startup and shutdown fuel combustion processes are inefficient and some pollutant levels are high. However, if your concern is the long-term average you don’t want to weigh those short-term values too much because they bias the result. The Environmental Protection Agency uncritically used the CEMS data in a couple of instances and proposed inappropriate limits as a result.
I am irritated by those who make claims that climate change effects are being observed now whenever there is an extreme weather event or a new weather record and have documented instances where the message is incorrect. In the first place, the message is never that there might be good news associated with warming and more CO2 but always it is a sign of imminent, inevitable Armageddon. I could write many posts on examples of this but just want to make a point about temperature trends. Recall that when setting up a meteorological sensor you have to consider whether it will make representative measurements. When measuring temperature trends, a big concern is whether conditions around the sensor are changing and over long periods of time that is difficult. In addition, changes to the observing methods or instruments themselves all affect the trend and have to be considered when evaluating the results. Ultimately measuring temperature trends is not easy and picking and choosing trends has over-hyped the observed global warming. Not considering the data correctly for the task at hand undermines the concept that CO2 is the control knob for climate change.
There is another major problem. The National Oceanic and Atmospheric Administration publishes the “official” temperature trends and it has been shown that there is a very strong correlation between the average temperature adjustments (final vs. raw) and the atmospheric CO2 concentrations. This is clear evidence that the adjustments to the temperature record are being made to match the CO2 is the control knob of climate theory.
Data numeracy recognizes that irregularities need to be reviewed. Inconsistent data patterns do not prove that there is a problem only that further review is necessary. If the data are audited in an open and transparent manner then everyone can be confident in the result. Sadly, too many people will not accept numerical results that run counter to their pre-conceived notions and biases.
My personal experiences with data reporting were in regulatory contexts that in the big scheme of things don’t matter much. But I think the data I submitted was unambiguous and believe that my results could withstand scrutiny. On the other hand, the implications of global warming are a big deal because they are being used as the rationale to completely over-haul the entire energy system of New York and the world. Unfortunately, much of the numerical evidence purportedly proving that global warming is occurring is ambiguous and the results do not standup to close scrutiny. My concern is that when I have gone through the process to evaluate data to check a climate change impact and shown that the claim is not supported by the evidence it has not been uncommon that people reject the results.
For example, an arithmetic average of mostly startup data was used to say that facilities were not using their air pollution equipment correctly.