Author: rogercaiazza

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered. This is a summary of articles that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article 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.

Video

In a new short film written for Net Zero Watch, Dr John Constable reminds us that human wealth in the broadest sense, from the smallest gadget to a tolerant and diverse society, is an improbable state of physics that results from work done by energy.

Video description of a new motion picture entitled Climate: The Movie funded by the CO2 Coalition, Heartland Institute, and CFACT.

Let’s Discuss the Facts Now About New York’s Energy Future

I highly recommend this description of the New York Jobs new social media campaign, “Energy Red Flag for NY” intended to raise public awareness of the opportunities, challenges and costs of implementing New York’s ambitious efforts to decarbonize the state’s economy. Working closely with The Business Council of New York State, New York Jobs Now’s goal is to provide data and analysis to help educate the public on the impact of these ambitious climate goals. Our reasoning is very clear and we write this op-ed with an eye towards clearly stating our goals and reasoning behind this campaign.

The summary concludes:

Responding to climate change, and implementing New York’s CLCPA, can provide immediate and long-term benefits for New Yorkers, but will also be complex, expensive and disruptive. The implementation decisions we make will determine how well we balance costs and benefits. New Yorkers should be demanding more complete, more accessible information on major state climate change programs – how much they cost, how they are being paid for, what they are achieving, and how New Yorkers are benefiting.

Hatred of Fossil Fuels

Francis Menton asks “What is it about fossil fuels and the people who produce them that brings forth such uncontrolled hatred, anger, and vengefulness in a very large segment of the population?”  After pointing all the value of concentrated and affordable energy he points out that those who advocate to ban fossil fuels continue to use them.  He suggests:

Here’s my proposal for the next phase of this game. The fossil fuel producers, either individually or through trade associations, should pick a state, logically a relatively small one (Vermont might be a good place to start), and go to the legislature with this proposition: Ban us! Make the sale or use of fossil fuels in your state illegal, starting at some early date, like for example tomorrow. We will then withdraw. And your citizens will then find out whether they prefer life with fossil fuels, or without them.

In other words, stop being such pansies. It’s time to call their bluff.

My only disagreement with his proposal is that I would start smaller with a virtue-signaling college town.  My candidate for calling the bluff is Ithaca, NY.

On the other hand, Maine was considering legislation that would prohibit natural gas companies from charging ratepayers for the construction and expansion of gas service mains and gas service lines beginning Feb. 1, 2025 (see Maine Debates Democrat Bill to Limit New Natural Gas Customers).  Jim Willis notes that the language of the bill has been modified to account for reality. 

Note that the usual suspects are clamoring for similar natural gas limitations in New York.  They hope to sneak it through as part of the budget because if it was considered openly the public would catch on and demand a reality slap.

New Jersey Referendum on Fossil-Fired Power Plants

A state Senate committee on Monday advanced a bill that would authorize a public referendum on amending the state’s Constitution to ban construction of new power plants that burn natural gas or other fossil fuels.  But the measure was changed to allow the construction of such plants if they are to be primarily used as emergency backup power sources.  This addresses the fact that wind and solar resources have their lowest availabilities when needed most.

Offshore Wind

I have been meaning to do a post on offshore wind issues.  David Wojick has done some good work lately.

• Offshore wind violates the Clean Air and Clean Water Acts
• Proposal to Use Different Foundations  One of my concerns is that the monopiles proposed for the monster turbines require disruptive pile driving that I think will adversely affect fisheries.  Wojick describes a less disruptive method.

One of the “features” of the wind and solar deployment is the use of “community benefit agreements” aka bribes.  Robert Bradley notes that Ocean City, MD refused offshore wind developer payola.

Heat Pumps

Ed Reid describes the ultimate risk of heat pumps – what happens when there is a blackout.

Parker Gallant notes that heat pumps increase electric usage a lot:

 A contact of mine here in Ontario had recently informed me he had a heat pump installed to replace his furnace and told me his electricity usage had quadrupled* since having the heat pump installed!  Quiring him about the total costs of installation and the potential rebate he informed me the total, including conversion of his service from 100 amp to 200 amp as well as a new hydro line cost almost $21K and his grant rebate will be $7,100 so his net costs will be almost $14K!**  At a current approximate cost of 18 cents/kWh we should suspect that will add somewhere between $1,200 to $2,000 per year to his electricity bill or perhaps about what he was previously paying for a natural gas supply! 

Fossil Fuels Make Us Sick

Blair King writing at the A Chemist in Langley blog has been a continuing inspiration to me because of his pragmatic approach.  In this post he addresses claims by the Canadian Association of Physicians for the Environment that air pollution from fossil fuels has severe health impacts.  They claim that  “air pollution from the burning of fossil fuels is one of the leading causes of premature mortality in Canada” but King shows “the citation used does not support that claim.”  The second claim to be examined is “the suggestion that fossil fuel pollution is responsible for one in seven premature deaths in Canada”.  He demonstrates that the claim is “so obviously wrong as to be incredibly puzzling and clearly represents a failure in the peer review process”. 

A slightly different version of this article also was published at Watts Up With That.

An article about response plans for pandemics by Joe Nocera writing at the Free Press described the plans by the scientist credited for eradicating smallpox for combatting an epidemic.  I was struck by the parallels between the differences between his recommendations and the lockdown plan response to Covid and the Climate Leadership & Community Protection Act (Climate Act plans to transition the electric system to net-zero greenhouse gas emissions.

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

Overview

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

D. A. Henderson

The Free Press has a weekly series of articles, The Prophets, about “fascinating people from the past who predicted our current moment and make our world more understandable today.”  Joe Nocera’s article “spotlights D.A. Henderson, the epidemiologist who warned that pandemic lockdowns won’t stop a disease but could instead lead to a public health disaster.”  It is a very interesting article and I recommend it highly.  He writes:

In 2006, ten years before his death at the age of 87, the legendary epidemiologist D.A. Henderson laid out a plan for how public health officials should respond to a major influenza pandemic. It was published in a small journal that focused mainly on bioterrorism—and was quickly forgotten.

As it turns out, that paper, titled “Disease Mitigation Measures in the Control of Pandemic Influenza,” was Henderson’s prescient bequest to the future. If we had followed his advice, our country—indeed, our world—could have avoided its disastrous response to Covid.

Nocera describes Henderson’s background.  After graduation from medical school, he took a job at the U.S. Communicable Disease Center—the original name for the Centers for Disease Control and Prevention, or CDC.  In 1960 as the head of the CDC’s new disease surveillance department smallpox was “high on his list of concerns—and for good reason. Ancient, airborne, and highly contagious, smallpox was estimated to have caused around 300 million deaths in the twentieth century alone.”  At that time smallpox was under control in the United States but he was worried about the possibility that an infected person could come and start an outbreak.  “When the World Health Organization announced a program aimed at eradicating smallpox, Henderson’s superiors at the CDC transferred him to the WHO in 1966 to take charge of what many scientists believed was a futile mission.”

There was an effective vaccine for smallpox but many thought that it wasn’t possible to vaccinate enough people to eradicate the disease.  Henderson’s plan was to place doctors and volunteers in all the places where the disease was still rampant and respond to breakouts as quickly as possible.  Quarantines and better vaccination technology enabled people to rapidly vaccinate everyone associated with a local breakout of the disease.  Henderson was the driving force to implement the plan across the world.  Nocera states:

In 1980, after two years without a single recorded case of smallpox, the World Health Organization declared it eradicated. Science writer Richard Preston, who wrote the introduction to Henderson’s book on the effort, described this feat as “arguably the greatest lifesaving achievement in the history of medicine.”

Pandemic Response

During G. W. Bush’s Administration, a program to develop a plan for a pandemic was put in place:

This was prompted by the book he brought on vacation in 2005, The Great Influenza, a terrifying account of the 1918 flu pandemic estimated to have killed 50 million people worldwide. Bush had already been caught flat-footed on 9/11. He did not want the government to be unprepared in the case of a killer virus. So he ordered that a plan be devised for responding to such a deadly microbe. “Look,” the president said, “this happens every hundred years. We need a national strategy.”

Nocera explains the response developed:

When a team of government scientists completed the plan two years later, among its central tenets was that schools and other institutions should be closed, and that there should be “reduced contact among adults in the community and the workplace.” This meant lockdowns. This was exactly the opposite of the wisdom about pandemics Henderson had acquired during his long career. He tried to tell them that, but his words fell on deaf ears.

The lockdown plan was based on a computer model advocated by Robert Glass, a senior scientist at Sandia National Laboratories in New Mexico:

Robert Glass found that when he entered different variables on how to stop a respiratory virus from spreading, the most effective way was to close schools—along with other parts of society as necessary. Glass managed to get this model to the two government scientists leading the team developing Bush’s pandemic plan, Dr. Carter Mecher and Dr. Richard Hatchett, who quickly embraced it.

Though none of them were epidemiologists, Mecher, Hatchett, and Glass were convinced that computer modeling would transform epidemiology. In The Premonition, Glass reflected on old-school scientists like Henderson with a kind of pity. “I asked myself, ‘Why didn’t these epidemiologists figure it out?’ ” he told Lewis. “They didn’t figure it out because they didn’t have the tools.” Tools like computer models.

At this point I was struck by the similarity between these modelers and the academic energy system modelers.  In particular, the arrogance that their models are the be all and end all tool to address the problem at hand and the condescension towards experts in the field.     

Nocera notes that Henderson tried to respond:

Henderson, on the other hand, believed that basing pandemic mitigation strategies on hypothetical models—models that themselves were based on hypothetical assumptions—could lead policymakers deeply astray. He said that people behaved in unpredictable ways that models could not capture.

Before the plan was finalized Henderson and other epidemiologists met with the modeling team.  The meeting did not go well with the epidemiologists all “berating the Bush team for failing to back up their draconian shutdown proposals with real-world evidence”.

But Mecher and Hatchett stuck by their model, and that was reflected in the pandemic plan, which was published in 2007. Henderson never stopped believing that the path the Bush administration chose was potentially disastrous.

The paper Henderson and his three younger colleagues wrote in 2006, after Henderson’s meeting with Bush’s team, was their last-ditch effort to stop the lockdown plans of the modelers. In retrospect, it was more than a mere journal article. It was a warning about what public health should and shouldn’t do during an outbreak of a highly contagious respiratory illness. It was also a manifesto about the purposes, and limits, of public health.

As he and his co-authors wrote in the 2006 paper:

What computer models cannot incorporate is the effects that various mitigation strategies might have on the behavior of the population and the consequent course of the epidemic. There is simply too little experience to predict how a 21st century population would respond, for example, to the closure of all schools for periods of many weeks to months.

We now know exactly how school closures affected the nation. The answer is very badly.

Nocera describes the negative consequences.  For example, the performance of students during the lockdown was disastrous and will have long-term effects.  If the lockdown had been effective at stopping the spread of the virus there would at least be a mitigating factor.  Nocera quotes Michael Osterholm, the prominent University of Minnesota epidemiologist, , “Look at what happened in China. They locked down for years, and when they finally relaxed that effort, they had a million deaths in two weeks.”

Parallels to the Net-Zero Energy System Transition

D. A. Henderson was a hands-on epidemiologist.  His mentor taught him the value of “shoe-leather epidemiology” which is shorthand “for the activities of an epidemiologist who left his office to personally investigate epidemics—collecting data and interviewing patients and officials”.  He also demonstrated hands on leadership in the fight to eradicate smallpox.  My point his position was developed based on personal experience.

My primary concern is the New York Climate Leadership & Community Protection Act net-zero transition.  As part of that transition the Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  Throughout the CAC deliberations of the draft scoping plan the State never refuted the claims by academic energy modelers that no new technologies would be needed for the transition and that there were no reliability issues. There have been two modeling approaches for the transition plan.  The entities responsible for electric system reliability rely on bottom-up models based on decades of experience with the all the components of the electric system.  On the other hand, the basis of the Scoping Plan is modeling by academics that is a top-down approach.  I am convinced that the top-down modeling to date overlooks too many critical aspects of the electric system to be credible.  That the state has not reconciled the differences between the New York Independent System Operator electric system projections and the analyses performed by the New York State Energy Research & Development Authority is a prescription for the same disastrous outcome as the pandemic response.

Conclusion

I have enough modeling experience to opine on their use.  Observations always trump model projections.  The reliance on models like the Global Climate Models used to claim that there is an existential threat from climate change can never be properly verified by comparison to observations.  That must always be kept in mind but it has been totally ignore in the New York process.  In addition, the future energy system has to be modeled.  The net-zero transition energy modeling is in two camps.  The academic top-down approach can be verified but the results are unimpressive.  Even the bottom-up models used by the entities responsible for electric system reliability have issues but there is a constant improvement based on refinements to address observations.

This article clearly shows that the Covid response should have relied on the epidemiologists whose observations suggested a different approach more akin to what Sweden did.  “Sweden’s death rate wound up being one of the lowest in the world—4 percent during 2020 and 2021. The U.S. excess death rate in the same period was 19 percent.”  I fear that ignoring the experience of responsible energy experts and relying on theoretical energy system modeling will have similarly disastrous impacts. 

Finally, note that the United States plan for the next pandemic has to be changed.  I can only hope that the advice of D. A. Henderson will be heeded this time.

For the first two months of the year the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) have been working on the  New York Cap-and-Invest (NYCI) Program stakeholder engagement process.  Although I have not posted on this process since I discussed the cost projections, I have been evaluating the pre-proposal outline of issues.  This post summarizes the comments I submitted.

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

Overview

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

Cap-and-Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program.  The program works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate Leadership & Community Protection Act (Climate Act).”  In addition to the declining cap, it is supposed to limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries. The stakeholder engagement process is supposed to refine the proposal over the next several months, DEC will and NYSERDA will propose regulations by summer, and the final rules are supposed to be in place by the end of the year.

Late last year DEC and NYSERDA released the pre-proposal outline of issues that included a long list of topics.  The Agencies said that they are “seeking and appreciate any feedback provided on these pre-proposal program leanings to inform final decisions in the State’s stakeholder-driven process to develop these programs.”  The Pre-Proposal Outline topic list follows:

• The Mandatory Greenhouse Gas Reporting       Program (forthcoming 6 NYCRR Part 253)
  • Types of GHG Emission Sources 
    • Minor Modifications      
    • Major Modifications      
  • Threshold Categories     
  • Data Collection 
  • Verification       
• The Cap-and-lnvest Program             
  • Obligated Sectors and Entities    
  • Demonstrating Compliance        
    • Compliance Periods       
    • Allowance Retirement Obligations        
  • Establishing a GHG Emissions Cap and Allowance Budget          
    • Setting the 2025 GHG Emissions Cap   
    • GHG Emissions Cap Trajectory             
    • Establishing Annual Allowance Budgets        
    • Implementation of Non-Obligated Adjustment   
    • Banking Adjustments     
  • Emissions-lntensive and Trade-Exposed Industries         
    • Identification of EITEs    
    • Emissions Intensity        
    • Trade Exposure 
    • Threshold for EITE Designation       
    • EITE Emissions Allowances             
    • Application and Annual Reporting
    • Consignment of EITE Allowances        
  • Increasing Affordability via Potential Electric Utility Consignment
  • Program Stability Measures and Cost Containment     
    • Price Floor        
    • Cost Containment Reserve (CCR)    
    • Emissions Containment Reserve (ECR)   
    • Price Ceiling      
    • Allowance Banking        
  • NYCI Program Considerations to Ensure No Disproportionate Impacts in Disadvantaged Communities  
    • No Offsets in NYCI          
    • Other Potential Regulatory Mechanisms     
    • Complementary Programs and Requirements         
  • Auction Logistics and Mechanics             
    • Implementation of Auctions             
    • Registration Requirements             
    • Auction Format
    • Simplified Bidding Option             
    • Publication of Results    
    • Initial Auction Period     
  • Market Integrity and Market Manipulation Prevention            
    • Prohibition of Collusion 
    • Auction Purchase Limits
    • Holding Limits  
    • Minimum Hold Times    
    • Associations      
    • Market Monitoring        

Responding to each of these items is an enormous effort and the agencies requested comments by March 1.  Providing substantive comments is very difficult because of a lack of documentation.  There were three second-stage engagement webinars in late January and the session recording and a slide deck is available for each which is the primary source of information.   The agencies promised to provide more documentation but a spreadsheet with some of the data used in the presentations was not available in a usable format until February 29.  The documentation provided does not include narrative descriptions of the analyses.

This perfunctory stakeholder process is consistent with all previous Climate Act stakeholder processes.  The Climate Action Council’s Scoping Plan has been described as a  “true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.”  Similarly, the modeling analyses for the NYCI proposal use an avalanche of technical jargon and impressive sounding phrases to suggest credibility and discourage questions.  They do not provide adequate information for detailed review. 

One of the key questions to be addressed is the limits on emissions set by the allowance auctions.  The modeling analysis must determine the expected emissions starting in 2025 to set the auction limits.  As far as I can tell the analyses used for NYCI projections are updates of the Integration Analysis for the Scoping Plan completed in early 2022.  A lot has changed since that time as inflation, supply chain, and other issues have increased prices and delayed implementation, but it is not clear if those problems were used to modify the analysis.  The Integration Analysis projections have never been reconciled with electric system projections by the New York Independent System Operator.  There has been no acknowledgement of the comments made on the Integration Analysis much less any attempt to incorporate issues raised.  My point is that I do not believe that there is any reason to bother providing detailed comments because past history indicates they will not be considered. 

Core Principles of Cap-and-Invest Program

Instead of wasting my timeaddressing specific technical issues, the comments I submitted only addressed general issues.  I focused my comments on the NYCI principles.  According to the NYCI website, Governor Hochul laid out five core principles for the Cap-and-Invest Program:

Affordability – Governor Hochul’s Consumer Climate Action Account will deliver at least 30 percent in future Cap-and-Invest proceeds to New Yorkers every year to mitigate consumer costs.

Funding a sustainable future – the Climate Investment Account established in the FY24 Budget will direct two-thirds of future Cap-and-Invest proceeds to support the transition to a less carbon-intensive economy.

Climate leadership – The program will be designed with the capacity to link with other current or future programs to further catalyze a nationwide movement towards carbon pricing, which can lower the price of the transition overall.

Creating jobs and preserving competitiveness – The program will launch new investment in industries that will create tens of thousands of good paying, family sustaining jobs of the future that can lift up entire communities.

Investing in disadvantaged communities – Cap-and-Invest will prioritize the frontline disadvantaged communities in our state that for far too long have suffered from pollution and environmental injustice.

The remainder of this article describes my comments on these principles and one overarching concern.

New York Auction Proceed Investment Effectiveness

There is an overarching issue with NYCI planning.  I believe that supporting ambitious clean energy investments is more difficult than acknowledged.  In my comments on the 2024 New York State Energy Research & Development Authority (NYSERDA) Regional Greenhouse Gas Initiative (RGGI) Operating Plan Amendment I explained that I had reviewed the historical investment results of RGGI auction proceeds and found that  RGGI has not been very effective at making emission reductions.  This is the template for NYCI, and the results are not encouraging.  According to Table 2 in Semi-Annual Status Report through December 31, 2022, the cumulative annual net greenhouse gas emission committed savings are 1,725,544 tons through the end of 2022.  That is 9.5% of the observed reduction of 16,196,531 tons since the three-year baseline before the start of RGGI in 2009. I conclude that the primary reason for the observed electric sector emission reductions in New York was due to fuel switching due to low natural gas prices and not RGGI investments. 

These observations are relevant for the future of electric sector emission reductions required for NYCI. In the electric sector, fuel switching is no longer an option in New York.  Coal is no longer used and oil emissions from NYCI affected sources are as low as they are going to get without retirement of oil-fired sources.  The average CO2 emissions reduction per year from RGGI investments has been 95,716 tons since 2013.  New York Part 242 CO2 Budget Trading Program specifies an annual reduction of RGGI allowances of 880,493 per year starting in 2022 and continuing to 2030.  That reduction is nearly ten times more than the reductions from RGGI auction proceed investments.  The Climate Act is going to require even more emission reductions.  Electric generating unit owners and operators have no options available for additional emission reductions other than reducing their operating times.  It is incumbent upon NYCI to invest auction revenues to effectively incentivize and subsidize carbon-free generation and reduce energy use so that the affected sources can reduce operations and not jeopardize system reliability.  The same issues are present for all other energy sectors.  There are no low-hanging options for emission reductions in New York.  If the sources are unable to reduce operations safely, then the Climate Act targets will be jeopardized.

My RGGI Operating Plan Amendment comments determined the cost effectiveness of RGGI investments for reducing emissions.  I found that the cumulative annual net greenhouse gas emission committed savings are 1,923.951 tons and that cumulative total investments are $945,900,000.  That equates to $492 per ton removed.  The 2023 Update to the NYS Value of Carbon Guidance lists the social cost of carbon dioxide, at a 2% discount rate, as $120 per short ton and $391 at a 1% discount rate.  This indicates that the investments are not producing emission reductions at a rate that is less than the societal benefits which suggests a fundamental problem with the NYSERDA investment strategies.  It also indicates that providing sufficient funds for NYCI emission reductions will be a challenge.

In my comments related to this issue I compared the allowance trajectory needed to meet the Climate Act mandates with the proposed allowance prices.  I found that the proposed allowance prices and allowance reduction trajectories are incompatible with the observed RGGI investment results such that the mandates will not be met

Affordability

The Hochul Administration has never clearly admitted the expected costs of the Climate Act net-zero transition.  I believe this is deliberate because the costs are politically toxic.  The first principle “Craft a program to deliver money back to New Yorkers to ensure energy affordability” is an attempt to claim the costs are under control.

My comments raised the point that there is an important tradeoff ignored in this principle. A fundamental component of a greenhouse gas emissions market control program is raising energy prices to incentivize the adoption of zero-emissions technologies.  If costs do not increase, then the public does not have any reason to invest in the more expensive zero-emissions technologies necessary to reduce emissions.

Another issue with any carbon cost scheme is that it is regressive affecting those least able to afford to pay more for energy the most.  I commented that delivering money back to New Yorkers should prioritize low- and middle-income consumers least able to afford regressive energy price increases with investments in programs that reduce their energy use.  This should cut their energy costs and will reduce emissions.

Funding a Sustainable Future

Another bit of missing documentation concerns the funding necessary to make the emission reductions necessary to meet the Climate Act mandates.  The primary Climate Act emission reduction strategy is to displace fossil fuel energy use by building wind and solar while electrifying buildings and transportation.  This principle acknowledges that this needs to be addressed: “Support ambitious clean energy investment”.

My comments emphasized the need for investment in zero-emissions technologies that can displace greenhouse gas emitting technologies.  NYCI allowance allocations must be consistent with Climate Act mandates.  No documentation of a feasibility analysis of the costs and deployment schedule for the proposed control strategies has been mentioned, much less provided.  Ideally, the Integration Analysis projections should be compared to the observed results so that the analysis can be updated.  In my Scoping Plan comments I evaluated bits and pieces but could only nibble around the edges.  Importantly I found issues even at that level that were never acknowledged,

Climate Leadership

The political slogan to “Catalyze other states to join New York and allows linkage to other jurisdictions” has little value.  I do not believe that it is possible to link to other jurisdictions as long as New York GHG emission accounting is different.  Incompatible features with the states of California and Washington and the Province of Quebec include the use of Global Warming Potential based on a 20-year period, the inclusion of upstream and downstream emissions, and the use of offsets.  My comments said that the State must make its accounting compatible or abandon this principle.

Creating Jobs and Preserving Competitiveness

One of the favored Hochul constituencies is labor so the “Protect existing jobs and support new and existing industries in New York” principles was included.  My comments argued that results in Europe suggest that the idea that transitioning away from fossil fuels and maintaining existing Emissions-Intensive and Trade-Exposedindustries is impossible. Robert Bryce explains:

The headline on a February 9 Bloomberg article concisely sums up Europe’s unfolding disaster: “Germany’s days as an industrial superpower are coming to an end.” The article says, “Manufacturing output in Europe’s biggest economy has been trending downward since 2017, and the decline is accelerating as competitiveness erodes.”  All across Europe, industrial capacity is shrinking. Last month, Tata Steel announced it would close its last two blast furnaces in Britain by the end of this year, a move that will result “in the loss of up to 2,800 jobs at its Port Talbot steelworks in Wales.”

These slides and the ongoing destruction of European heavy industry bring to mind the trenchant lines that John Constable of Britain’s Renewable Energy Foundation delivers in our new five-part docuseries, Juice: Power, Politics & The Grid.  Constable, who is also the energy editor at the Global Warming Policy Foundation, delivers a stark warning., he says, “I tell decision-makers in the United States to study the European example very, very carefully. I mean, you have no excuse for not looking at Europe and learning. We’ve tested this for you.”

I do not believe it is possible to create more jobs than lost due to the increased costs inherent in a net-zero transition.  My comments stated that this principle cannot be achieved unless there are triggers to pause implementation when established differences in energy costs are exceeded.

Investing in Disadvantaged Communities

I do not think that the general public understands that the Climate Act includes a strong emphasis on climate justice “to ensure that frontline and otherwise underserved communities benefit from the state’s historic transition to cleaner, greener sources of energy, reduced pollution and cleaner air, and economic opportunities”.  The relevant principle “Ensure 35%+ of investments benefit Disadvantaged Communities” is a direct response the Climate Act requirement to “invest or direct resources in a manner designed to ensure that disadvantaged communities receive at least 35 percent, with the goal of at least 40 percent, of overall benefits of spending.”

New York’s climate justice community organizers have the misplaced belief that peaking power plants in New York City are “perhaps the most egregious energy-related example of what environmental injustice means today”  and are demanding that they be shut down as soon as possible.  However, in the “Role of Cap-and-Invest” webinar the following slide describes the sources that create inhalable air pollution burdens in New York.  It points out that:

• Individually controlled (permitted) stationary sources yield a minority of the air pollution emissions in New York.
• In 2020, electric generation units represented 8.5% of non-wood fuel combustion PM25 emissions in NY, and other permitted sources represented approximately 3.5%.
• Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources.

My comments noted that NYCI should focus on Disadvantaged Community investments that address the emissions from the buildings and transportation sectors that the NYCI analysis shows are the primary contributors to air quality impacts in those communities. 

The same activists have also latched on to outlier analyses that claim that market-based programs lead to disproportionate impacts in disadvantaged communities and are lobbying for market restrictions.   Emission trading programs are an effective solution for emissions like greenhouse gases that have regional or global impacts but are not designed to address local impacts of specific sources.  The Pre-Proposal Outline described the regulatory programs that address local issues.  My comments argued that those programs should be used to address local issues and NYCI should not be modified to try to address co-pollutant emissions with local impacts.

Discussion

One of the characteristics of the proposed net-zero Climate Act transition is over-reliance on the presumption that control strategies that have worked elsewhere will work in this application.  NYCI is a prime example.  However, past performance does not guarantee future success.  This is especially true if fundamental design components change.  Previous successful Environmental Protection Agency allowance caps have been based on feasibility whereas the Climate Act caps are aspirational political limits that have not been tested for practicability.  Options of limits on trading and banking allowances have been proposed that are incompatible to any emissions trading program.  An overarching issue is that control options for SO2 and NOx control are different than for GHG which has unacknowledged implications. 

My submittal included comments on the proposed additional limits on the distribution of allowances intended to address real and imagined issues with past programs.  I did not describe them here because there are too technical.  My comments noted that all these patches overly complicate the program and may or may not have the desired effect while risking unintended consequences.

Conclusion

Hochul’s NYCI principles are political slogans destined to fail.  Claiming affordability is possible is unlikely because NYCI is going to markedly increase prices.  Politicians have glommed on to the auction proceeds and dictated how they should be distributed without consideration of the need to fund effective GHG emission reduction programs.  The goal to link with other current or future programs to further catalyze a nationwide movement towards carbon pricing is impossible with New York’s current GHG emission accounting requirements.  Creating jobs and preserving competitiveness ignores the observed effects of net-zero in Europe.  It is appropriate to invest in disadvantaged communities, but no proof has been offered that those least able to afford increased energy prices will not be adversely impacted even with this principle.

I believe that the political calculus driving NYCI implementation is perverting the effectiveness of this market-based program to the point that it will not work.  I do not think that New York’s leadership understands how best to make climate policy work.  Last year I described the book Making Climate Policy Work.  The authors recommend clear thinking and strategy as opposed to “Efforts spent tilting at ephemeral, magical policy solutions waste scarce resources that should instead be invested in things that work.”  The goal of their book is to explain how market-oriented climate policies have fallen far short and how they might be modified so that they work.  NYCI is just such a magical policy solution that has been modified so it will not work.  I believe NYCI will flounder on the shoals of reality.