Pragmatic Environmentalist of New York Principle 3: Baloney Asymmetry Principle

This is one of the principles that that describe my pragmatic environmentalist beliefs.

I updated this on May 8, 2017 to add references for the lake effect snowstorm example and lake temperature data.

Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”

Brandolini’s link is to a presentation on the problem and includes recommendations for dealing with it in the context of the managerial leadership. However it is directly relevant to environmental issues as well.

Consider this example of global warming causing severe weather. In November 2014 there was a massive lake-effect snow storm in Western New York. New York’s Attorney General said the snowstorm was evidence of needed action on climate change. Slate followed the event with an article “proving” the claim.

In order to repudiate the global warming trigger claim the lake effect mechanism has to be explained and the relevant data from the event compiled. The Slate article explained that lake effect snow is caused by a temperature difference between a body of water and the air over the lake. The BS claim is that because the water is warmer then the storm was worse. However the alignment of the wind with the lake, the depth of the cold air layer, and the change of wind direction with height all contribute to the severity of a lake effect snowstorm.

To repudiate the BS claim these other factors have to be explained and the necessary data to show how they affected the storm compiled and presented. It turns out that the primary factor causing the extraordinary snow amounts with this particular storm was that the wind direction stayed constant for much longer than normal. That being the case how did global warming contribute to constant winds? Moreover, when I checked the actual lake temperature with the average lake temperature it was more or less the same as the average. The Slate article relied on average temperature data but not the data from the event.   If global warming were the cause then why wasn’t the lake warmer than average during the event?

Update May 8, 2017: References for the lake effect snowstorm example and lake temperature

Lake Effect Snowstorm November 17 – 19, 2014

Average Lake Erie Temperature Period of Record 1992 – 2016

  • November 19: 9.7 deg. C
  • November 20: 9.5 deg. C
  • November 21: 9.4 deg. C

Actual Lake Erie Temperature during the event – All three days were colder than average!

  • November 19, 2014: 8.9 deg. C
  • November 20, 2014: 8.2 deg. C
  • November 21, 2014: 7.5 deg. C


Pragmatic Environmentalist of New York Principle 2: Sound Bite Environmental Issue Descriptions

This is one of the principles that that describe my pragmatic environmentalist beliefs.

Sound bite descriptions necessarily only tell one side of the story because they have to fit space available. As a result they frequently are mis-leading, not nuanced, or flat out wrong.

Sound bites are brief recorded statements (as by a public figure) broadcast especially on a television news program or a brief catchy comment or saying. In this principle, I would expand the definition to include the core information that “everyone knows” about a particular topic. In today’s society they unfortunately represent an inordinate share of the public’s knowledge of an environmental issue.

In my, admittedly limited, experience trying to describe a technical issue or project to the press or a public relations person the interview often led to innocent mis-characterizations. If the audience does not have relevant background and you are not experienced talking to that kind of audience to include appropriate background information, the resulting sound bite can be mis-leading.

Because there are space and time constraints there is no room for the background caveats to explain the nuances of the issue. This limitation also can be primarily innocent.

However, there can be more sinister implications to the sound bite when the story is politically motivated or fits the agenda of an organization. In these cases noble cause corruption can lead the author of the sound bite to deliberately characterize the issue incorrectly by selectively choosing the information included and not including key caveats.

Whatever the cause, the problem for pragmatic environmentalists is that correcting the record won’t be a sound bite so the audience that only has the patience to hear the sound bite may ignore the correction or lose interest in the complete story. Moreover space or time may not even be available to provide the clarifying information.

Pragmatic Environmentalist of New York Principle 1: Environmental Issues are Binary

This is one of the principles that that describe my pragmatic environmentalist beliefs.

In almost all environmental issues there are two legitimate sides. Pragmatic environmentalism is all about balancing the risks and benefits of both sides of the issue. In order to do that you have to show your work.

While this might seem patently obvious presented in this fashion consider how often the public discourse on an environmental issue is just a long list of environmental impacts that “everyone knows” and suggestions that those impacts will be catastrophic.

Consider this example: “For decades, power plants in our communities here in Western Queens have strongly contributed to increased asthma rates and increases in hospitalizations and ER visits that exceed the average in Queens,” said Councilman Costa Constantinides.

It is generally accepted that asthma rates have been increasing but the problem is that over the same period where they are increasing ambient pollution levels have been going down. Consider the EPA Air Quality Trends at New York City information that shows that from 2000 to 2015 ozone is down 16.7%, inhalable particulate matter is down 31.7% and sulfur dioxide is down 85.1%. These data suggest that increasing asthma rates are not the result of increasing pollution rates contradicting the environmental impact that “everyone knows” causes increasing asthma rates. For a comprehensive evaluation of the EPA science related to particulate matter health impacts I recommend “Scare Pollution: Why and How to Fix the EPA”.

Pragmatic environmentalists recognize that air pollution causes health impacts. However the risk that additional societal investments for increased pollution control could not provide the intended benefits has to be considered. In particular, if society spends money to reduce power plant emissions below the rates that have contributed to the lower observed pollution levels it may not improve asthma rates and worse may divert money that more appropriately should be invested into research determining why asthma rates are increasing so that the actual causes can be addressed.

Replacement Power for Indian Point


Since his election New York’s Governor Andrew Cuomo has threatened the closure of the Indian Point Energy Center located 25 miles north of New York City and in January 2017 finally announced its closure by April 2021. Cuomo claims that Indian Point produces 2,000 megawatts of electrical power and that “more than enough replacement power to replace this capacity will be available by 2021”.

However, when you look at what has been permitted to be built within that time frame it is not clear that is as straight forward as suggested. In the first place, Indian Point’s nameplate capacity is 2,150 MW not 2,000 as described. Nuclear power is characterized by high capacity factors and because Indian Point provides over 20% of New York City’s power the location of the replacement generation matters. The Champlain Hudson Power Express transmission line has been permitted to bring 1,000 MW of Hydro Quebec hydropower to New York City. The only other large generation resource that has been permitted close to New York City is the Cricket Valley Energy Center, a proposed 1,000 megawatt combined-cycle, electric generating plant. So nominally these two facilities can replace 2,000 MW of Indian Point but as shown in this post the devil is in the details.

Cuomo’s Indian Point Closure Plan

As part of his state of the state proposals, Governor Andrew M. Cuomo announced the closure of the Indian Point Energy Center by April 2021. As described in the press release the Governor’s position is:

  • Replacement Power: Indian Point produces 2,000 megawatts of electrical power. Currently, transmission upgrades and efficiency measures totaling over 700 megawatts are already in-service. Several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power. Together, these sources will be able to generate more than enough electrical power to replace Indian Point’s capacity by 2021.
  • Early Close Date: Entergy Corp. has agreed to cease all operations at Indian Point and will shut down the Unit 2 reactor in April of 2020. Unit 3 will be shut down in April of 2021. Unit 1 reactor was permanently shut down in October 1974 because the emergency core cooling system did not meet regulatory requirements. In the event of an emergency situation such as a terrorist attack affecting electricity generation, the State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively.
  • Negligible Bill Impact: The Public Service Commission’s Indian Point Contingency Plan and other planning efforts have ensured that more than adequate power resources are able to come online by 2021 to ensure reliability of the power grid. Given these planning efforts and likely replacement resources, the plant’s closure in 2021 will have little to no effect on New Yorkers’ electricity bills.
  • No Net Increase of Emissions Due to Closure: The Governor’s leadership on energy and climate change will ensure that Indian Point’s closure will not have an adverse impact on carbon emissions at the regional level. Through the Regional Greenhouse Gas Initiative, the state will continue to drive reductions in greenhouse gases across the power sector. Further, the Governor’s Clean Energy Standard to get 50 percent of New York’s electricity from renewables by 2030 is the most comprehensive and ambitious mandate in the state’s history to fight climate change, reduce harmful air pollution, and ensure a diverse and reliable energy supply at affordable prices.

Other Side of the Story – Replacement Power

There are two aspects of power generation that have to be considered when discussing replacement power: the potential power output or name plate capacity and the actual generation produced. The New York State Independent Operator annual load and capacity report, the “Gold Book” provides that information. The name plate capacity of Indian Point 2 is 1,070 MW and Indian Point 3 is 1,080 MW. The average net generation from 2011 to 2015 from Indian Point 2 was 8,530 GWh and from Indian Point 3 was 8,422 GWh or 16,953 GWh from the facility. My point is that the net generation is the key parameter for replacement not the capacity.

In order to determine whether the Governor’s plan holds water we have to parse the press release. The first suggested component is “transmission upgrades and efficiency measures totaling over 700 MW that are already in-service”. I have trouble understanding how these measures will replace observed generation. The aforementioned NYISO 2016 Gold Book describes distinct transmission projects approved by the PSC as part of the Indian Point Contingency Plan in October 2013 that were projected by the Transmission Owners to be in service by summer 2016 and also notes that it also included 125 MW of additional demand response and combined heat and power resources to be implemented by Consolidated Edison, some of which is already in effect. Presumably these projects are part of the 700 MW mentioned in the press release.

However, the contingency plan was developed to specifically address the problem that New York City is essentially a massive load pocket. Because most of New York City and Long Island are on islands they are a limited number of transmission lines into the City so the location of the generation matters. Moreover, because one of the City blackouts occurred because of a disruption to transmission into the City, reliability planning is a very important. My guess is that these in-service upgrades and measures are critical to that requirement. However because they were in place and Indian Point generation did not go down they do not represent actual displacement of the energy produced. Maybe it won’t be needed in New York City but it was used elsewhere and must be replaced.

The press release notes that “several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power.”   I assume that the hydropower replacement refers to Champlain Hudson Power Express. As noted previously the only other New York City are large generation resource that I know of is Cricket Valley.

According to the Champlain Hudson Power Express web site the project will bring up to 1,000 megawatts (MW) of clean, renewable power to the New York metro area. For the purposes of this analysis assume that this power can be provided 100% of the time. With that assumption, Champlain Hudson Power Express provides 8,760 GWh of power so we only have to replace 8,193 GWh of Indian Point Generation.

According to the Cricket Valley web site this is a proposed 1,000 megawatt (MW) combined-cycle, electric generating plant in Dover, NY. I could not find a proposed capacity factor (actual generation divided by the maximum potential generation) so assumed 80%. In that case, the net generation 7,008 GWh so the remaining generation needed is 1,185 GWh.

Therefore, in order to displace the actual average generation produced by Indian Point additional generation capacity capable of 1,185 GWh is needed. Implicit in the Governor’s plans is that renewable energy will be part of this replacement. Rather than trying to explain the difficulties of that approach myself, I refer you to the Planning Engineer’s explanation that Not all Megawatts are Equal. If the problems enumerated in this post could be overcome the total generation produced by 21 NYS industrial wind facilities in 2015 was 3,983 GWh so it appears that seven more wind facilities could produce the remaining generation. Note however, that the total wind energy nameplate capacity is 1,892 MW with a capacity factor of 28% in 2015. Because Indian Point generation is dispatchable that means true replacement energy has to produce dispatchable power and that requires storage. Moreover, the timing of when wind is available means that more nameplate capacity would be required than necessary at first glance. There are similar concerns relative to the use of solar renewable energy. So I remain unconvinced that replacement will be as easy as proposed.

Other Sides – Timing, Bill Impact and Emissions

Each of these topics could have their own post but I am only going to address each briefly.

The schedule is for Entergy Corp. to shut down the Unit 2 reactor in April 2020 and Unit 3 in April 2021. The State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively. Both the Champlain Express and Cricket Valley projects have been permitted but neither has started construction. The expected construction time for Champlain Express is three and a half years which means that it will not be ready by April 2020. Because natural gas combined cycle plants have relatively short construction times that facility probably will meet the first closure date if construction begins soon. I strongly believe that no new generation facility greater than 25 MW in New York State can be permitted in less than five years because of the extraordinary permitting requirements in place so nothing else could be permitted and constructed by the second closure date. So I expect that the extensions will be needed.

The Governor claims there will be negligible bill impact because of planning efforts and likely replacement resources. I am not an economist but the expected costs of Champlain Express $2.2 billion and Cricket Valley $1.5 billion have to be paid for somewhere. Surely the costs to continue operating Indian Point are less than that. Why won’t pre-mature retirement of this resource have a bill impact?

This plan is supposed to lead to no net increase of emissions due to closure. The emphasis has always been on carbon “pollution” and the press release is careful to claim no adverse impact on carbon emissions at the regional level skirting the question whether NY emissions will increase. In fact even if Cricket Valley is the only fossil replacement power for Indian Point there were will be an increase of over 3,630,484 tons of GHG emissions (Table 4-2 in the Cricket Valley DEIS). The missing pollutant is Nitrogen Oxides. The final Cross State Air Pollution Rule allowance budget and the Governor’s policies on allowance distributions could very likely lead to a problem covering emissions with allowances (a topic for a separate post). If the generation gap from the closure of Indian Point is made up of New York’s existing natural gas plants and Cricket Valley then there could over 400 tons of additional NOx emissions. Emissions in the 2016 ozone season were 6,521 and the allowance budget is only 5,135 tons. New York State has aggressively pursued NOx reduction policies and there are not many opportunities left for additional reductions so any increase is problematic.

Cuomo Proposes a Lower Regional Greenhouse Gas Initiative Cap

I had intended to make my first post a description of what I hope to do at this website. However, I want to comment on an issue that has come up and have decided that an example of what I hope to do is better than a description.

On January 9, New York Governor Cuomo presented the 14th proposal of his 2017 State of the State: He proposed lowering the Regional Greenhouse Gas Initiative (RGGI) Cap by 30% between 2020 and 2030. Let’s look at both sides of this issue.


The Regional Greenhouse Gas Initiative ( is a cooperative effort by nine Northeastern and Mid-Atlantic States to cap and reduce CO2 emissions from the power sector. Because emissions dropped much more than expected, the RGGI states revised and lowered the 2014 RGGI cap to 91 million short tons. The RGGI CO2 cap then declines 2.5 percent each year from 2015 to 2020. The current policy is that the cap will remain flat after that. Cuomo proposes to further reduce the cap from 78.2 million tons in 2020 to 75.1 million tons in 2021, declining to 54.6 million tons in 2030.

Cuomo’s Side of the Issue

According to the press release

In New York, RGGI has led to a 46 percent reduction in carbon emissions from affected power plants and a 90 percent reduction in coal-fired power generation. To date, New York State has generated close to $1 billion in RGGI proceeds, which help fund clean energy and emission reduction programs. Under the current policy, the RGGI cap remains consistent after 2020 and emissions remain flat region-wide. By reviewing the RGGI program and adjusting the cap to reflect the progress made in just a few short years, New York and neighboring states will continue to reduce emissions annually after 2020 and ensure that power sector emission reductions continue through 2030.

The Governor’s proposal to reduce RGGI’s cap an additional 30 percent between 2020 and 2030, builds upon Governor Cuomo’s landmark clean energy programs, including the Clean Energy Standard, established by the Governor in August 2016 to require 50 percent of New York’s electricity to come from renewable energy sources by 2030. An additional component of this plan includes capturing the carbon benefits of zero-emission nuclear power. 

Pragmatic Environmentalist Side of the Issue

While it is probably not fair to ask for supporting documentation for a press release, the Governor’s landmark clean energy programs have been remarkable for the lack of implementation information so developing a response is difficult. Nonetheless it is possible to show that the press release sound bite is at best, misleading. Consider this quote: “In New York, RGGI has led to a 46 percent reduction in carbon emissions from affected power plants and a 90 percent reduction in coal-fired power generation.” The implication is that were it not for RGGI these reductions would not have occurred.

The Environmental Energy Alliance of New York (EEANY) submitted a relevant white paper to RGGI on June 6, 2106 archived under the April 29 2016 stakeholder meeting section at The white paper notes that there was a paper on this topic : Murray, Brian C., Maniloff, Peter T., Why Have Greenhouse Emissions in RGGI States Declined? An Econometric Attribution to Economic, Energy Market, and Policy Factors, Energy Economics (2015), doi:10.1016/j.eneco.2015.07.013. This paper concluded that “The analysis shows that after the introduction of RGGI in 2009 the region’s emissions would have been 24 percent higher without the program, accounting for about half of the region’s emissions reductions during that time”. The presentation further suggested that “The other half is due to recession, complementary environmental programs and lowered natural gas prices.”

There also was a relevant Congressional research service report Ramseur, Jonathan L., April 27, 2016: The Regional Greenhouse Gas Initiative: Lessons Learned and Issues for Congress, Congressional Research Service, 7-5700, R41836, The Regional Greenhouse Gas Initiative: Lessons Learned and Issues for Congress. There was no attempt to quantify the specific emissions impact but the author noted that

“Although actual emissions were ultimately well below the original emissions cap, the cap’s existence attached a price to the regulated entities’ CO2 emissions. Because the cap level was above actual emissions, the allowance price acted like an emissions fee or carbon tax. Although the cap likely had limited direct impact on the region’s power plant emissions, the revenues generated from the emission allowance sales likely had some impact on emission levels in the region.”

The White Paper includes an analysis that I prepared to quantify the change in emissions due to RGGI. I used data from EPA’s CAMD Data and Maps website to look at the changes in CO2 emissions in the RGGI states by fuel type. The analysis did not attempt to reconcile differences between RGGI and all the other programs in this database. Annual data were downloaded for the years 2006-2015 for the RGGI states for all programs. Non-RRGI affected units are included and some of the included units report only six months of the year so this is not an exact analysis. Nonetheless, these data can give us an idea of how RGGI emissions were reduced.

For this analysis (Table 1 in the white paper) the 2006-2008 data were averaged to establish a pre-RGGI baseline and the total and fuel-type specific annual emissions were subtracted from the baseline to get the reductions during the RGGI program. For the facilities in this dataset in 2015 there has been a 41 million ton reduction from the 127 million ton baseline or a 32% reduction. Note that coal and residual oil emissions dropped 57 million tons from the baseline of 85 million tons or 67%. Natural gas emissions increased 15 million tons and other solids (mostly wood) increased1.3 million tons. Over the same time period gross loads and steam load declined 23% and 58%, respectively.

The RGGI “Investment of RGGI Proceeds Through 2013” (Published April 2015 by RGGI Investment of RGGI Proceeds: Full Report). report states that “Over their lifetime, these RGGI investments are projected to save more than 48.7 million mmBtu of fossil fuels and 11.5 million MWh of electricity, avoiding the release of approximately 10 million short tons of carbon pollution”. In 2013 RGGI CO2 emissions were 89,115,811 tons of CO2 so based on this RGGI report were it not for RGGI there would have been 10 million more tons of CO2 emitted so total emissions would have been 99,115,811 tons so the difference from the baseline is 28,178,600 tons (Table 2 in the white paper). I calculated the percentage difference with and without the program to compare with results from the Murray and Maniloff paper. That calculation estimates that emissions would have only been 11% higher than without the program according to the RGGI estimate of investment impacts.

The lower bound for RGGI program CO2 emissions reductions during this period can also be estimated. It can be argued that the coal and residual oil emissions were lower due solely to the changes in cost differences relative to natural gas and additional regulations and compliance pressure for NOx, Hg, and (in New York) opacity. This assumes that RGGI compliance is incorporated into the bid price and so was not a driver in facility decisions. Making those assumptions then means that the CO2 reductions directly due to RGGI should be the savings of 48.7 million mmBtu of natural gas specifically and the natural gas emission factor for CO2 should be used for CO2 displacement. Table 3 lists this calculated value, 2,848,950 tons. This calculation shows that emissions would have been only 3% higher than without the program.

Recall the quote: “In New York, RGGI has led to a 46 percent reduction in carbon emissions from affected power plants and a 90 percent reduction in coal-fired power generation”. It is difficult to reproduce the reduction estimates but the values are consistent with the white paper estimates of the total reductions. Three different evaluations of the actual impact of RGGI concluded that the emissions would have ranged between 24% and 3% higher than without the program. I should also note that claiming RGGI has anything to do with the coal-fired power generation reductions is a stretch because of the effect of lower natural gas prices and other New York environmental regulations.

Next post: the feasibility of further CO2 reductions in New York.