Balancing the risks and benefits of environmental initiatives
Author: rogercaiazza
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.
The Climate Leadership & Community Protection Act (Climate Act) website was extensively revised at the start of 2023. It includes a link for the Scoping Plan Toolkit which is described as “resource to help community and partner organizations” with specific “resources to facilitate conversations about New York’s climate work.” As I was working on an article about the cap and invest program I noticed that there were two fact sheet pdf files for cap and invest: Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF]. This is a short post about the new format of the website and the cap and invest “toolkits”.
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.
Climate Act Website
The Climate Act website was revised at the start of 2023. Now it is a public relations site to sell the Climate Act. It has been revised so that it is more accessible to smart phones with large text fonts and splashy graphics. The main internal links cover “Our Impact”, “Get Involved”, News & Events”, “Resources” and “Partner Toolkit”. I list the links within each of these categories below:
There is blog post fodder in every one of these links. For example, the lead for the Addressing Energy Affordability Concerns link says “As energy prices rise, we must power our future focused on clean and renewable resources.” Not included in the platitudes and talking points within the link is a reference to the experience of any jurisdiction that has pushed the use of wind and solar resources over fossil fuel that has actually lowered consumer bills. It is all flash and style for pushing the narrative without substance.
Cap and Invest Toolkit Fact Sheets
This post is going to introduce issues associated with the cap and invest toolkits. There are two fact sheets for the cap and invest program: Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF]. When I first started looking at these resources. I found that they both linked to the cap and invest program one pager. I alerted a contact I have known for years because there is no contact on the web pages. The next morning the link to the Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax was changed so someone else caught the problem. I also question the label of the one pager document. The author’s interpretation is that a one pager means two sides of one page. I think the generally accepted implication is to condense the summary to a single page.
I am going to do a more detailed post on the cap and invest plan toolkits but for now I just want to make one point. Both fact sheets extoll the virtues and success of the Regional Greenhouse Gas Initiative (RGGI) cap and invest program. New York utilities have been covered by that program since 2009 and New York agencies never lose the opportunity to claim that it has been a success. I have been involved in the RGGI program process since its inception and have written many articles about the details of the RGGI program.
In early December I evaluated the 2020 RGGI Investment Proceeds report that describes the results of RGGI investments over the entire region. I found that since the beginning of the RGGI program CO2 emissions have been reduced more than 50% but that RGGI funded control programs have been responsible for only 5.6% of the observed reductions. The main reason for the reductions has been fuel switching to natural gas. When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $818 per ton of CO2 reduced.
In late December I did a similar analysis of just the New York investment proceed results. I found that in New York since the beginning of the RGGI program CO2 emissions have been reduced 39% in 2021 but the reduction was 47% until the State shutdown the Indian Point nuclear station. The RGGI funded control programs have been responsible for only 16% of the observed reductions. The main reason for the reductions has been fuel switching to natural gas. When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $565 per ton of CO2 reduced.
I conclude that RGGI is not an effective CO2 emission reduction program and that because the emission reduction efficiency of the RGGI investments is far greater than any social cost of carbon metric yet proposed that the investments are not cost-effective. RGGI success is the eye of the beholder.
Mention of a ban on gas stoves recently caused a national uproar. Closer to home the New York State Climate Leadership & Community Protection Act (CLCPA) implementation plan calls for zero-emission equipment, including stoves, in new and existing buildings. When pressed about New York’s plans Governor Hochul said “”I know it’s a concern because a lot of people are misrepresenting what this is all about”. I think the misrepresentation is on the part of the Hochul Administration,
I submitted comments on the Climate Act implementation plan and have written over 275 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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.
Background
The Climate Act established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for 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 and power the electric gride with zero-emissions generating resources by 2040. 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 write a Draft Scoping Plan that was revised in 2022 and the Final Scoping Plan was approved on December 19, 2022.
There are multiple aspects of a ban on gas stoves that I have wanted to address. Fortunately, most of the points I wanted to make have already been made so this post is more of an overview of other work than original effort on my part.
Childhood Asthma and Gas Stoves
The initial reason for the recent uproar about gas stoves was a study published in an open-source journal called Population Attributable Fraction of Gas Stoves and Childhood Asthma in the United States (Gruenwald et al., 2022). The sound bite takeaway from the study was that gas stoves are responsible for 12.7% of childhood asthma in the US. I don’t have a lot of faith in any study that claims an air pollution association with asthma rates but was not relishing trying to develop an analysis.
Blair King writing on his blog did a masterful job eviscerating the claims in the paper. In brief, the study was based upon a 2013 paper that used old data from the 1980’s and 1990’s. The analysis was done using a 70-year-old statistical tool called PAF which is widely used in epidemiological studies. However, the tool breaks down when multiple risk factors (confounding variables) are present. For asthma, there are no fewer than seven risk factors so the analytical tool becomes useless. I recommend reading his article but the conclusion nails the issue:
To conclude, I can only restate that the Gruenwald et al paper seems to have some clear challenges that would typically preclude it from consideration in a policy-making process.
Its underlying data is of low statistical power.
Its conclusion is directly contradicted by more recent studies with significantly greater statistical power. and
It relies on a statistical tool that is considered invalid in situations with confounding variables yet it is being used to analyze an association that is absolutely rife with confounding variables.
Put simply, this is not the study I would rely on to make a major policy change that will affect millions of people and will cost billions to implement. As to its conclusion: are 12.7% of childhood asthma cases in the US attributable to cooking with natural gas? Based on the points above, that conclusion is almost certainly not the case.
This isn’t the first time that a study that is weak science is used as an argument for sweeping policy changes. What did surprise me is how quickly the story raced through the media. Robert Bryce explained how that happened in his post The billionaires behind the gas bans. I highly recommend that you read the whole thing but I present some highlights below.
He explained that he started looking into a new organization called the Climate Imperative Foundation in late 2021 when he read a story that the new group has a planned budget of $180 million annually over five years for a total of $900 million. When he investigated the source of the money, he discovered that two of the most recognizable names on the six-person board are Silicon Valley venture capitalist John Doerr and Laurene Powell Jobs, the widow of late Apple CEO Steve Jobs. Forbes magazine estimates that Doerr has a net worth of $12.7 billion. Forbes puts Jobs’ net worth at $17.7 billion. Unsurprisingly Bryce found that most of the money is coming from Doerr and Jobs.
His article explains why the emergence of the Climate Imperative Foundation is important:
First, it shows that the effort to “electrify everything” and ban the use of natural gas in homes and businesses – and that includes gas stoves — is part of a years-long, lavishly funded campaign that is being bankrolled by some of the world’s richest people.
Second, despite numerous claims about how nefarious actors are blocking the much-hyped “energy transition,” the size of Climate Imperative’s budget provides more evidence that the NGO-corporate-industrial-climate complex has far more money than the pro-hydrocarbon and pro-nuclear groups. Indeed, the anti-hydrocarbon NGOs (most of which are also stridently anti-nuclear) have loads of money, media backing, and momentum. As can be seen in the graphic below, the five biggest anti-hydrocarbon NGOs are now collecting about $1.5 billion per year from their donors. (All data is from Guidestar.) That sum is roughly three times more than the amount being collected by the top five non-profit associations that are either pro-hydrocarbon or pro-nuclear.
Third, banning the direct use of natural gas in homes and businesses may be worse for the climate. You read that right. Burning gas directly allows consumers to use about 90% of the energy contained in the fuel. Using gas indirectly — by converting it into electricity and then using that juice to power a heat pump, stove, or water heater — wastes more than half of the energy in the fuel. That point was made by Glenn Ducat, in his excellent new book, Blue Oasis No More: Why We’re Not Going to “Beat” Global Warming and What We Need To Do About It. Ducat is a Ph.D. nuclear engineer who worked at Argonne National Lab, as well as at two electric utilities. He explains “Burning natural gas by residential commercial and industrial customers is at least twice as efficient and emits about half as much CO2 as processes that use electricity produced from fossil fuels. Converting process-heat applications to electricity before the electricity grid is completely carbon-free will increase CO2 emissions.” (Emphasis in the original.)
In the interest of full disclosure, I note that the New York plan is to eventually use electricity from zero-emissions sources. However, there are life-cycle energy use issues with wind, solar and energy storage that mean the Climate Act transition does not reduces CO2 as much as it claims because of the efficiency of burning natural gas directly for heating, cooking and hot water.
Bryce documents how the efforts to demonize gas stoves has rolled out since 2020. One of the authors of the 12.7% asthma paper is employed by the Rocky Mountain Institute (RMI) which has published other articles that make the same claims. He provides other evidence that this paper doesn’t stand up to scrutiny.
He went on to investigate where RMI gets their funding.
Some of it is coming from Amazon billionaire Jeff Bezos. In 2020, the Bezos Earth Fund gave RMI $10 million, which the group said will be used to “reduce GHG emissions from homes, commercial structures, and other buildings, enabling RMI to increase its current work with a coalition of partners in key states. The project will focus on making all U.S. buildings carbon-free by 2040 by advocating for all-electric new construction…”
Bezos also has provided $100 million grant to the National Resources Defense Council. The Sierra Club is getting funds from Michael Bloomberg’s Bloomberg Philanthropies, including $500 million to the Beyond Carbon project. His article clearly shows that the narrative that the fossil and nuclear industries are providing massive money to funding disinformation while the noble NGOs struggle to find enough money to counter their claims is false.
Bryce makes two final points:
The first is the hypocrisy of billionaires funding efforts to slash hydrocarbon use while they are consuming staggering amounts of hydrocarbons. According to a 2020 article in Vanity Fair, Michael Bloomberg owns eight houses in New York state alone, and “he also reportedly owns several properties in London, Florida, Colorado, and Bermuda.” Thus, Bloomberg may own a dozen houses. How many of those houses have gas stoves? I’ll make a wild guess and bet that it’s more than one. Oh, and according to Vanity Fair, while he was mayor of New York, Bloomberg “was known to spend weekends” at his house in Bermuda, “traveling back and forth on private jets.” And what is fueling those private jets? I’m guessing here, but it’s probably not organic quinoa.
The final bit of hypocrisy at work here is the regressive nature of the gas bans. Indeed, it’s clear that banning natural gas will mean higher costs for consumers. Last March, in the Federal Register, the Department of Energy published its annual estimate for residential energy costs. It found that on a per-BTU basis, electricity costs about 3.5 times more than natural gas. It also found that gas was, by far, the cheapest form of in-home energy, costing less than half as much as fuels like kerosene, propane, and heating oil.
That means that efforts to ban natural gas are, in practice, an energy tax on the poor and the middle class. During a recent interview, Jennifer Hernandez, a California-based lawyer who represents The 200, a coalition of Latino groups that has sued the state over its climate policies, told me that “Natural gas is the last source of in-home affordable energy. And these climate extremists can’t stand it.”
The Scoping Plan and All-Electric Homes
Governor Hochul has been pushing back on the notion that her Administration is coming after residential gas stoves. The final thing I wanted to address was the Scoping Plan strategies for buildings particularly as they relate to electric appliances. Table 11 (page 183) from the Scoping Plan Chapter on Buildings explicitly says adopt standards for zero-emission equipment. Clearly that precludes gas stoves at some point.
James Hanley from the Empire Center wrote a great explanation of the truths of the Scoping Plan and the gas stove ban. I reproduce his post in its entirety below:
Governor Hochul is pushing back against the fear that she’s coming after homeowners’ gas stoves. She insists that she’s not, and that she’d “like to deal in the truth here because a lot of that isn’t getting out.”
Fair enough, so let’s deal with that truth.
First, it’s true that Hochul didn’t recommend a gas stove ban in her 2023 State of the State address. While she did say she wants to “prohibit the sale of any new fossil fuel heating equipment by no later than 2030 for smaller buildings, and no later than 2035 for larger buildings,” she made no mention of prohibiting the sale of other fossil fuel appliances – stoves, hot water heaters, and clothes dryers.
But the Governor’s silence on those appliances doesn’t settle the issue, and any suggestion that it does violates her urging that we “deal in the truth.”
The truth is that the Climate Action Council’s Scoping Plan explicitly recommends banning sales of fossil-fuel fired hot water heaters in 2030 and fossil-fuel fired clothes dryers and stoves in 2035.
The truth is that this Scoping Plan is the roadmap that the state legislature and all state agencies are supposed to follow to implement the Climate Leadership and Community Protection Act (CLCPA).
The truth is that the Governor or her successor(s) could follow up this year’s recommendations for action in future years, or the legislature could on its own.
The truth is that the Department of Environmental Conservation is supposed to make rules implementing the CLCPA and could begin the regulatory rule-making process to ban these appliances without the Governor’s direct prompting.
And the truth is that advocates of eliminating all fossil-fuel equipment from New York’s economy are not going to give up in despair just because the Governor didn’t – at least not yet – advocate every recommendation from the Scoping Plan.
There’s another, less visible truth, as well. The goal of anti-fossil fuel activists is to continually reduce the use of natural gas until the pipeline distribution system becomes economically unsustainable. The Scoping Plan has a whole chapter discussing the “strategic downsizing” of the gas system. And while the goal of making it economically unsustainable is not made explicit, it is the foreseeable result of this downsizing strategy.
The more homes that are forced or incentivized to switch to all-electric, the fewer gas customers there are left to cover the cost of maintaining this large distribution system. That will put cost pressure on those remaining gas customers, forcing more of them to switch to electricity. That puts further cost pressure on the remaining customers, and so on, until maintaining the system is no longer financially sustainable.
With this long-range strategy, no explicit ban is even necessary.
This will not affect propane stoves and appliances, of course, because they are not fed by a pipeline system. So they may get at least a temporary reprieve. But they are clearly targeted by the Scoping Plan and anti-fossil fuel activists as well.
In brief, while it’s true that Hochul did not propose a ban on replacement fossil fuel-powered appliances in this year’s State of the State address, there is plenty of time between now and 2035 for her, a successor, or the DEC to act in conformity to the recommendations set out in the state’s CLCPA Scoping Plan. Even if they don’t act to enact an explicit ban, the Scoping Plan lays out of goal of diminishing the infrastructure for gas delivery.
So don’t believe those who are now naysaying the idea of a gas appliance ban. Gas and propane users will need to organize effectively to make their voices heard if they are to prevent a forced transition to electric appliances.
These zero-emission standards across a range of equipment types should apply starting in the years noted below.
2030: Adopt zero-emission standards that prohibit replacements (at end of useful life) of residential-sized equipment used for the combustion of fossil fuels for heating and cooling and hot water. The standards beginning in 2030 should regulate equipment sized to typically serve single-family homes and low-rise residential buildings with up to 49 housing units.
2035: Adopt zero-emission standards that prohibit replacements (at end of useful life) of fossil fuel appliances for cooking and clothes drying.
Discussion
It has been said of the Scoping Plan that “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”. I have spent most of last year trying to interpret what is important and can confirm that statement. It is a political document intended to push the agenda of the Hochul Administration which is apparently to pander to the emotional needs of the constituency that believes that there is a climate crisis and an easy and painless solution. There are enormous ignored tradeoffs associated with the complete transformation of the energy system that has been built up over one hundred years to one with zero-emissions in the 27 years to 2050. Nothing is as simple as portrayed in the Plan or the politician’s descriptions of what is going to happen.
The biggest problem with the Scoping Plan is that it does not address any of the many “what if?” questions. Consider the electrification of home cooking appliances in this regard. I believe that the overarching what if question related to all-electric homes is what if there is an ice storm. During an extended wintertime blackout, a gas or propane stove can be used for cooking and for limited heating. An all-electric home without electricity has nothing. Those differences could mean a life or death situation.
Richard Ellenbogen mentioned some transition issues in a letter:
Additionally, if you ban the sale of gas ranges, what happens if your existing gas range breaks. Do you have to rewire your home to install a new stove and then buy all new pots to work with an inductive cook top? What are you supposed to do for cooking while you wait a month for an electrician to install a service that can cost thousands of dollars depending on the existing service? I have a breaker panel within thirty feet of the stove in my house and my house has an existing 400 amp service which is far larger than most will. Even if I had to switch ranges, it would cost at least $2000 for the electrical work, excluding patching and painting of the holes needed to run the cable, just to run the service. That is beyond the cost of the range. Inductive cook tops, which are safer and use less energy, are three times the cost of a gas range, independent of the $400 set of pots and pans that will work with it. If the existing service and breaker panels were inadequate, you can add $6000 to that figure, at least. What if you live in a high-rise apartment and the board or building management doesn’t have the funds to rewire the entire building when your stove breaks? The gas range in my daughter’s apartment needed replacing. We had a new one installed for $750, delivered. Not that we could have installed an electric range anyway because the electrical service wasn’t there, but an equivalent inductive range started at $2000 and went up from there. $2400 with pots and pans. That was two years ago.
Finally, the effect of the billionaire funding sources should not be ignored. Anyone associated in any way with the fossil fuel industry is portrayed as a shill such that their work should be disregarded as propaganda. Because funding sources are a legitimate concern, I maintain that it is important to understand the source of anyone’s funding. To say that an organization that gets its funding from a donor with a specific agenda is not exactly the same situation as a fossil fuel shill is naïve. In both cases it does not mean that the results are wrong but that they must stand up on their merits. (By the way that is the reason that my posts typically include references.) In this instance the claims of significant health impacts of gas stoves do not withstand scrutiny so the publicized studies do not warrant banning their future use.
Conclusion
The Hochul Administration’s war on natural gas and propane is irrational. While methane does have a more potent impact on the greenhouse effect than carbon dioxide in a molecular comparison, in the atmosphere methane does not have anywhere near the effect of carbon dioxide. The atmospheric residence time is on the order of 12 years so methane does not build up in the atmosphere. Furthermore, there is a large body of evidence showing that the claimed health impacts of methane combustion are weak. Those fundamental flaws destroy the rationale to eliminate the use of natural gas and propane as planned in the Scoping Plan.
On the other hand, there are significant benefits for the use of natural gas and propane. It is cheaper. It is energy dense and can be transported easily so when it is combusted in a modern high efficiency appliance you get a lot of bang for the buck with relatively small impacts. I suspect that many New Yorkers appreciate its dependability relative to electricity. It allowed my family to survive two extended blackouts and I am not sure what we would have done without it.
I have found that New York’s emissions are less than one half of one percent of global emissions and that the average increase in global emissions is greater than one half of one percent. In other words, even if we eliminate our emissions, the increase in global emissions will replace our reductions in less than a year. That does not mean we should not do something but it does mean that we can and should take the time to be sure that the things we mandate do not do more harm than good. Until such time that the Hochul Administration is held accountable to answer the what if questions not addressed in the Scoping Plan it is likely that the transition to net-zero will do more harm than good.
The politicians who are downplaying the idea of a gas appliance ban are just kicking the can down the road to be somebody else’s problem. Someway or somehow every building in New York State is going to be electrified to the maximum extent possible according to the Scoping Plan. Gas and propane users must make their voices heard if they are to prevent a forced transition to electric appliances. Please contact your elected officials and tell them we must have full accountability before a mandated transition.
This is a guest post by Mark Stevens, a regular reader at this blog. Mark is a retired science and technology teacher from Long Island. I have been meaning to do a post on whales and the offshore wind industry so this was timely.
What’s Going On
The NY Post reported a 7th dead whale washed up on the Jersey shore. A humpback washed up on the Amagansett shore in December. Eight dead whales in two months? Moreover, David Wojick recently reported that on January 18, 2023 there was a NOAA fisheries media teleconference that noted:
Since January 2016, NOAA Fisheries has been monitoring an Unusual Mortality Event for humpback whales with elevated strandings along the entire East Coast. There are currently 178 humpback whales included in the unusual mortality event. Partial or full necropsy examinations were conducted on approximately half of the whales. Of the whales examined, about 40% had evidence of human interaction, either ship strike or entanglement. And to date, no whale mortality has been attributed to offshore wind activities.
The transcript makes for fascinating reading. The Fisheries spokespersons went to great lengths to make the point that no whale mortalities have been directly linked to offshore wind development. But there were notable conditions in those statements: “We do not have evidence that would support the connection between the survey work and these recent stranding events or any stranding events in the last several years.” The other key condition is that the offshore wind development is doing survey work now and not construction. The open question is whether or not offshore wind development could kill whales.
Bloomberg reports that planned wind projects off the New England coast threaten to harm the region’s dwindling population of endangered right whales, according to a US government marine scientist.The warning from a top National Oceanic and Atmospheric Administration official, obtained by Bloomberg under a Freedom of Information Act request, underscores the potential legal and environmental perils of offshore wind development along the coast. Both initial construction of wind projects and decades of expected operation threaten to imperil right whales in southern New England waters, Sean Hayes, chief of the protected species branch at NOAA’s National Northeast Fisheries Science Center, said in a May 13 letter to Interior Department officials. The department is weighing at least 10 proposals to install wind turbines in shallow Atlantic waters — projects key to fulfilling Biden’s 2030 goal.
The NOAA fisheries media teleconference claimed that survey work had not been linked to whale strandings. Surveys entail prolonged use of “machine gun sonar” emits an incredibly loud noise several times a second, often for hours at a time, as the ship slowly maps the sea floor.Mapping often takes many days to complete. A blaster can log hundreds of miles surveying a 10-by-10 mile site.
There are lots of ways this sonar blasting might cause whales to die. Simply fleeing the incredible noise could cause ship strikes or fish gear entanglements, the two leading causes of whale deaths. Or the whales could be deafened, increasing their chances of being struck by a ship later on. Direct bleeding injury, like getting their ears damaged, is another known risk, possibly leading to death from infection. So there can be a big time difference between blasting and death. Sonar blasting in one place could easily lead to multiple whale deaths hundreds of miles away. If one of these blasters suddenly goes off near a group of whales they might go off in different directions, then slowly die. It is not guaranteed that the dead whales will wash up on shore.
The NOAA fisheries media teleconference did not address construction impacts. Sound travels 5 times faster in water and humpback whale sounds can travel thousands of miles according to Scientific American. Pile driving the hundreds of enormous monopiles that hold up the turbine towers and blades will be far louder than the sonic blasters, especially with eight sites going at once. These construction sites range from Virginia to Massachusetts, with a concentration off New Jersey and Long Island. This is shown to cause whale mortality.
The impetus for the The NOAA fisheries media teleconference was related to humpback whales strandings. However, some of the dead whales off New Jersey are endangered sperm whales. And there are the severely endangered North Atlantic Right Whales throughout the area where offshore wind developments are planned.
Offshore Wind and the Climate Act
New York’s Climate Leadership and Community Protection Act (Climate Act) established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Act requires that by 2030, 70% of electricity will be generated from renewable energy sources such as solar and wind and calls for the development of 9,000 megawatts of offshore wind energy by 2035.
According to the New York State Offshore Wind Overview five projects have been procured: South Fork (132 MW), Empire Wind 1&2 (816 MW and 1,260 MW), Sunrise Wind (924 MW), and Beacon Wind https://www.beaconwind.com/about/(1,230 MW). Unfortunately, the websites do not provide consistent information but the best guess number of turbines is 316 for a total of 4,362 MW. At that rate, the 9,000 MW target will require 652 turbines with capacities between 11 and 15 MW. On January 26, 2023 bids were due for another round of Climate Act offshore wind development.
Is it time to re-think offshore wind?
In order to do the offshore wind development site surveys an incidental harassment authorization is required. The first fact is that the huge 2016 jump in annual humpback mortality coincides with the huge jump in NOAA Incidental Harassment Authorizations. The second fact is that this is just the start of whale harassment when hundreds of enormous monopiles are driven into the seabed for the massive deployment of offshore wind. When construction gets into full swing there will be multiple pile drivers hammering away which can only result in impacts beyond incidental harassment.
In addition to the hundreds of bird strikes including bald eagles and others, wind turbines are massive killing machines here and around the world. And the fact that they produce energy about ¼ of their nameplate capacity, cost hundreds of billions of dollars with huge taxpayer subsidies, are intermittent and still need fossil generation backup when the wind stops, require 10s of thousands of acres, have shortened life in the harsh marine environment; require more steel, concrete, copper, and materials than conventional generation of the same output; have monstrous fiberglass blades which are not recyclable, why are we blindly building them? In addition, most wind projects are built by foreign companies. Do we want billions of ratepayer dollars and taxpayer subsidies going overseas?
According to a study by the Center For Management Analysis of CW Post/LIU, Dr. Matt Cordero determined repowering the Northport Power Station alone with state-of-the-art technology will produce 3500+ MW (more than Empire Wind), cut emissions over 90%, cost less than Empire, use fewer materials, use a fraction of the area that ALREADY EXISTS with a power station and in-place infrastructure, will have zero bird strikes and whale deaths, provide tax benefits for the community, will last decades longer and is on call 24/7 vs. intermittent (20% of the time) wind.
Furthermore, intermittent wind and solar need massive battery backup and storage with huge costs, land requirements, massive pollution and greenhouse gas emissions for ore extraction and fabrication, and pose a deadly hazard to the region if it catches on an unextinguishable fire that emits deadly gasses.
Emission reduction by NYS will have an undetectable effect on global emissions, especially with China, Russia, India and others building dozens of coal power plants. They will have reliable, life-saving, cost-effective electricity generation. States with a large portion of renewables like California, Texas, North Carolina have high rates, power failures, rolling blackouts and a restricted weather operating range, and they IMPORT reliable power from other states, thus relocating emissions to surrounding states. Tesla and others left California for those reasons. Are they really cutting emissions?
Finally, the European Union, especially Germany and the UK have shuttered nuclear and fossil generation, relying on unreliable wind and solar sources. Costs are so high, people must decide whether to buy electric heat or food, and industries are leaving for other countries with cheaper and more reliable electricity, resulting in unemployment, poverty and economic collapse.
We currently have a reliable, cost-effective generation mix of fossil, wind, solar, hydro and nuclear. New York State must seriously rethink replacing that generation with intermittent wind and solar. Our survival and economy depend on it.
I wanted to mark the occasion of this, my 500th post, with a bit of retrospective since I started posting on this blog on January 11, 2017. I did something similar on July 29, 2021 when I reached 300 posts.
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 sound bites that must be rebutted by getting into details. I have tried to show the complicated “other” side of environmental issues that gets overlooked during policy discussions. 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, 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. At the time of my 300th post, the Climate Act implementation process accounted for 109 articles. Since then, 169 of the 200 latest published articles have addressed it for a total of 278 out of the 500 articles. I truly believe that the Climate Act “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 also have also written numerous 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 28,775 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.
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 many reposts. My thanks to both of them for bringing visitors.
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 has posted blog articles on my articles about the CLCPA implementation process which get 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. Recently the editor of the GreenCarJournal contacted me and asked if I would like to share my perspective but that did not result in a spike of visitors.
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.
Another measure of personal satisfaction are the contact emails. I get pleasure whenever I get something like this:
We are soul brothers. My background is in the green industry – Horticulture, arboriculture, landscaping, etc. I got into the world of pesticides because I really was convinced all pesticides were bad. Guess what… they’re not. If you read the label and do as you’re supposed to…
I feel obligated to do our part to reduce pollution, and waste but there are many who don’t know or care to know what the trade-offs are. There are way too many pushing change without considering all the ramifications.
Keep preaching brother and if I can be of help at any point, give me a shout.
The blog statistics describe what visitors are reading. It is not a good sign that nearly half the viewers look at the home page, about page or menu. It appears that many viewers see what the page is about and have no interest to continue on. The most popular article by far is one on the proposed rebuilding of Interstate 81 through Syracuse. I presume that the title matched some trending internet search term and they ended up at the site. Early on I did a post on the Paris climate agreement costs that also got a lot of views. I suspect it is a source of frustration to the state that when searching for specific Climate Act items my posts generally turn up.
Finally, it is a source of amusement to me that people from all over the world have visited the site. Someone has visited the site from every country that is highlighted in the following map. I also have listed the number of visitors from the more popular countries below that.
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.
I recently got an email from Ronald Stein that raised an energy literacy issue that has been something I wanted to write about for some time. New York’s Climate Leadership and Community Protection Act (Climate Act) mandates a transition of the energy system to one with no fossil fuel infrastructure. What about the 6,000 products that are manufactured using fossil fuel feedstocks?
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. Unfortunately, looking solely at fossil fuels as evil and not considering the enormous benefits of fossil fuel as an energy source and as the material used to manufacture so many items used by society is misplaced. I submitted comments on the Climate Act implementation plan and have written over 275 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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.
Energy Literacy
In this section I quote and paraphrase the material from the email.
Ronald Stein is a professional engineer, energy advisor, and national TV commentator, Ron has spent much of his life trying to get more people to truly understand energy – where it comes from, how it works, and what we can expect in the future. After starting off his career as a project manager for refineries and chemical plants, Ron later did a stint at Universal Studios where he oversaw the building of the Jaws ride. Eventually, he would start his own company, PTS Advance, which partners with engineering firms and refineries to augment their core staff when excess needs arise. The family-owned business now has locations across the country, with over 1000 contractors staffing various energy infrastructure projects.
His email explained:
Energy literacy starts with the knowledge that renewable energy is only intermittent electricity generated from weather dependent breezes and sunshine. For the 8 billion on this planet, wind turbines and solar panels cannot manufacture any of the 6,000 products in our daily lives, nor any of the fuels for ships, planes, militaries, and space programs.
It went on to provide a few takeaways on energy literacy, i.e., the elephant in the room that no one wants to talk about:
The potential for nuclear fusion for unlimited zero-emission electricity is exciting. It has the potential, in the decades ahead, to wean the world from coal and natural gas for electricity generation.
Facing reality, fusion, like wind, solar, nuclear, and hydro, ONLY generate electricity. None can manufacture any products, or fuels for transportation infrastructures needed by the 8 billion on this planet.
On the other hand, we have crude oil that is never used for generating electricity, AND is virtually useless until its manufactured into usable products via the 700 refineries around the world.
Today, the world’s 8 billion are dependent on more than 6,000 products made from the oil derivatives manufactured from crude oil, and the 50,000-merchant ships and 50,000 jets, and militaries, and space programs are based on the fuels manufactured from crude oil.
We may have long-range plans to generate electricity from wind, solar, and nuclear fusion, but no plans to replace crude oil that is manufactured into everything in our daily lives.
Energy literacy will enhance one’s comprehension that the cost of energy affects everything, from the food we eat, the clothes we wear, transportation, communications, housing, healthcare, and the leisurely living made possible by energy.
The world needs to comprehend that energy is more than intermittent electricity from wind and solar. Ever since the discovery of the versatility of products available from petroleum derivatives, and the beginning of manufacturing and assembly of cars, truck, airplanes, and military equipment, the world has had almost 200 years to develop clones or generics to replace the crude oil derivatives that are the basis of more than 6,000 products we use such as: medications, electronics, communications, tires, asphalt, and fertilizers.
The social needs of our materialistic societies are most likely going to remain for continuous, uninterruptable, and reliable electricity from coal, natural gas, or nuclear electricity generation backup, and for all those chemicals derivatives that get manufactured out of crude oil, that makes everything else that’s part of our daily lifestyles and economies.
The purpose of the email was to announce a podcast posted January 14, 2023 at Energy Media about the elephant in the room, the products manufactured from fossil fuels that built the world from 1 to 8 billion in less than 200 years, beginning right after the discovery of oil. Ron explains:
There’s no doubt about it, our entire modern society – from medication to food to infrastructure and beyond – all was made possible thanks to the discovery of oil. When talking about the energy transition, Ron cautions dropping oil and gas before reliable alternatives are readily available. To him, that’s like “jumping out of a plane without a parachute.”
For more, check out Ron’s interview with The Epoch Times for a video that has already been viewed more than 200,000 times! “The 35-minute YouTube video is a conversation about the elephant in the room that no one wants to talk about: the lack of energy literacy in the bizarre California energy policies.” The emphasis on the video is on California’s policies. It is entirely relevant to New York’s Climate Act.
Climate Act Implications Conclusion
One of the talking points of proponents of the Climate Act is that many clean energy jobs will be created. Stein’s work makes the point that the clean energy jobs are only associated with making electricity. In addition, most of the clean energy jobs are construction jobs and not associated with operating the generating resources. New York’s over-riding emphasis on reducing GHG emissions means that fossil fuels that can be used to make electricity but also provide fuel for heating and transportation and support manufacturing will be prohibited. I am pretty sure that is going to lead to a net loss of jobs.
The other relevant point is that the Climate Act fails to consider any positive impacts of fossil fuels. Eliminating fossil fuel infrastructure in the state means that no manufacturing that uses fossil fuels as feed stock will be welcome in the state. I also find it hypocritical that there is no backup plan for the replacing fossil fuel feedstocks used to make the products in the following figure.
Stein makes the important point that today’s society requires not only reliable electricity but all the chemicals derivatives that get manufactured out of crude oil and natural gas. Failure to consider the value of 6,000 products that are manufactured using fossil fuel feedstocks under values fossil fuel benefits to society in the Climate Act.
This is a guest post by Mark Stevens, a regular reader at this blog. Mark is a retired science and technology teacher. When he sent an email with this I asked if I could post it and he agreed.
Cut Greenhouse gasses! Save The Planet! A better vehicle! Really?
I didn’t know EVs (electric vehicles) are about 1000 lbs. heavier than their petroleum equivalents and therefore have higher brake wear (increased particulates), tire wear (increased nano particles), and require more charging energy.
I didn’t know EVs’ batteries lose power in the cold and reduce their range, and the batteries need replacing after several years approaching half the cost of the vehicle.
I didn’t know the rare elements needed in EVs like lithium, cobalt, copper, nickel are mined in third world countries where child slave labor is used to mine the metals and the metals obtained are refined resulting in mass poisoning of the land and water and massive greenhouse gas emissions are emitted in the refining.
I didn’t know the grid doesn’t have the capacity to charge EVs on a massive scale which will lead to rolling blackouts like California, North Carolina and Texas when many families are charging at the same time.
I didn’t know that electricity providers will boost rates significantly higher to charge EVs at home resulting in cost-of-operation higher than a gasoline car.
I didn’t know the total greenhouse gas emissions in EV cars from obtaining rare earths to fabrication to end-of-life disposal is greater than that of conventional cars.
I didn’t know that if EVs were really viable they wouldn’t need thousands of dollars of taxpayer subsidies.
I didn’t know EV batteries can suddenly explode in an unstoppable fire that emits toxic gasses. This results in ordinances requiring EVs to NOT park in garages.
I didn’t know the EVs’ components are not easily recyclable and end-of-life disposition is a major problem for landfills, recyclers and incinerators.
I didn’t know Connecticut’s fleet of electric busses were withdrawn due to several catastrophic fires.
I didn’t know a home charger costs thousands of dollars.
I didn’t know a 500 mile trip would require hours of recharging on the way.
I didn’t know I would have to detour and spend time finding a street charger.
I didn’t know low and middle-income Americans will find using and affording a new or used electric car will be unaffordable.
I didn’t know the tax on your gasoline to keep our roads maintained will soon be replaced by a special tax on your electric vehicle registration as make-up.
I have written enough articles on solar siting issues that I have setup a page that summarizes them all. The original intent of this blog post was to announce the addition of a scorecard documenting the loss of prime farmland allowed by the Hochul Administration’s solar siting policies. However, one of the latest solar project approvals was for a project that proposes to build on marginal farmland proving that it can be done so I have added a description of that project.
New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. I have written extensively on implementation of the Climate Act. Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level but the current implementation policies are doing more harm than good. 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.
Solar Siting Issues
I became aware of the particular issues of utility-scale solar development on agriculture after I had a couple of people contact me describing issues that they had and suggested that I look into the issue. The problems that they raised are real, solutions to mitigate problems are available, but in the rush to develop as many renewable resources as quickly as possible the State of New York has dropped the ball on responsible utility-scale solar development. Given the massive amount of projected utility-scale solar generation capacity required to meet Climate Act goals the rush to develop solar projects could easily lead to the permanent loss of significant amounts of prime farmland that will hurt farming communities and endanger Climate Act strategies to sequester carbon in soil.
The New York State Department of Agriculture and Markets (DAM) has guidelines for solar developments. In prepared testimony Michael Saviola explained: “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.”
Solar Siting Farmland Scorecard
In order to document the State’s irresponsible solar siting policies, I have developed a scorecard to track of the loss of prime farmland. I used Exhibit 15: Agricultural Resources in the solar project permit applications for the data. A list of applications is available at the New York State Office of Renewable Energy Siting that references the docket for each permit. I have tried to accurately represent the project area, project footprint, and the area of prime farmland in each permit application but the applications do not use the same terminology so my interpretations might be inconsistent.
The following scorecard table lists the project names and the permitting authority. The original power sector permits were handled by the Department of Public Service Article 10 process but now the state rams over-rides any local concerns with the New York Office of Renewable Energy Siting (ORES). The table lists photovoltaic capacity (MW) for each project. My interpretation of the project area is that it represents the land under contract to the project developer for locations being evaluated for placement of project facilities, including the proposed collection substation and interconnection facilities. I interpret the Project Footprint as only the area of the project components. All the applications are required to include an exhibit for agricultural resources that specifies how much of the project area and footprint are soil types that are defined as prime farmland. Mineral Soil Groups 1 through 4 are considered to be highly productive soils by DAM. I calculated the Percentage Prime column as the sum of the prime farmland soil categories divided by the Project Area to compare with the DAM goal for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified as Prime Farmland soils.
Update: The latest Update of the Scorecard is available here.
At this time, there are seven approved projects that have accessible Agricultural Resources exhibits (Homer Solar’s exhibit is unavailable). Six of the seven projects exceed the DAM goal for limited conversion. I should also note the DAM has made the point that once this land is converted to industrial solar panels that is unlikely that it will be converted back to farmland simply because the need for solar power will never go away as the Climate Act net-zero goals are implemented. The developers piously claim that the most of the project footprint can be converted back but I side with DAM that this is a transparent excuse of no value.
The solar development scorecard lists a total of seven applications that have been approved for a total of 1,339 MW. The total project areas cover 17,430 acres and the project footprints total 7,912 acres. Despite the best efforts of Department of Agriculture and Market staff to prevent the loss of Prime Farmland, these projects were approved and the prime area lost for farming in these projects totals 4,216 acres or 24% of the combined project areas.
Discussion
In early January Governor Hochul announced approval of siting permits for three major solar energy centers including Tracy and Riverside. Frankly I was wondering if any industrial solar development would propose to develop land that met the DAM 10% goal so I was pleased to see the Tracy application. It is possible to develop solar facilities on marginal farmland.
I think the Agricultural Resources exhibit descriptions of the Riverside Solar and Tracy Solar projects are instructive.
The Riverside Solar application states:
The Applicant has worked with participating landowners to site Facility components in order to minimize impacts and allow for continued agricultural use on land adjacent to the Facility Site. The Facility will be constructed in accordance with the NYSAGM guidance document “Guidelines for Solar Energy Projects – Construction Mitigation for Agricultural Lands”, dated October of 2019 (NYSAGM Guidelines), which is discussed further below in Section 15(c). During the construction and operational life of the Facility 1,012 acres of land within the Facility fence line will be taken out of agricultural production and will be utilized for solar energy components. Additionally, the Facility Site includes approximately 366 acres of land located in areas of MSG 2-4. There are no occurrences of MSG 1 soils at the Facility as is indicated in Table 15-4 below. Areas not within MSG 1-4 were evaluated for the feasibility of siting Facility components as practicable. However, for various reasons such as landowner preferences, presence of wetlands and streams, and efficient siting of Facility components to reduce fragmentation and appropriately consolidate the Facility and minimize the overall footprint, the Applicant was unable to further consolidate or arrange the Facility layout to significantly reduce the use of land in MSG 2-4 areas. Following the decommissioning of the Facility the land can be restored to its agricultural use. While in operation, the Facility will utilize agricultural land for solar energy production. This will ensure that parcels remain intact during the life of the Facility, rather than being sold or subdivided for other purposes that may not allow the land to be reverted to agricultural use. The Facility will allow for continued agricultural use on parcels excluded from the Facility and will protect the viable agricultural land being utilized by the Facility for future use following decommissioning at the end of the Facility’s useful life.
In the absence of a state policy for responsible solar siting, out-of-state developer AES can come in with these lame excuses and take another 292 acres of prime farmland out of production. The referenced Table 15-4 is nearly six pages of individual soil types without a summary listing. I interpret the obfuscation relative to the relevant prime farmland statistics to mean that they know full well just how inappropriate this application is.
The Facility footprint consists of 864 acres, defined as the area within the limits of disturbance (LOD). Within the Facility footprint, 816 acres are active agriculture, based on the active agriculture analysis described in Section 15.9.1. Table 15.8-1 summarizes the agricultural areas of the Facility footprint affected by construction and operation. Construction will result in temporary impacts where it will not be feasible to continue farming due to construction laydown areas and temporary workspaces. Operation will remove active agricultural land from farming for the life of the Facility.
Figure 15-8 in Appendix 15-A depicts mineral soil groups present within the Facility Site. Table 15.9-1 identifies the mineral soil coverage within the Facility Site and Facility footprint. Soil groups identified by NYSDAM as Mineral Soil Groups 1 through 4 are considered to be highly productive soils (NYSDAM 2021). Mineral Soil Groups 3, 5, 6, 7, and 8 are present within the Facility Site.
It is apparent that the Tracy Solar project has proposed to install solar panels on marginal farmland. Surely this is an example that should be the standard for all future development.
Conclusion
The implications of these two projects does not reflect well on the New York State solar siting requirements. The Tracy Solar projects shows that marginal farmland can be used for solar panels. As it stands now solar developers are free to come into the state and put up as many solar panels as they want on as much prime farmland as they want in direct contravention of DAM goals. In addition, there are no solar capability standards so developers are free to install fixed panel racking systems that cost less but do not meet the capacity expectations of the Scoping Plan. The state has not updated its cumulative environmental impact assessment for the larger renewable energy capacities in the mitigation scenarios so the full consequences of the necessary 40,000 MW of solar development are unknown. I submitted a comment to the Council in March calling for a moratorium on utility-scale solar siting in March that was ignored. The most frustrating part to me is that the State has instituted responsible solar siting guidelines in the policy option roadmap for the proposed 10 GW of distributed solar development. The failure to simply require those requirements for utility scale solar developments is baffling.
Until the Hochul Administration institutes responsible utility-scale solar siting guidelines similar to the roadmap for distributed solar development there will be significant and irreplaceable loss of Prime Farmland and damage to farming communities across the state.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I submitted comments on the Climate Act implementation plan and have written over 275 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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.
Climate Act Background
The Climate Leadership and Community Protection Act (Climate Act) established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for 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 and power the electric gride with zero-emissions generating resources by 2040. 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 write a Draft Scoping Plan that was revised during 2022. The Final Scoping Plan was approved on December 19, 2022. Unfortunately, the revisions only addressed the language of the draft plan and not the substance of the numbers used from the Integration Analysis.
The Post Standard published three letters to the editors related to the Knauss article. Two of the articles expressed concern about the dangers of heat pumps and the resulting lack of heat during periods when electricity blackouts occur. Hanah Ehrenreich argued that we should know better than to question the Scoping Plan.
Recent letters to the editor by Roger Caiazza and David Seeley (”Dangers and possibilities of NY’s all-electric future,” Jan. 4, 2023) argue electrification as a substitution for gas heat would intensify dangers, with the Buffalo storm as the example. If they had read Tim Knauss’ well-informed and straightforward reporting on New York’s implementation strategy for the 2019 Climate Leadership and Community Protection Act, they would know better.
Two years have been spent in a detailed implementation development process including scientists, representatives of the fossil fuel industry and utility companies, labor leaders, environmentalists, and many months of public input.
The description of the Scoping Plan as a detailed implementation development process is naïve. The 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.” I suspect that because all these experts worked for two years and there was public input, then the public perception is that means the Scoping Plan included a feasibility analysis. The fact is that the plan did not determine whether all the aspects could work as proposed to maintain current standards of reliability, prevent significant risks to affordability, and would not cause significant adverse environmental impacts. Also, as I said in my letter, the state plan does not address “what if” questions.
Ehrenreich goes on to say:
Buffalo residents — old and young — died in their natural gas-heated homes. Gas heat does not operate without electricity. Those gas-heated homes that lost power were 30 degrees indoors. Meanwhile, homes in Buffalo that maintained electricity still had heat, which saved lives.
I have a couple of problems with this paragraph. The first point is that while it is true that gas heat does not operate without electricity, gas stoves can be lighted with a match providing some heat and hot food which is impossible in an all-electric home. More importantly, a fossil fueled generator can be used to provide the power necessary for gas furnaces to operate. One of the “what if” questions so far unanswered is what happens to all the people who have invested in emergency generators. Even if the State allows them in the future, where is the fuel going to come from when all other uses are outlawed? The second point is the line “homes in Buffalo that maintained electricity still had heat, which saved lives”. Home in Buffalo that had electricity could run their gas furnaces and that saved lives too. People who died in homes with gas furnaces would have died in electric homes too.
There could be another interpretation of this paragraph. My letter to the editor made the point that at some point there will always be insufficient energy for a heat pump to create heat inside a home. I think that Ehrenreich might have interpreted that to mean that I was saying that they don’t work at all. The technology has improved so that an advanced heat pump can provide heat to a lower temperature but if the temperature is below 15o F no heat pump will work well.
Ehrenreich states:
Ductless mini-split heat pumps in my 1920 home provide consistent heat (air conditioning in the summer) without the astronomical cost of retrofitting the original furnace and vents. A National Grid comparison ranked my home as high efficiency, with fall 2022 as overall lowest electricity costs.
The point that I tried to make is that the impression that replacing an existing fossil-fired furnace with a heat pump is all that needs to be done for all the weather conditions that we can expect in Upstate New York is not likely to be true. In addition to properly sizing the heat pumps and making sure the right type is purchased, there are issues with the building shell, ventilation, and the distribution system within the house that have to be addressed for a successful conversion. It might work most of the time but if it does not work all the times that a gas furnace does then there will inevitably be a crisis.
Ehrenreich says:
Meanwhile, gas heat dependency is forcing friends in the United Kingdom and Germany to cook with wood and dress indoors as if they were going skiing.
The same energy crisis that is causing problems with gas heat dependency are also affecting electricity prices which have the same effects. The gas dependency issue is ultimately a lack of supply because the United Kingdom and Germany have failed to develop their own sources of fossil fuels. Oh wait, that is exactly what New York is doing with the ban on natural gas development and I maintain that ultimately this will lead to problems that could have been avoided.
Ehrenreich concludes:
The climate is in crisis and the stunted natural gas industry is dragging homes and families into a state of emergency. New York state has stepped into the national forefront by taking essential legislative action. We need to do everything possible to welcome and speed this implementation.
New York’s greenhouse emissions are less than one half of one percent of global emissions and global emissions have been increasing by more than one half of one percent per year. The fact that anything we do to reduce emissions will be offset in a year does not mean that we should not do something but it does mean we should take the time to do it right. Folks like Ehrenreich are convinced that we have to act immediately because they have been brainwashed by the incessant propaganda from activists and the media. A Critical Examination of the Six Pillars of Climate Change Despair does a good job explaining why the rationale that there is a crisis is wrong.
Conclusion
I despair that so many people have such entrenched opinions about the problem of climate change and the alleged simple and inexpensive solution that they have closed their minds to reality. Anyone who claims to have an open mind should consider the following. Steven Koonin’s book What Climate Science Tells Us, What It Doesn’t, and Why It Matters does an excellent job critiquing the science behind the concerns about climate change but it is pretty technical so this video is a good overview. Frankly I am more concerned that New York is going down a path that requires dependency upon renewable energy because I am convinced that current renewable technology won’t work.
In 2023 the State is going to be developing regulations and proposing regulations to implement the outline of the net-zero transition described in the Scoping Plan. I encourage all New Yorkers to get involved and demand a feasibility analysis to determine whether the arbitrary greenhouse gas emissions targets in the Climate Act can be met reliably, affordably, and with acceptable environmental impacts. Before passing any legislation or endorsing a regulatory approach for any component of the Climate Act, the Hochul Administration must be held accountable for feasibility analyses and explanations how New Yorkers will survive when there is an ice storm after everything is converted to electricity. Anything less is a dangerous abrogation of the public’s right to safe and affordable energy.
I submitted comments on the Climate Act implementation plan and have written over 270 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. I also follow and write about the Regional Greenhouse Gas Initiative (RGGI) market-based CO2 pollution control program for electric generating units in the NE United States. I have extensive experience with air pollution control theory, implementation, and evaluation having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, RGGI, and several Nitrogen Oxide programs. 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.
Climate Act Background
The Climate Act established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for 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 and power the electric gride with zero-emissions generating resources by 2040. 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 write a Draft Scoping Plan that was revised in 2022 and the Final Scoping Plan was approved on December 19, 2022. Unfortunately, the revisions only addressed the language of the draft plan and not the substance of the numbers used from the Integration Analysis.
Investment Projection
My initial impression of the New York cap and invest program post calculated a revenue projection for the proposed cap and invest program. From 2025 to 2030 I estimate that emissions will have to go down 14.76 million tons per year to meet the 2030 GHG emissions target. New York’s investments in the Regional Greenhouse Gas Initiative yield an expected cost per ton reduced of $537 for a total of $7.9 billion. Governor Hochul proposed “legislation to create a universal Climate Action Rebate that, subject to a stakeholder and rulemaking process, is expected to drive more than $1 billion in annual cap-and-invest proceeds to New Yorkers”. If the $1 billion is added then the total revenues would be $9 billion per year.
Scoping Plan Cost Projection
The primary documentation for the numbers presented in the Scoping Plan is the Tech Supplement Annex 2. Key Drivers Outputs spreadsheet. The 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.” The spreadsheet is worse. Not only is the information provided buried in a massive spreadsheet but the authors of the Integration Analysis presented misleading, inaccurate, and biased data to support the narrative that the costs of inaction are more than the costs of action. I have extracted the relevant tabs from the massive reference spreadsheet into my analysis spreadsheet to address the first concern.
The data in the Integration Analysis that is used in the Scoping Plan is misleading. On one hand as many numbers are possible are only provided relative to a Reference Case instead of a status quo or business-as-usual case that represents the full costs of the control strategies necessary to meet the net-zero by 2050 Climate Act goal. I maintain that the true cost of New York’s net-zero transition by 2050 should include all costs associated with all programs designed to reduce GHG emissions. The authors of the Integration Analysis and Scoping Plan excluded decarbonization costs that I believe should be included and provided insufficient documentation to enable anyone to determine what is in or out of the Reference Case. For example, consider the supporting data for Figure 48 (Fig 48 tab in my spreadsheet).
Note the transportation investments in the Reference Case total $1.056 trillion but that the cost for the Low-Carbon Fuels scenario is only $3.4 billion more. That means most of the costs associated with capital and operating expenses for light-duty vehicles, medium- and heavy-duty vehicles, and buses as well as charging infrastructure costs are buried in the Reference Case because these costs are a lot more than $3.4 billion.
The cost data in the Integration Analysis that is used in the Scoping Plan is inaccurate. For example, in the calculations for the new wind, solar, and energy storage resources needed to replace existing fossil-fired resources it is assumed that none of the existing or newly developed resources reach their effective life expectancy. Wind, solar, and energy storage resources all have expected lifetime less than 25 years and it is more than 25 years to 2050 so this inaccurately underestimates the cost of electric generation.
The data in the Integration Analysis that is used in the Scoping Plan is biased. Wind and solar resources are intermittent so the assumption of the amount of energy produced affects the projected capacity of resources needed. Without exception the future amount of energy from wind and solar resources is biased high relative to the New York Independent System Operator projections. As a result, the costs projected are unreasonably low. Based on my evaluation the Integration Analysis biased every choice to make the zero-emissions replacement resources cheaper.
I emphasize that the annual revenue numbers that I believe should be clearly listed in the Integration Analysis and Scoping Plan are not provided so I can only make an estimate. Given all the limitations described above, the revenue values in the final row in the Figure 48 table shown above should be used cautiously. The annual expenditure values listed are the difference between the mitigation scenarios and the Reference Case divided by the number of investment years (27) from 2024 to 2050. The values range between $10 and $11 billion.
Other Cost Projections
I have heard other numbers tossed around so I did a bit of research to find other values.
In testimony regarding the environmental provisions of Governor Cuomo’s Executive Budget Proposal for SFY 2020-2021, Peter Iwanowicz, Executive Director, Environmental Advocates of NY, January 27, 2020 stated:
The costs of inaction are enormous. Based on the widely accepted social cost of carbon pollution of $50 per ton, New York has $10.2 billion dollars in costs per year attributed to the pollution we emit that is fueling climate change. This is a staggering blow to our health, our environment, our communities, and our economy.
Back calculating this projection assumes 204 million tons which is about the total CO2 emissions for 2017. The problem is that social cost of carbon parameter can only be applied once because it represents all the impacts from the time of the reduction to 2300. Counting them more than once is the same as claiming that because I lost ten pounds five years ago that I lost 50 pounds.
The Bond Act is a good start—but it’s not enough. It’s been three years since New York passed our landmark climate law, the Climate Leadership and Community Protection Act (CLCPA), and we’re far from achieving the law’s mandate of largely decarbonizing the state economy by 2040. The state’s own analysis shows that we’ll need to invest roughly $15 billion a year by 2030, and $45 billion a year by 2050.
The Integration Analysis does include annual projections for net direct costs of between $10.4 and $12.2 billion for 2030 and between $41.0 and $41.3 billion in 2050.
Among NY Renews’ key goals for the upcoming legislative session is the creation of a $10 billion Climate and Community Protection Fund, modeled after the state’s Environmental Protection Fund. It’s an amount in line with the Climate Action Council’s estimates of what meeting the goals in the climate plan will cost: $10 to 15 billion a year, whether the costs are paid by the state, the federal government, industry, ordinary New Yorkers, or a mix of all of the above.
There are enough options for guessing what the Council estimates as costs that these numbers are consistent.
I found a couple of independent estimates of the total costs to meet the net-zero target by 2050: An article by Ken Gregory critiques a report by Thomas Tanton “Cost of Electrification: A State-by-State Analysis and Results”. In Tanton’s analysis the estimated total installed cost (overnight) is approximately for New York is $1.465 trillion or $54.3 billion per year. Gregory’s total national capital cost of electrification is $433 trillion and New York’s proportional share based on Tanton is $22.2 trillion. Overbuilding solar and wind by 21% reduces New York overall costs to $18.2 trillion. Allowing fossil fuels with carbon capture and storage to provide 50% of the electricity demand reduces New York’s estimated costs to $1.2 trillion or $44.4 billion per year.
Conclusion
The New York Senate held a public hearing to examine legislative and budgetary actions necessary to implement the Climate Act Scoping Plan on January 19, 2023. One of the primary concerns of the legislative and budgetary actions has to be how much money is required. I modified the draft of this post to submit as a comment. The main point I wanted to make is that it is very important that the Legislature understand that the numbers presented in the Scoping Plan are inappropriate for any future legislative actions. Those actions must be based on the total costs of implementation and not just the costs relative to a Reference Case. Beyond that I offered no substantive recommendation for revenues needed because of the inadequate documentation in the Scoping Plan.
I determined the emissions reduction trajectory needed to meet the 2040 GHG emissions target, calculated the control cost per ton removed based on the RGGI auction proceed investments, and found that a total of $7.9 billion per year is needed. That is the low-end cost of the projections. At the upper end three projections exceed $45 billion a year. All these estimates will impose extraordinary cost burdens on New Yorkers. No one in the Hochul Administration has owned up to these costs. When will this news become public knowledge?
Finally, all the cost per ton reduced estimates in these projections exceed the New York State Value of Carbon guidance. The Frequently Asked Questions guidance states:
The term value of carbon is any representation of monetary cost applied to a unit of greenhouse gas emissions, expressed in terms of the net cost of societal damages (i.e., the “social cost of carbon”), marginal greenhouse gas abatement cost, or using another approach. DEC recommends that State agencies use a damages-based value of carbon for cost-benefit analysis, for describing societal benefits, and evaluating other types of decisions, such as state procurement, contracts, grants, or permitting.
This means that all these projected costs exceed the cost-benefit analysis for describing societal benefits. New York’s greenhouse emissions are less than one half of one percent of global emissions and global emissions have been increasing by more than one half of one percent per year. The facts that the expected investments exceed the societal benefits values and that all New York emission reductions will be replaced by emissions from elsewhere in a year does not mean that we should not do something, but it does mean we should take the time to do it right.
On January 10, 2023 New York Governor Kathy Hochul delivered her 2022 State of the State Address. This post describes my initial impressions of the announced plan to use a market-based program to raise funds for the Climate Leadership & Community Protection Act (Climate Act) implementation. I believe that this will be a future textbook example of how perverting the previously successful concept of a market-based pollution control program to fit the ideological purposes of a political agenda inevitably leads to failure.
I submitted comments on the Climate Act implementation plan and have written over 270 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. I also follow and write about the Regional Greenhouse Gas Initiative (RGGI) market-based CO2 pollution control program for electric generating units in the NE United States. I have extensive experience with air pollution control theory, implementation, and evaluation having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, RGGI, and several Nitrogen Oxide programs. 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.
Climate Act Background
The Climate Act established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for 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 and power the electric gride with zero-emissions generating resources by 2040. 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 write a Draft Scoping Plan that was released for public comment at the end of 2021 and approved on December 19, 2022.
The Climate Action Council (Council) has identified the need for a comprehensive policy that supports the achievement of the requirements and goals of the Climate Act, including ensuring that the Climate Act’s emission limits are met . A well-designed policy would support clean technology market development and send a consistent market signal across all economic sectors that yields the necessary emission reductions as individuals and businesses make decisions that reduce their emissions. It would provide an additional source of funding, alongside federal programs, and other funding sources, to implement policies identified in this Scoping Plan, particularly policies that require State investment or State funding of incentive programs, including investments to benefit Disadvantaged Communities. Equity should be integrated into the design of any economywide strategy, prioritizing air quality improvement in Disadvantaged Communities and accounting for costs realized by low- and moderate income (LMI) New Yorkers. Pursuant to the Climate Act, a policy would be designed to mitigate emissions leakage. Finally, an economywide strategy would be implemented as a complement to, not as a replacement for, other strategies in the Scoping Plan. A well-designed economywide program will bring about change in the market and promote equity in a way that does not unduly burden New Yorkers or with the global economy.
It is no surprise that the Scoping Plan recommends a market-based program. New York was a primary driver for RGGI and has consistently touted its success. However, the reality is that RGGI is not as successful as they claim. I will explain why the experiences of RGGI should be warning signs for this program. If you are interested in a good overview of Hochul’s cap and invest program I recommend James Hanley’s article: Cap and Invest or Cap and Divest.
Comments on the Draft Scoping Plan Economy-Wide Strategy
I submitted comments on the Draft Scoping Plan chapter on a market-based approach to provide an additional source of funding for policies that “require State investment or State funding of incentive programs, including investments to benefit Disadvantaged Communities”. I will summarize some of my overarching concerns in this section.
My comments described general issues for a carbon pricing market-based approach. One major difference between controlling CO2 and other pollutants is that there are no cost-effective control technologies that can be added to existing sources to reduce emissions. Combine that with the fact that CO2 emissions are directly related to energy production, the result is that the primary way to reduce emissions is to reduce operations. Consequently, CO2 emission reductions require replacement energy production that can displace existing production. This necessarily increases costs to consumers and is why I believe carbon pricing will always be a regressive tax.
There are other practical reasons that carbon pricing will not work as theorized. Leakage is an insurmountable problem. Pollution leakage refers to the situation where a pollution reduction policy simply moves the pollution around geographically rather than reducing it. Ideally the carbon price should apply to all sectors across the globe so that leakage cannot occur. Preventing leakage in an area as small as New York is impossible because, for example, car owners on the border will simply cross the border to purchase fuel. A fundamental problem with all carbon pricing schemes is that funds decrease over time as carbon emissions decrease unless the carbon price is adjusted significantly upwards over time. The Regulatory Analysis Project (RAP) recently completed a relevant study: Economic Benefits and Energy Savings through Low-Cost Carbon Management for Vermont that concludes “carbon pricing alone will be a weak tool to deal with the realities of consumer behavior, our historic buildings infrastructure, rural settlement patterns, and the many barriers that working families and businesses face in choosing to invest in energy efficiency or other low-carbon options”. Based on investment results for RGGI proceeds, the programs funded are not cost-effectively reducing emissions. The Climate Act mandate for funding in Disadvantaged Communities will exacerbate that issue because cost-effectiveness will not be a primary consideration.
In addition to my practical concerns “A Practical Guide to the Economics of Carbon Pricing by Ross McKitrick defines how carbon pricing is supposed to work in theory. His guide is at odds with the Final Scoping Plan for every point. He explains that “First and foremost, carbon pricing only works in the absence of any other emission regulations”, but the cap and invest program proposed by Hochul is in addition to the emission regulations of the Climate Act itself. The Guide goes to note “another important rule for creating a proper carbon-pricing system is to be as careful as possible in estimating the social cost of carbon”. He argues that “whatever the social cost of carbon is determined to be, the carbon price must be discounted below it by the marginal cost of public funds (MCPF) — that is, the economic cost of the government raising an additional dollar of tax, on top of what is already being raised”. The Scoping Plan does not even recognize the importance of this aspect of carbon pricing. He concludes: “There may be many reasons to recommend carbon pricing as climate policy, but if it is implemented without diligently abiding by the principles that make it work, it will not work as planned, and the harm to the Canadian economy could well outweigh the benefits created by reducing our country’s already negligible level of global CO2 emissions.” Substitute New York for Canada and I believe this describes this Hochul’s cap and invest program.
Results of the Existing Cap and Invest Program
New York fossil-fired electric generating stations are already in a cap and invest program. I previously mentioned that I have evaluated the RGGI program. This section describes the results of that work especially as they relate to the proposed program.
The costs per ton reduced exceed any estimates of the societal value of carbon reductions. Since 2009 when the RGGI program started, I found that the cost per ton removed of the investment proceeds from RGGI auctions is $818 per ton for the entire RGGI region. According to the latest NYSERDA RGGI funding status report the projected costs of the current programs are $776.1 million, the net greenhouse gas emission savings are 1,656,198 tons and that works out to emission cost per ton removed of $469. If all the RGGI administrative and operating costs are included another $113 million is added to the total and the emissions cost per ton removed is $537 per ton. It is not clear to me how much of this funding meets the criteria for disadvantaged community investments.
I evaluated current emissions relative to the 2030 Climate Act target of a 40% reduction by 2030. The following table lists the trajectory of observed, projected, and interpolated emissions consistent with the 2030 requirements. New York State has released the official GHG emissions for New York State for 2018 and 2019 and they are highlighted in gold. I estimated emissions for 2020 and 2021 based on observed RGGI emission levels. Note that they increase due to the shutdown of the Indian Point nuclear generating facility. The 2030 levels are fixed and are highlighted in rose. There are four columns that list the emissions trajectory necessary to get from the observed emissions to the target. The annual reduction in the trajectory is the difference between the observed emissions and the 2030 target divided by the number of years. For example, the estimated GHG emissions in 2021 were 378.69 million metric tons. If the emissions are reduced by 14.76 million tons per year, then in 2030 the emissions will meet the target of 245.87 million metric tons.
The emissions reduction trajectory of 14.76 million tons per year is going to be a challenge. The following table (the link is to the full table because I cannot figure out how to make tables in the text get bigger when a reader clicks on it) lists the New York State GHG emissions (MMT CO2e AR5 20 yr) by sector from the DEC emissions inventory . There have been years when the annual reductions have exceeded that trajectory but there have also been years when it went up by that much. RGGI has a three-year compliance period intended to smooth out the inter-annual variation. Whether the compliance period for the Climate Act program will do something similar is one of those details that remains to be worked out.
I think the fundamental cap-and-invest program issues that New York energy users and suppliers will have to deal with this year is the disconnect between the theory of cap and trade with what is proposed, the practical considerations necessary to make it work, and the preconceived notions of the environmental community.
There are two fundamental issues. The theory of market incentives is that raising the cost of carbon will let the market innovate to produce the least cost approach to provide carbon reductions. That takes time and that makes the schedule problematic. It may not be possible for the innovation necessary to replace a system that took decades to build to coincide with the 27-year arbitrary schedule of the Climate Act net-zero by 2050 target. The other fundamental theoretical issue looms huge. The state is going to “invest” the proceeds. Government investments pick winners and losers and governments don’t have a good record in that regard.
The second overall concern is the practical considerations necessary to make any market-based program work. At the top of that list is emissions monitoring. In the RGGI cap-and-invest program there were minor monitoring implementation issues because all the affected sources were already providing the data necessary to run the program. Hochul’s cap-and-auction program affects distributors of heating and transportation fuels and large-scale emitters of greenhouse gasses outside the electric utility industry that are not in similar programs so they have to create a new reporting system. The program is going to have to determine how to define compliance and establish penalties for failure to comply. Every sector has the issue of weather-related variations in energy use. The RGGI program addressed that with a three-year compliance period.
The biggest practical concern is the revenue target. The New York State value of carbon guidance cost ranges between $121 per ton in 2020 and $137 per ton in 2030. That could be used as the auction allowance price target. Presumably the auction will use the same features as in RGGI that establish boundary limits to keep the price near the target. The potential revenues using the emissions trajectory and the New York value of carbon yields a little over $40 billion in 2024 and $34 billion in 2030. According to the Citizen’s Budget Commission New York State’s personal income tax revenues were $47.1 billion in state fiscal year 2015-2016. I cannot imagine that the DEC and NYSERDA will use regulations to propose a cap-and-invest revenue scheme that is on the order of the leading source of tax revenue. One alternative possibility is to calculate the money needed to get the 14.76 million tons per year reductions required by multiplying it by the observed $537 per ton reduction cost from RGGI investments. That total of $7.9 billion divided by the 2025 emissions, 320 million tons, yields a target allowance cost of $24.76. That is a more reasonable value that may enable the Hochul Administration to avoid legislation for the program.
There are other practical considerations that mostly add funding and effort. All affected entities must provide consistent emissions data and the State has to develop a new system to track that information. There is a significant logistical effort for entities to participate in the auctions that must include another tracking system. It is necessary to setup a market monitoring presence so someone is making sure that there isn’t market manipulation going on.
The last practical considerations are more of a problem. New York’s Climate Act mandates that upstream emissions must be considered. How is a fuel distributor supposed to keep track of where and how his fuel is coming from? Hochul’s speech claims that New York wants to get other states involved but New York’s unique emissions requirements would require other states to adopt them too.
The final concern is the response of environmental advocates to market-based programs. As far as I can see, they oppose these programs because evil industry is not punished enough. In order to push their notion that zero-risk pollution control approaches are the only consideration and there are no tradeoffs, they have a list of market program talking points. Emission trading programs create hot spots because some locations don’t decrease their emissions as much as others. There is a persistent suspicion that somehow industry cheats on the emissions monitoring. Finally, they think that industry is getting windfall profits from these programs. As a result, more and more limitations are added to the program making is less and less efficient.
Hochul’s announcement specifically included environmental justice complications. Offsets are not allowed because sources would not make reductions near some disadvantaged community. Recall that CO2 emission reductions require replacement energy production that can displace existing production. If New York State investments do not provide sufficient displacement results then there will be a scarcity of allowances and the price of allowances will go up. In the RGGI program there was a feature that released extra allowances if the price exceeded an acceptability threshold. I suspect that the environmental advocates will oppose adding allowances to the system because it threatens the response to the “existential crisis.” The problem is that if allowances are not available then the only compliance option left is to not operate which could threaten reliability. I have seen no sign the environmental advocates recognize this threat.
Another issue is the requirement to invest at least 35 percent with a goal of 40 percent, so they directly benefit disadvantaged communities. I fear that this means that program funding is going to be more based on consistency with this mandate and not cost-effectiveness. There are 15 programs listed in the latest NYSERDA RGGI funding status report that have cost and GHG emission savings estimates. As noted above, the sum of the costs divided by the tons reduced is $537 per ton, but the cost per ton reduced for the 15 programs ranges from $61 to $2,515 with a standard deviation of $681. If programs are chosen in the upper end of the costs per ton reduced to favor politically connected constituencies then it will be more difficult to meet the aggressive schedule and ambitious annual reduction targets of the 40% reduction in GHG emissions by 2030 mandate.
The final environmental justice issue is that Governor Hochul will “propose legislation to create a universal Climate Action Rebate that, subject to a stakeholder and rulemaking process, is expected to drive more than $1 billion in annual cap-and-invest proceeds to New Yorkers”. I previously estimated that the cost of the investments to meet the necessary reduction trajectory would be $7.9 billion. Presumably we must increase that cost by more than $1 billion to cover the cost of the Climate Action Rebate so I choose the cost to be $9 divided by the 2025 emissions, 320 million tons, which yields a target allowance cost of $28.13. I guess that is still a reasonable value that may enable the Hochul Administration to avoid legislation for the program.
Conclusion
The Final Scoping Plan states that “A well-designed policy would support clean technology market development and send a consistent market signal across all economic sectors that yields the necessary emission reductions as individuals and businesses make decisions that reduce their emissions”. I conclude that the conditions noted in the Hochul speech preclude such a “well-designed” policy.
The Scoping Plan states that “Equity should be integrated into the design of any economywide strategy, prioritizing air quality improvement in Disadvantaged Communities and accounting for costs realized by low- and moderate income (LMI) New Yorkers”. It is not clear how they propose to prioritize air quality improvements in any particular location in a statewide emissions market. You can say it but that does not mean you can do it. The costs for LMI New Yorkers are addressed with a Climate Action Rebate that simply passes costs along to everybody else.
The Scoping Plan notes that “Pursuant to the Climate Act, a policy would be designed to mitigate emissions leakage.” Again, it is easy to say that it will mitigate leakage but how can it possibly be tracked, much less be prevented. James Hanley addresses this issue well in his critique.
The plan goes on to say that “an economywide strategy would be implemented as a complement to, not as a replacement for, other strategies in the Scoping Plan” and that “A well-designed economywide program will bring about change in the market and promote equity in a way that does not unduly burden New Yorkers or with the global economy.” The theory is fine but the theory is raise the price of carbon, return all the proceeds to the consumers, and let the market evolve over time to the least-cost emission reduction solutions. That is not what is proposed.
Hochul’s address stated that “New York’s Cap-and-Invest Program will draw from the experience of similar, successful programs across the country and worldwide that have yielded sizable emissions reductions while catalyzing the clean energy economy.” Hochul’s cap-and-invest proposal will proscribe a certain cost for permits to operate, control all the revenues, and determine how they are spent. In my opinion that is exactly like a tax and nothing like similar market-based programs. The proposed cap-and-invest program is a carbon tax with complicating factors that make it more likely to fail to provide the claimed benefits. I conclude that it will not end well.
Pragmatic Environmentalist of New York 