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.

Draft Scoping Plan Comments on Electric Vehicles

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The plans for this transition are described in the Draft Scoping Plan. This post discusses the comments I submitted on electric vehicles in the transportation sector discussion of the Plan.

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 have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. 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 establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until July 1, 2022.

I prepared the comments described here because I found that the Integration Analysis is simply making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation. I am convinced that the Integration Analysis future energy system modeling did not consider feasibility in any of its projections. Instead, the analysts simply tweaked projection assumptions until they got the reductions they needed.

Cost Issues

The Integration Analysis projections for electric vehicle costs start in 2020. Note, however, that 2020 is a modeled year,” reflecting historical trends”. I don’t think that the observed data in 2020 and 2021 is consistent with the model projections. For one thing the analysis projects a decrease in the EV costs and this was not observed. In my comments I recommended that the final Scoping Plan address those discrepancies.

As far as I can tell, the electric vehicle costs are based entirely on new vehicle sales. There is no acknowledgement that the used car market will likely change because of the cost of battery replacement. Sellers will likely get less relative to new cars in the battery electric vehicle market. Buyers may get a relative deal but will lose in the end when the batteries have to be replaced.

My comments analyzed the Integration Analysis spreadsheet documentation. The total costs for vehicles and a charging system for each new zero-emissions vehicle for the Reference Case are shown at the top of the Light Duty Vehicles Total New Vehicle Costs of Vehicles and Chargers table. The cost from 2020 to 2050 is $619.6 billion. The scenario minus reference case costs are listed for each scenario in the lower section of the table. The biggest problem is that the device costs for zero-emissions charging technology and the vehicles themselves is presumed to decrease significantly over time. Home EV chargers and battery electric vehicles both are claimed to go down 18% between 2020 and 2030. The cost decreases are so large that the total costs for the zero-emissions vehicles adoption is cheaper than using existing technology by $44 billion for Scenario 2 and $37.8 billion for Scenarios 3 and 4.

One issue I have with the Integration Analysis spreadsheets is that the data provided cannot be used to reproduce the total numbers. For example, the device costs for different types of medium-duty trucks, heavy-duty trucks, and buses are listed. To get those cost, device prices have to be multiplied by the sales for each category. The Integration Analysis spreadsheet provides the sales for combined medium and heavy-duty vehicles. Without knowing how those totals are broken down by the device cost categories it is impossible to estimate the total costs.

Even without being able to calculate the costs for those vehicles there is an apparent inconsistency with the recently released net present value of system expenditures. The transportation investment cost for the Reference case in Figure 48 is $1,056 trillion and the costs for the mitigation scenarios are higher by between $3 and $40 billion. As shown above light-duty vehicle costs relative to the Reference Case are lower by $38 to $40 billion. As noted above, I cannot provide precise numbers for the medium-duty trucks, heavy-duty trucks, and buses category but the device costs decrease similarly to the light duty vehicles. I guess the costs would be an order of magnitude less. Consequently, I am comfortable saying that the mitigation scenarios are projected to be $40 billion less than the Reference Case. I could find no cost numbers for the other components of the transportation category such as aviation, public transit and railroads. Light-duty vehicles account for two thirds of the total transportation sector emissions and the total costs for the light duty vehicles in my estimate of costs is about the same fraction. As a result, I don’t expect that the costs for the other sectors will be so large to account for the difference between reference case in Figure 48 $3 to $40 billion and my estimates which are negative $40 billion. Simply put, the costs are included in the Reference Case for the cost benefit analysis in Figure 48 and the Integration Analysis spreadsheets costs are inconsistent.

Implementation Issues

There is no bigger disconnect between the ZEV proposed strategy and reality than the ZEV charging infrastructure requirements. The biggest problem is the millions of cars will have to rely on chargers that cannot be dedicated for the owner’s personal use because the owners park on the street or in parking lot. In order to provide a credible ZEV strategy, the final Scoping Plan has to describe a plan how this could possibly work. The Integration Analysis simply presumes that it will work.

The Draft Scoping Plan assumes without documented analysis that zero-emissions trucks will be viable alternatives to current equipment. It is not enough to say they are viable because they have started to appear on the market. They must be tested. Moreover, there is no recognition that the trucking industry is nation-wide. If the proposed zero-emissions technologies costs are cheaper and don’t impose marked changes to operations then everyone will convert because it is a better solution. However, if it is not a better, cheaper solution that drives adoption of zero-emissions vehicles everywhere what is the plan for out-of-state vehicles? I cannot imagine that trucks will have to meet New York registration requirements if they are just passing through the state. If deliveries to New York must use zero-emissions vehicles that would mean swapping the motive power and that would markedly increase costs. Because of its importance to the viability of the Integration Analysis the final Scoping Plan should account for these issues.

My analysis of the Integration Analysis spreadsheet documentation showed another issue. The analysis presumes an unprecedented adoption rate for light-duty electric vehicles but provides no reason why this is possible. Anecdotally, I don’t want to accept the downsides of an electric vehicle for my lifestyle and the vast majority of my friends feel the same way. Where is the evidence that people will willingly choose zero-emissions vehicles?

Public Engagement

A common theme in the Draft Scoping Plan is that any doubts that the public has about any aspect of the net-zero transition can be simply addressed by convincing them with appropriate information. I guess the Draft Scoping Plan assumes that this will drive the adoption rate. The problem is that the draft Scoping Plan only tells one-side of the story instead of presenting all the issues and making a case for their preferred approach. Simply put, that is propaganda and it has no place in the Scoping Plan.

There is another disconnect between the public and the Climate Action Council when it comes to grid-interactive assets. This refers to using electric vehicle batteries as storage for the grid at times when the grid needs the power. I am positive very few people know about this component of the plan and cannot imagine public acceptance when they are told about it. The concept is that their vehicles will be grid-interactive assets and that means that they will lose control of their vehicle’s range because someone, somewhere decides that the power they have stored in their car for their own use is needed somewhere else. The personal inconvenience of that loss of control is a losing proposition in my opinion.

There are many specific issues with zero-emissions vehicles that are not addressed in the Draft Scoping Plan. As the United Kingdom implements their own EV mandates electric system upgrade costs have become obvious. California is leading New York in EV adoption but there are warning signs that implementation is not working out as expected. None of the apparent unintended consequences are addressed. Safety issues related to fires are becoming an issue but the Draft Scoping Plan does not recognize the issue.

Conclusion

I think that the transportation sector strategies in the Draft Scoping Plan are mostly wishful thinking. As the technology stands now it will be a long time before there isn’t a cost premium to get comparable vehicle capabilities for both new and used vehicles. The Integration Analysis projected deployment rates and device costs are both overly optimistic. The final Scoping Plan should present bounded estimates of costs and impacts and provide documentation that describes the positive and negative issues associated with electric vehicle deployment. The documentation has to make its case relative to the other side of the story and not simply ignore that there are any downsides or uncertainties. I am particularly concerned that the feasibility of the planned transition relative to affordability and reliability has been ignored.

Climate Act Draft Scoping Plan Transportation Sector Scenarios

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The comment period for the Draft Scoping Plan is open until June 10, 2022. The Council requested feedback on the components of three mitigation scenarios. My overview summary of the components described the scenarios and I previously described the building sector scenarios. This post discusses the control measures in the transportation sector and supplements an earlier article addressing transportation costs.

Climate Act Background

Integration Analysis Reference Case and Scenarios

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates in December 2021. I refer you to my building sector scenario post for more details. The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)”. Subsequently, the consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”. The three mitigation scenarios are described in Section I on page 14. This article describes the transportation sector actions.

Table 16. Level of Transformation by Scenario: Transportation from Appendix G Section I page 118 lists the transformation strategies for the transportation sector. It would take an extraordinary amount of work to debunk these wishful thinking strategies that may sound good for the Draft Scoping Plan but will not necessarily work in the real world. I will give just one example: rail transportation.

I previously addressed one particular aspect of transportation sector costs: the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 relative to Scenario 4. The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion. I estimate that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a reduction of 64.7 million miles. While my estimate is for 2035, consistent with the Empire Corridor evaluation, and the Draft Scoping Plan is for 2050, I don’t think there is any question that the numbers are inconsistent.

Within the non-road transportation category in Table 16, the rail component for all three scenarios states “90% electrification, 10% hydrogen use in 2050”. There is no detail of how those categories are broken out. According to Appendix G, Scenario 4 would get additional vehicle miles traveled reductions by using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS”. That alternative calls for an electrified passenger rail line from New York to Buffalo, including a completely new line between Albany and Buffalo. I cannot say if the plan is to add catenary to electrify the railroads or use battery-electric locomotives. Hydrogen (via electrolysis) is listed under the low-carbon fuels category and is supposed to be used for medium and heavy-duty vehicles and freight rail. Because freight transportation energy use exceeds passenger energy use, I assume that freight locomotives will be a mix of hydrogen and electric power.

There are two issues. The Appendix G Scenario 2 transportation investment category is only $3 billion more than the Reference Case, $15 billion for Scenario 3 and $40 billion for Scenario 4. In the absence of documentation, I can only guess that the different railroad transportation strategies in Scenario 4 reflect the added costs. Secondly, my interpretation of this strategy is that the Draft Scoping Plan expects that within New York State, railroad locomotives will have state-specific limitations. The problem is that the major railroads operate their locomotives over much greater distances than New York State. A train carrying containers from the West Coast might change locomotives once or twice but certainly runs through from the Midwest. Is the Scoping Plan expectation that there will be a change of locomotives at the state line? Theory may be fine but the practical implementation introduces a whole host of logistical issues and hidden costs.

Electric Vehicles

The Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions table lists specific programs in the Reference Case. Table 1 extracts assumption data from that spreadsheet so that the Reference Case and mitigation scenarios can be compared.

Consider the light duty vehicle strategies. For all motor vehicle registrations in New York in May 2022 there are only 62,123 electric vehicles statewide. The Integration Analysis projects that there will be 138,156 light-duty electric vehicles in 2025 in the Reference case. Scenario 2 projects 257,718 LDEV in 2025 and both Scenarios 3 and 4 project 275,417. In order to reach those levels, there will have to be a significant increase in electric vehicle sales.

My concern is that this increase in EV sales is based on no documented references. As Christian Twiste writes the current reality is very much different:

The average electric vehicle cost $65,977 as of March, compared to an average price of $45,927 across the entire industry, and a much lower price of $26,052 for a compact car, meaning going electric will cost a frugal family over 250% more than opting for a small car mainstay like a Toyota Corolla or Honda Civic. Even if you have the funds and are willing to spend them, Politico reported last weekend that most models are sold out until next year. Ford and Volkswagen both anticipate no new vehicles being available until 2023. Tesla’s least expensive model won’t be available until December, and Rivian, a new entry in the market, was forced to cut production in half this year due to supply chain issues.

The unprecedented buildout proposed in these Draft Scoping Plan scenarios has to be documented to be considered viable.

EV Charging

The LDV charger cost comparison table extracts data from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet related to charger systems. The Electric Vehicle Supply Equipment: Per-Vehicle Costs section at the top of the table lists cost directly from the Integration Analysis spreadsheet. In a previous article I found a reference bus charging infrastructure. The Center for Transportation and the Environment (CTE) Charging Infrastructure webinar listed costs between $5,000 and $7,000 for an AC level 2 charger and between $50,000 and $70,000 for a DC level 3 charger. There is an obvious disconnect between those numbers and the $24,000 value for 2020 in this table. More disturbing are the cost projections over time. The Integration Analysis projects a cost decrease of 18% for light duty vehicle battery chargers between 2020 and 2030, a 41% decrease between 2020 and 2040, and a 61% decrease between 2020 and 2050. The first ten years the price decreases by 18%, the second ten years the price decreases another 27% and the last ten years the price decreases another 34%. Sorry I am not buying this incredibly optimistic assessment of future cost reductions without documentation. The fact that the battery charging cost reductions are identical to the hydrogen fuel cell cost reductions suggests that some analyst simply made an assumption.

The total costs of course reflect these optimistic charger costs. Assuming that every new car needs a new charger, I multiplied the number of new battery electric light duty vehicles by the charger cost. Relative to the Reference Case the projected costs of battery electric light duty vehicles is projected to be $15 billion for Scenario 2 and $18.5 billion for Scenarios 3 and 4. Note that if the cost for chargers stays the same then the the projected cost is $37 billion for Scenario 2 and $42 billion for Scenarios 3 and 4. There is an associated issue that I could not address due to the poor documentation. The expected lifespan of an electric vehicle charging system is ten years. I don’t know if the final costs in the Draft Scoping Plan incorporate the lifespan adjustment that is going to increase costs markedly. That adjustment means that the real charger cost has to account for all the cars in the New York fleet. The final Scoping Plan should clarify whether those costs were included.

Light-Duty Vehicle Costs

The LDV Zero-Emission Vehicle Costs table extracts data from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet related to the costs of light-duty vehicles themselves. The Transportation – Vehicle Cost by Technology: Reference Trajectory section at the top of the table lists cost directly from the Integration Analysis spreadsheet. Note the cost of zero-emissions battery electric $43,794 and hydrogen fuel cell vehicles $58,392. The following table from Inside EVs lists the costs of battery electric vehicles on September 18 2022. There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.

https://insideevs.com/news/534027/electric-car-prices-us-20210918/

Similar to the car charging the cost projections over time are disturbing. The Integration Analysis projects a cost decrease of 35% for light duty battery electric vehicles between 2020 and 2030, a 42% decrease between 2020 and 2040, and a 44% decrease between 2020 and 2050. The first ten years the price decreases by 18%, the second ten years the price decreases another 11% and the last ten years the price decreases another 3.4%. Sorry I am not buying this optimistic assessment of future cost reductions without documentation.

I also calculated the total costs for vehicles over the period 2020 to 2050 in the LDV Zero-Emission Vehicle Costs table. The total cost for new vehicles in the Reference Case is $619.6 billion. Scenario 2, Strategic Use of Low-Carbon Fuels, total costs are $575.6 billion so the Draft Scoping Plan claims that converting to zero-emission vehicles will cost less than the Reference Case by $44 billion. The assumptions for Scenarios 3 and 4 must be identical because they both have a total cost of $581.8 billion for a difference of $37.8 billion. The massive cost reductions projected for zero-emissions vehicles is most of the reason that converting to zero-emissions is cheaper. Note that the apparent difference between the scenarios is the use of hydrogen fuel cell vehicles in Scenario 2.

Conclusion

In order to provide meaningful comments, the documentation has to be improved. In the first place, I recommend that all control measures should be listed, with the assumptions, costs and expected emission reductions provided. That information could clarify the questions about the differences between scenarios for the railroad projections. Without it I can only note that the projections seem inconsistent with the primary source mentioned.

Both the charger cost and zero-emission vehicle cost projections are overly optimistic about the future. The final Scoping Plan must update the analysis to incorporate what has happened since the Integration Analysis projections were completed. Costs have not been going down as projected for 2022. If they cannot forecast a couple of years ahead correctly then estimates out to 2050 are not credible.

The purpose of this analysis was to compare the transportation scenarios for the three mitigation scenarios. There is insufficient documentation to determine if the differences are meaningful. I cannot make any comments on the transportation sector scenario differences.

Draft Scoping Plan Comments Submitted in May

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Draft Scoping Plan that describes how to meet those goals was released to the public at the end of 2021 and the comment period is open until June 10, 2022. This post describes comments that I submitted in May 2022 for your information and in hopes that others will be encouraged to submit their own comments.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

The remainder of the article lists the summaries of comments that I submitted in May 2022.

Caiazza Comment Electric Service and Distribution System Upgrades Needed for Electric Heating

I submitted these comments on May 15, 2022. They are based on the work of Kip Hansen. He estimated costs associated with the distribution network for upgraded residential electric service; electrical distribution system improvements so that all homes can heat with electricity and use the “more usual and affordable” overnight electric vehicle chargers; and disconnecting natural gas supplies. I applied his reference information to New York and found that these costs range from $16.8 to $43.1 billion. These costs don’t include “the costs to homeowners, who must pay for the service upgrade, service entrance wires, and circuit breaker panel box. And, of course, does not include the purchase new appliances or the installation of EV chargers.” This cost estimate also does not include disconnection costs for fuel oil or propane heated homes. Finally, these estimates only apply to single family homes and not the 4.2 million housing units that are in multi-family buildings.

I believe the Draft Scoping Plan should describe all the control measures, provide references for assumptions, list the expected costs for those measures and list the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios. This information is not available so I could not confirm that these costs are included in the Integration Analysis or provide the opportunity to provide meaningful comments.

Caiazza Personal Comment on the Benefits Greater than Costs Claim

I submitted these comments on May 30, 2022 to incorporate the cost data that was released last week. The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”. In my verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading. This comment explains why that the Draft Scoping Plan must address this issue and makes recommendations for changes to language to clarify the caveats associated with the claim.

These comments show that the trick used to deceive the public into hearing that benefits out-weigh costs excludes legitimate Climate Act costs by mis-categorizing initiatives such as the 2035 zero-emission vehicle mandate as part of the business-as-usual Reference case. In addition, the Plan uses incorrect guidance to inflate the societal benefits of avoided emissions. The final Scoping Plan should describe all the control measures, provide the assumptions used for the strategies, and list the expected costs and expected emission reduction for each measure for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios so the public can decide for themselves which costs associated with “already implemented” program are appropriate.

Caiazza Personal Comments on Benefits of Climate Action

I submitted these comments on May 31, 2022 to include the information on my Citizens Guide Climate Act Effects on Global Warming Page into the record. The Draft Scoping Plan asserts that there will be benefits from the implementation of the Climate Act but provides no documentation to support that claim. These comments highlight the claims that must either be substantiated by analysis and documentation or removed from the final Scoping Plan.

These comments include my personal analyses of the potential effect of the Climate Act on global warming and global emissions both as an example of the analysis necessary to make claims and as a cautionary tale. The fact is that any expectation that the Climate Act will have any detectable effect on the severity of current or future climate change is mis-placed because the expected impact on global warming is an immeasurable 0.01°C by the year 2100. If you cannot measure the change in temperature there is no way you can detect a change in the purported effects of that temperature change.

In addition, when New York’s emissions are considered in the context of global emissions it is unreasonable to expect that other jurisdictions will be encouraged to implement similar restrictions. In the first place, New York’s emissions are less than one half of one percent of global emissions. At the same time, New York’s 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world. That ranking was achieved in no small part because New York has had access to abundant, reliable, and affordable energy for many years. Expecting that countries without our wealth will be encouraged to develop costly zero-emissions energy resources is naïve and immoral.

Conclusion

There are not many days left until the end of the comment period. I am planning to submit as many comments based on the work done in my blog as possible in that time. If time were not so short, I would spend more time writing stand-alone articles for the blog. As an alternative I am just going to copy the summary from comments submitted as a blog update every few days for the next couple of weeks.

If you are a New Yorker, I encourage you to submit comments at the Climate Act comment page. I fear the only thing that we can count on from the comments submitted is a tally of how many people support the Draft Scoping Plan versus how many people don’t. In New York’s political climate it is all about the numbers and not the science, technology, or expert opinion. Just go to the page and you can enter 2000 characters of text as a comment. If nothing else just explain that you have concerns about reliability, affordability, safety and lack of personal choice associated with the transition to net-zero. Feel free to copy as much of my material as you want and do not feel obligated to mention the source.

Climate Act Benefits Greater than Costs Claim Numbers Update

One of the key claims in the Draft Scoping Plan documentation is that “The cost of inaction exceeds the cost of action by more than $90 billion”. Last month I consolidated documentation that had been presented in multiple earlier posts that supports my statement that the costs far exceed the benefits. The single most glaring omission of the Draft Scoping Plan is the near complete lack of cost documentation but with two weeks left in the comment period some of the numbers that were used in the Benefits and Costs chapter of Appendix G were made available. This post uses the new information provided to evaluate the benefits claim.

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 have written extensively on implementation of New York’s response to climate change because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. Bottom line for me is that in its present form the Climate Act 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) establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

At a recent meeting there was an opportunity for the public to ask questions about the New York State Energy Research & Development Authority (NYSERDA) work supporting the Draft Scoping Plan. I asked about the missing cost information and John Williams, Vice President, Policy and Regulatory Affairs, responded: “In response to your inquiry for additional cost information, we have added clarifying information to the existing Excel document, ‘Appendix G Annex 2: Key Drivers and Outputs,’ which can be found on the Climate Action Council Draft Scoping Plan website.” I extracted all the new tables to a separate spreadsheet. The spreadsheet table summarizing the cost methods is difficult to read so I have also extracted that information in a document. Also note that more detailed documentation for my cost-benefit analysis is available here and here.

Benefits Exceed the Costs Claim The Draft Scoping Plan claim that “The cost of inaction exceeds the cost of action by more than $90 billion” is presented in Figure 51 in Appendix G Integration Analysis Technical Supplement. The Climate Act overview presentation for the public hearings included a similar figure and made the claim. However, there is a caveat or in this case, a trick. In the following figure I have highlighted the description that notes that the benefits are “relative to Reference Case”. By the way, that caveat is usually not noted when these results are presented. The clarifying data in the updated spreadsheet lists all the values in the table. Because the values are exactly the same, I believe the updated spreadsheet numbers were simply pulled from the figure and not from the analyses themselves.

Reference Case Costs

The next figure I evaluated in my analysis of the benefits claim was the total system expenditures shown in Figure 48. My biggest gripe was that the values in the Figure were not quantified. Thankfully the clarifying data in the updated spreadsheet provides numbers. The Reference Case total in the following table lists the net present value of system expenditures as $2,665 billion. Scenario 2, low-carbon fuels expenditures are $2,974 billion; Scenario 3, accelerated transition expenditures are $2,953 billion; and Scenario 4, beyond 85% reductions expenditures are $2,972 billion. More importantly the category costs are now available. Note that these numbers are not rounded in any way so I believe that they were copied from a different spreadsheet or model.

I have frequently heard Climate Action Council member refer to the net cost totals in Figure 47 as the costs of Climate Act implementation. However, these costs are relative to Reference Case for the three mitigation scenarios. In other words, the numbers presented subtract out the Reference Case costs. As explained in the previous post, the rationale for this approach is those estimates include not only the business-as-usual programs but also programs that are already implemented. This new cost information can be used to see if these already implemented programs are really business-as-usual strategies.

Category Cost Implications

The clarifying information update provides numbers associated with each category in Figures 47 and 48. In this section I will address three of the more impactful categories.

The “Buildings Investment” category “Includes capital and operating expenses for building equipment and appliances (e.g., space heaters, air conditioners, water heaters) and investments for building shell upgrades”. The net present value of system expenditures from 2020 – 2050 is $565 billion for the Reference Case. The building sector costs for the mitigation scenarios only range from $235 billion to $240 billion (42% increase) but the emission decreases relative to the Reference Case are 95% greater. In my opinion, that seems inconsistent with the Reference Case costs. It appears that Reference Case cost reductions per ton are double the mitigation scenarios. This anomaly could be caused by excluding the costs but including the emission reductions from the presented numbers.

The ”Transportation Investment” category “Includes capital and operating expenses for light-duty vehicles, medium- and heavy-duty vehicles, and buses, in addition to charging infrastructure costs”. The net present value of system expenditures from 2020 – 2050 is $1,056 billion for the Reference Case. Previously it appeared that the bar chart components difference to add charging infrastructure and the additional costs of electric vehicles relative to current alternatives seemed unacceptably low. According to the Integration Analysis, Scenario 2 transportation initiatives will reduce emissions 79% relative to the Reference Case at a cost of only $2.97 billion. Obviously, this does not pass the smell test. Something is overlooked or deliberately manipulated to make this claim.

The Figure 47 category label is Electricity but the description in the cost methods overview table is Electricity Incremental. I assume they are the same. The description of this category states that it “Includes capital and operating costs for electricity generation, transmission, costs to upgrade existing distribution system, and in-state hydrogen production costs.” The net present value of system expenditures from 2020 – 2050 is $424 billion for the Reference Case. The Integration Analysis described in the Draft Scoping Plan projects that the additional costs necessary to transition the electric grid to zero-emissions ranges between $89 and $111 billion. According to the Integration Analysis that covers the cost of between 5,659 and 7,265 MW on additional land-based wind, 7,393 and 9,310 MW of additional off-shore wind, 40,648 and 45,254 MW of additional solar, and 10,987 and 14,731 MW of additional energy storage beyond the capacity expected in the Reference Case. The additional costs necessary to the transition the electric grid to zero-emissions range between $89 and $111 for incremental electricity. Many things are overlooked or deliberately manipulated to make this claim. A US Energy Information Agency (EIA) report “Capital Cost and Performance Characteristic Estimates for Utility Scale Electric Power Generating Technologies” published in 2020 estimates that a 200 MWh battery energy storage system has a capital cost of US $65.9 million. Assuming that the average of the additional energy storage capacity provides four hours of energy for every MW and using the EIA cost number, energy storage costs alone are $213 billion.

Discussion

In my previous post I argued that the authors of the Draft Scoping Plan apparently included the already implemented transportation investment statewide zero-emission vehicle mandate in the Reference Case. I pointed out that suggesting that the zero-emissions vehicle “implemented policy” should not be included in the Climate Act implementation costs is disingenuous at best. The press release announcing that the Governor signed the legislation states: “The actions announced today in advance of Climate Week 2021 support New York’s ambitious goal of reducing greenhouse gas emissions by 85 percent by 2050, as outlined in the Climate Leadership and Community Protection Act.” It goes on to quote Governor Hochul: “New York is implementing the nation’s most aggressive plan to reduce the greenhouse gas emissions affecting our climate and to reach our ambitious goals, we must reduce emissions from the transportation sector, currently the largest source of the state’s climate pollution”. I think that these statements pretty well represent any dispassionate observer’s belief that the only reason for this mandate is to support the Climate Act. As such those costs are not legitimate Reference Case business-as-usual costs.

I also pointed out the claim that “The cost of inaction exceeds the cost of action by more than $90 billion” includes a caveat that the comparison is relative to the Reference Case. I showed how the semantic justification that the transportation investments were already implemented excluded the costs of the zero-emissions vehicle mandate from the costs side of the comparison. In order to further tilt the results, the emission reduction benefits attributed to the transportation investments were not excluded in the comparison. In other words, the comparison takes out the costs that would hurt their case but leaves in emission reduction benefits that help make the case that the benefits are greater than the costs.

The newly released categorial cost data provide evidence of similar manipulation of the data for other categories to provide the desired result. The building sector costs for the mitigation scenarios only range from $235 billion to $240 billion (42% increase) but the emission decreases relative to the Reference Case are 95% greater. The numbers also confirm my initial transportation initiative concerns. According to the Integration Analysis, Scenario 2 transportation initiatives will reduce emissions 79% relative to the Reference Case at a cost of $2.97 billion. The Integration Analysis projects that just the cost of battery electric vehicle chargers will be over $15 billion for Scenario 2 relative to the Reference Case. Finally, the claim that the additional costs necessary to transition the electric grid to zero-emissions range between $89 and $111 for incremental electricity are ludicrous. I estimate that the additional energy storage costs alone are $213 billion more than the Reference Case costs.

Conclusion

In my opinion the Climate Act claim that the benefits out-weigh costs is obviously incorrect. I have shown the recently released numbers confirm my earlier analyses. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. In order to fulfill this obligation, the Draft Scoping Plan must describe all control measures, assumptions used, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios. Given the overt manipulation of the data used to erroneously claim that “The cost of inaction exceeds the cost of action by more than $90 billion”, I have no faith in any cost numbers presented without that documentation.

New York Legislative Race to the Bottom

This article was originally posted at Watts Up With That

In a couple of weeks, the comment period closes for the Draft Scoping Plan that outlines how New York is to achieve its Climate Leadership and Community Protection Act net zero ambitions. Despite the fact that any rational observer can only conclude that there is no real plan for a reliable electric system and the Plan provides very little cost information, environmental advocates have convinced the most progressive of the State’s legislators that it is not enough. On May 26 Assemblyman Jeffrey Dinowitz, Chair of the Assembly Codes Committee, and State Senator Liz Krueger, Chair of the Senate Finance Committee, along with environmental advocates and experts, announced the introduction of the Climate Change Superfund Act (S.9417). In brief it codifies the litigation against fossil fuel companies as a cash cow for adaptation programs.

The press release states:

In light of the billions of dollars in damages that New York State has suffered as a result of climate change, and the tens of billions more to come in future decades, this first-in-the-nation legislation will use the polluter-pays model exemplified by existing federal and state superfund laws to collect $30 billion over ten years for climate change adaptation from the parties most responsible for causing the climate crisis – fossil fuel companies.

Right now consumers are facing pain at the pump as well as in their gas and electric bills. At the same time, the oil and gas industry is raking in enormous profits.The Climate Change Superfund Act will claw back some of the oil and gas industry’s recent windfall profits and use them for adaptation costs that would otherwise be charged to state taxpayers. The program is designed to prevent such costs from being passed on to consumers.

“The climate crisis is here, right now, and it’s already causing billions of dollars in damage and a growing death toll in New York State,” said Senator Krueger. “We must begin to make the investments necessary not only to mitigate future climate change, but to adapt to and defend ourselves from the damage that’s already been done. The cost of inaction is inconceivable – in money, in lives, and in countless other ways. Nonetheless, there will be a large price-tag to the work we have to do, and it’s only fair that the companies who made the mess should pay for cleaning it up. The Climate Change Superfund Act is one critical piece of the puzzle of funding our state’s response to the climate emergency.”

“The damage done to our climate and to our communities from decades of corporate disregard for scientific evidence is irreparable and omnipresent,” said Assemblyman Dinowitz. “As we continue to take big steps towards a green future in order to mitigate the worst potential impacts from climate change, the Climate Change Superfund Act would be a vital resource to invest in adaptive and resilient infrastructure, and it is common sense to charge those who did the most damage to our climate for the costs of keeping people alive amidst our new climate reality.”

Rationale

Unfortunately, their rationale uses the same line of reasoning that was used to pass the Climate Act. Because “everybody” knows that climate change causes unusual weather and the climate and weather illiterate think anecdotes prove their case, they actually believe that New York has suffered billions in damages from climate change and not just weather.

The bill language says:

Climate change, resulting primarily from the combustion of fossil 6 fuels, is an immediate, grave threat to the state’s communities, environment, and economy. In addition to mitigating the further buildup of greenhouse gases, the state must take action to adapt to certain consequences of climate change that are irreversible, including rising sea levels, increasing temperatures, extreme weather events, flooding, heat waves, toxic algal blooms and other climate-change-driven threats. Maintaining New York’s quality of life into the future, particularly for young people, who will experience greater impacts from climate change over their lifetimes, will be one of the state’s greatest challenges over the next three decades. Meeting that challenge will require a shared commitment of purpose and huge investments in new or upgraded infrastructure.

Implementation

It is a holiday weekend and I have other things to do than to try to make sense of the implementation language in the proposed legislation. If ever get to the point where I can stomach looking into the plan, I will try to figure out how they account for the fact that New York’s total GHG emissions are less than half a percent of total global emissions. What share of global emissions is accountable for New York’s alleged problems? Shouldn’t that be somehow a function of New York emissions? I suspect the innumeracy of the authors of the legislation affects the plans and upon closer inspection will undermine the whole thing.

My impression skimming through the legislation is that this applies to fossil fuel production. Ronald Stein recently pointed out that the primary usage of crude oil is “to manufacture derivatives and fuels which are the ingredients of everything needed by economies and lifestyles to exist and prosper”. If I am right that this legislation covers fossil fuel production then how do they hope to address that aspect without unduly impacting consumers?

One last point. In another outstanding example of cluelessness, the underlying argument that the primary reason fuel prices have gone up is because the evil oil companies are making windfall profits. Somehow these energy market experts have convinced themselves that if this monstrosity ever gets enacted and withstands the inevitable lawsuits that the fossil fuel producers won’t simply pass the costs on to consumers. They say they are going to prevent that, but aside from yet another magical solution, I cannot imagine how that could ever work in favor of the consumer. At the same time these same politicians have enacted a holiday on fuel taxes because costs are too high.

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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.

Draft Scoping Plan Cost Documentation Announcement

Note: This post was updated to add a revised link to the spreadsheet that lists all the clarifying information update on May 29, 2022.

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Draft Scoping Plan that describes how to meet those goals was released to the public at the end of 2021 and the comment period is open until June 10, 2022. This post announces the fact that the with two weeks left in the comment period the numbers that were used in the Benefits and Costs chapter of Appendix G of the documentation are now available.

Climate Act Background

Draft Scoping Plan Cost Documentation

The Draft Scoping Plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”. In my recent verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading. I recently published an article that consolidates documentation that supports my contention that the costs far exceed the benefits. A main finding in my cost-benefit analysis is that most of the values in the supporting documentation (Section 3.4 Benefits and Costs, Appendix G Integration Analysis Technical Supplement Section I) are only presented in bar charts. In other words, the values of the numbers are not included.

At a recent meeting there was an opportunity for the public to ask questions about the New York State Energy Research & Development Authority (NYSERDA) work supporting the Draft Scoping Plan. I asked about the cost information and John Williams, Vice President, Policy and Regulatory Affairs, responded. He indicated that detailed information was available and suggested that I follow up for more information. I sent him an email asking for specific information. I explained that, for example, in Appendix G, Section I, Figure 48 lists the net present value of system expenditures in Reference Case and Scenarios 2-4. The only associated number given in the text is a mention that the Reference Case totals $2.7 trillion. I said that I believe that at a minimum the values of the cost categories listed on the right-hand side of the bar charts should be available in a table somewhere for each of the scenarios. I also said that detailed control measure costs should also be available so that the public can check the category costs and critique specifics.

On May 27 Mr. Williams responded:

In response to your inquiry for additional cost information, we have added clarifying information to the existing Excel document, “Appendix G Annex 2: Key Drivers and Outputs,” which can be found on the Climate Action Council Draft Scoping Plan website. At the end of the workbook, you will see a series of green tabs. The “Cost Methods Overview” tab describes how costs were calculated throughout the analysis. Accompanying tabs provide the data associated with the cost figures published in the Draft Scoping Plan.

We hope this will help you and all stakeholders better understand how our cost analyses were performed. Please reach out if there are any questions.

My hats off to Mr. Williams for responding to my request. He is the only one in the Administration that has responded to any of my comments.

Conclusion

While I really appreciate the response it is a problem that this obvious need was not included until there are only two weeks left in the comment period. Unfortunately, only two things were provided: the numbers associated with the cost figures in Section 3.4 Benefits and Costs of Appendix G and a table summarizing the cost methods. I also believe that it is problematic that a casual reader would have no idea that this new information has been included in an update because the appendices listing on the Climate Act Draft Scoping Plan page does not mention that an update is available. Finally, tacking 15 tables at the end of an already huge spreadsheet does not foster easy use. I have extracted all the new tables in a separate spreadsheet. The spreadsheet table summarizing the cost methods is difficult to read so I have also extracted that information in a document.

I will follow up with another post later regarding the information provided.

Climate Act and New York State 2021 Wind Resources

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. One of the targets is a zero-emissions electricity grid by 2040. In order to meet that target the plan is to expand wind and solar generating resources. This post looks at the 2021 wind resource availability relative to Climate Act expected wind resource builds.

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 have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. 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 establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Draft Scoping Plan Wind Resources

The Integration Analysis has three mitigation scenarios. The Mitigation Scenarios Summary Fuel Mix table projects that 9,445 MW of on-shore wind capacity will need to be developed in the Scenario 2, “Strategic Use of Low-Carbon Fuels”; 10,154 MW in Scenario 3, “Accelerated Transition Away from Combustion”; and 11,052 MW in Scenario 4, “Beyond 85% Reductions”.

At this time the New York Independent System Operator (NYISO) is preparing its capacity expansion projections. I previously described that effort and noted that the analysis includes 27 sensitivity cases in addition to the preliminary baseline. With the caveat that those projections are the first draft and could change significantly, it is important to note that the preliminary baseline projection for land-based wind is 22,789 MW and that the sensitivity cases range from 16,702 MW to 31,678 MW. Clearly, at some point the differences between the Integration Analysis and the NYISO projections have to be resolved given that the NYISO is projecting on the order of double the Integration Analysis.

2021 Wind Resources

The NYISO Gold Book summarizes New York load & capacity data. It includes a table that lists pertinent information for every generating unit in New York. I have been extracting wind facility information so that I could calculate capacity factors for many years as shown in this table. In 2021 two new facilities came on line. At the start of the year the nameplate capacity of all the wind facilities was 1,985 MW and it increased to 2,191 MW after the new facilities came on line. However, the capacity factor, the actual generation produced relative to the maximum possible generation was only 22.3%.

I found another NYISO resource dated March 31, 2021 that provides the 2021 wind production the 2021 wind curtailment. The data sets list the hourly total wind production and curtailments for the entire New York Control Area (NYCA). I have summarized the data in the following table. Curtailments are those hours when the system load is small enough that wind production is greater than what is needed so the wind power is curtailed, i.e., not used.

With respect to production, I believe that these data show that the New York wind resource is not particularly good. The percentiles are shown in the first column and the data indicate that wind power is greater than 78% of the total capacity only 87 hours (99^th percentile) in 2021. Three quarters of the time the production is less than 696 MW equivalent to one third of the total capacity. If you assume that production less than 10% is the threshold for no value then wind won’t be producing appreciable power 30% of the time.

Discussion

These results have an important ramification for resource planning. The existing wind facilities are spread across the state. NYISO cannot provide individual unit generation so I cannot definitively say that those facilities are highly correlated. However, given that half the time the total generation capacity is only 16% of the total I am sure that is the case. As a result, that improving energy production at the lower levels requires a lot more generation capacity. For example, at the 25^th percentile the total capacity is 151.6 MW. If planners predict we need wind generation capacity to equal 1,000 MW 75% of the time. then, based on 2021 data, the state land-based wind capacity would have to increase to 13,900 MW, over six times greater than current capacity

The key point of this article is that there are limitations to New York’s wind resource capability. Dietmar Detering and I have corresponded about the Integration Analysis wind resource projections. He has found that “The Integration Analysis predicts between 10,997 MW and 13,239 MW of land-based wind installed within New York by 2050, and estimates annual generation between 31,224 GWh and 37,896 GWh which corresponds to a capacity factor of about 33%. My capacity factor table shows that the maximum state-wide capacity was 28% in 2014 and was only 22.3% in 2021. The Climate Action Council needs to reconcile those differences.

There are a few possible explanations. New York’s decreasing capacity factors could reflect the age of the fleet. The Integration Analysis could reflect larger wind turbines that have higher capacity factors because they can reach higher wind speed layers. In either case that suggests that all the New York existing land-based wind facilities need to be replaced. There is insufficient documentation available in the Draft Scoping Plan to confirm whether the Plan assumes complete replacement. As far as I can tell the Integration Analysis assumes “indefinite” expected lifetimes for energy storage, wind and solar infrastructure and assigns lifetimes to other resources despite the fact that renewable resource lifetimes are half that of other resources. Given that creative bookkeeping I doubt that existing resource replacements are included in the total costs of the mitigation scenarios.

Conclusion

The Climate Act 2040 zero-emissions target will require much greater reliance on wind and solar generating resources. Unfortunately, the authors of the Climate Act did not recognize limitations for those resources. These results show that land-based wind in New York is not a particularly good resource. Winter time solar is poor because of New York’s high latitude with short days in the winter and excess cloudiness downwind of the Great Lakes. Overall, New York’s has a poor wind and solar resource capability.

It is imperative that the State conduct a detailed evaluation of renewable energy resource availability to determine the generation and energy storage requirements of the future New York electrical system. As these results show, the annual wind resources capabilities are low. I submitted comments in March that explain that in order to ensure electric system reliability for an energy system that depends on renewable generators and energy storage, the resources available during periods of low wind and solar energy production must be known. To date, many studies do not consider the importance of worst-case conditions on reliability planning and I believe that the Draft Scoping Plan also fails to address this issue. The comments explained that there is a viable approach that could robustly quantify the worst-case renewable energy resources and provide the information necessary for adequate planning.

All Electric Building Act – Affordability

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. In order to implement the changes needed additional legislation is needed. Environmental advocates are pushing Renewable Heat Now bills including the All-Electric Building Act. This post puts that legislation into the context of the current electricity reliability crisis facing New Yorkers.

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 have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. 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

I previously described two bills that address the building sector components that need to be changed for the net-zero transition. According to the Advanced Code Act: “Buildings are the single largest user of energy in the State of New York, accounting for almost 60% of all energy consumed by end-use in the State.” Revisions to building codes will be “directly impacting a building’s energy load and carbon footprint”. The Gas Ban notes that the Climate Act “requires greenhouse gas emission reductions from all sectors, which will entail, among other things, converting buildings throughout the state from heating and cooking with combustible fuels to heating and cooking with non-emitting sources such as energy-efficient air, ground, and water sourced electric heat pumps which also provide cooling, and electric and induction stoves”. I understand that the Advanced Code Act has already passed.

All Electric Building Act

I described the public hearing for this legislation that establishes the All-Electric Building Act. As has been the case with other legislation the bill assumes that there are no technology limitations and that all new buildings can be built without fossil fuel infrastructure without any issues.

The proposed legislation revises the state energy conservation construction code to “prohibit infrastructure, building systems, or equipment used for the combustion of fossil fuels in new construction statewide no later than December 31, 2023 if the building is less than seven stories and July 1, 2027 if the building is seven stories or more”. It allows the building code council to exempt systems for emergency back-up power, or buildings specifically designated for occupancy by a “commercial food establishment, laboratory, laundromat, hospital, or crematorium, but in doing so shall seek to minimize emissions and maximize health, safety, and fire-protection.” However, it limits the areas where the combustion of fossil fuels is allowed and the building must be designed as all-electric ready.

The legislation includes a provision for affordability. It requires state agencies to identify policies to ensure affordable housing and affordable electricity (meaning that electricity costs no more than 6% of a residential customer’s income) for all-electric buildings by February 1st, 2023. Note that I have been unable to determine the current affordability status of New York.

Affordability

Energy affordability, in general, and electricity affordability, in particular, should be a major concern. There is no question that there is a home energy crisis:

According to WE ACT for Environmental Justice, an organization whose mission is to combat environmental racism and build healthy communities for people of color, 13 percent of all residential households—about 1,137,000 in total—are 60 days in arrears on their utility bills, with an average of $1,427.71 in debt. The debt level is even higher for Con Ed customers, averaging about $2,085 per residential household/customer.

More than 471,629 disconnection notices were sent out in April 2022 for residential customers across New York State, with Orange and Rockland counties leading the way, with 79 shutoffs that month. For commercial customers, there were more than 77,651 disconnection notices overall, with almost 2,544 already carried out. National Grid (KEDLI) had the highest number of service terminations, 882, followed by Con Edison at 831 terminations and National Grid (KEDNY) at 310. Residential terminations in March were at 131 and commercial terminations stood at 1,688.

The proposed legislation addresses affordability but puts the cart before the horse by evaluating electricity affordability after the bill is enacted:

§ 11-111. Additional reporting. On or before February first, two thousand twenty-three, the department of public service, the division of housing and community renewal, the department of state, and the New York state energy research and development authority shall report jointly to the governor, the temporary president of the senate, the minority leader of the senate, the speaker of the assembly, and the minority leader of the assembly, regarding what changes to electric rate designs, new or existing subsidy programs, policies, or laws are necessary to ensure that subdivisions six and seven of section 11-104 of this article do not diminish the production of affordable housing or the affordability of electricity for customers in all-electric buildings. For the purpose of this subdivision, “affordability of electricity” shall mean that electricity does not cost more than six percent of a residential customer’s income.

In 2016, New York State set a target that low-income New Yorkers should pay no more than 6% of their income toward energy bills and I applaud its inclusion in this legislation. However, I have not been able to find out how New York State stands relative to this target. I did find an analysis for New York City that showed that over 460,000 low-income families in New York City are paying over 6% of their pre-tax income toward their energy bills. That works out to 14.6% of the households.

All Electric Building Act Costs

I have yet to see an evaluation of the potential costs of this legislation. The Integration Analysis spreadsheets that support the Draft Scoping Plan include a table with device costs. In order to ensure that heat pumps work at all times in New York’s winters upgrades to the building shell (insulation, infiltration and windows) are needed. According to device cost table an air source heat pump runs $14,678 and a deep shell upgrade of $45,136 totaling $59,814 or a ground source heat pump ($34,082) and a basic shell upgrade ($6,409) totaling $40,491 for single family homes. This legislation would mandate adding those costs above the cost of an efficient furnace or boiler ranging from $3,085 to $8,975. Obviously, those added costs are going to add to the affordability burden for New Yorkers.

Conclusion

The bill requires a study after the law becomes effective to ensure it does not “diminish the production of affordable housing or the affordability of electricity for customers in all-electric buildings”. That is an example of the cart before the horse mindset of this legislation and the Climate Act itself. This bill should be amended to include a specific affordability target and only proceed as long as the metric is achieved. I think that there should be a state-wide goal for the percentage of customers that don’t meet the 6% target and the State should make the current value readily available. Without that information it is inappropriate to implement this legislation.

By any measure New York’s complete elimination of GHG emissions is so small that there will not be any effect on the state’s climate and global climate change impacts to New York. New York’s emissions are only 0.45% of global emissions. I have shown that global emissions have increased more than New York’s total share of global emissions since 1995. In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year. Against that backdrop it is not clear why any increase in New York energy costs from any renewable heat legislation should be considered until the electricity energy crisis is resolved.

Public Hearing on All-Electric Buildings Act

On May 12, 2022 the New York State Assembly had a legislative hearing for Assembly Bill A8431, the “all-electric building act”. The recording for the hearing offers a glimpse into New York’s irrational net-zero transition legislation. This post describes the legislation and the testimony presented by Climate Action Council Co-Chair Doreen Harris and her response to questions about costs of this control strategy.

Climate Act Background

I recently described two bills. According to the Advanced Code Act: “Buildings are the single largest user of energy in the State of New York, accounting for almost 60% of all energy consumed by end-use in the State.” Revisions to building codes will be “directly impacting a building’s energy load and carbon footprint”. The Gas Ban notes that the Climate Act “requires greenhouse gas emission reductions from all sectors, which will entail, among other things, converting buildings throughout the state from heating and cooking with combustible fuels to heating and cooking with non-emitting sources such as energy-efficient air, ground, and water sourced electric heat pumps which also provide cooling, and electric and induction stoves”.

All-Electric Building Act

This legislation establishes the All-Electric Building Act. As has been the case with other legislation the bill assumes that there are no technology limitations and that all new buildings can be built without fossil fuel infrastructure.

Harris Testimony

The May 12, 2022 legislative hearing for this bill started with testimony from Doreen Harris. She is the head of the New York State Energy Research & Development Authority (NYSERDA) and co-chair of the Climate Action Council. Her presentation starts on the video at 4:45. She explained that buildings are the largest source of greenhouse gas emissions according to the most recent inventory performed using the Climate Act’s unique emission estimation methodology. In order to eliminate those emissions, the Draft Scoping Plan found that fully electrify buildings are necessary. Unfortunately, her testimony was long on generalizations and short on specifics relative to what the Draft Scoping Plan requires to meet the net-zero goals.

She noted that in this year’s State of the State the Governor announced a commitment to support two million climate friendly homes. This includes a plan to achieve one million efficient and electrified homes and up to one million electrification ready homes by 2030. To achieve this, they plan to increase energy efficiency and deploy clean home heating and cooling technologies.

Rather than explaining what the Draft Scoping Plan projects is necessary she talked about NYSERDA programs. For example, she said there is “laser focus” on the combination of heat pumps and energy efficiency because “when installed at scale they are the number one solution for emissions reductions in the sector. Harris bragged (at 7:40) that the New York Stretch 2020 Energy Code will save homeowners $275 per year. However, that code change “improves the State Energy Code’s efficacy by roughly 10%”.

I submitted comments on the Draft Scoping Plan residential heating projections that showed that a primary driver of home heating electrification is the building shell cost. The Draft Scoping Plan states:

Two bundles of building shell improvements have been included: a basic shell upgrade and a deep shell upgrade. Basic and deep shell upgrades include a variety of measures focused on reducing energy use and increasing occupant comfort; these measures include, for example, varying levels of roof and wall insulation improvements, window treatments such as double or triple paned windows and infiltration improvements. Space heating demands are reduced by 27-44% with the basic shell package and 57-90% with the deep shell package, depending on building type.

Clearly the Stretch 2020 Energy Code is no where close to the basic or deep shell upgrades envisioned in the Draft Scoping Plan.

Most people at the hearing were worried about costs. Chair Harris lost the opportunity to explain what the Draft Scoping Plan projects as costs for the air source heat pumps, ground source heat pumps, and different building shells. She said that heat pumps paired with high performing building envelopes will work everywhere in New York. She did not explain how much that might cost. The following table lists data from the Council’s Plan. My interpretation of the Scoping Plan is that a ground source heat pump paired with a basic shell upgrade ($40,941) or an air source heat pump paired with a deep shell upgrade ($60,954) should work everywhere. The reference table gives the price of an efficient gas furnace as $3,085. That is quite a price premium for zero-emissions.

Given its importance all the assumptions used to generate the numbers should be available but there is insufficient documentation for that. The Draft Scoping Plan claims only 26% of residences need deep shell upgrades. I estimate that more than half actually will need to have deep shell upgrades using a more refined climatology. I estimate that the entire building sector component cost is $230 billion relative to the reference case in the Draft Scoping Plan. I calculated that just the residential retrofit heat electrification costs range between $259 billion and $370 billion using one methodology and between $295 billion and $370 billion based primarily on the number of residences that need deep building shell upgrades.

Chair Harris also made the claim that all-electric homes will be “more resilient and safer than buildings previously built and supported by fossil fuels as they lose heat during power outages”. I can only guess that the rationale for this argument is that the building shell improvements will be so good that the buildings will not lose as much heat when the power goes out. Eventually, however, even the best insulated and sealed home will become too cold to be livable. That is why people who are truly concerned about safety during power outages incorporate an independent backup system. For heating many use wood stoves. In my case I have used a backup electric generating system: first portable and more recently a whole house generator. A backup system that can be operated indefinitely is the truly “more resilient and safer” alternative.

The responses to questions were interesting. Assemblyman Cusik at 13:00 asked for the timeline for the State’s plan for implementing fully electric. Rather than explaining what is in the Draft Scoping Plan Chair Harris gave the pitch for Hochul’s two million climate friendly homes by 2030 proposal. Recall that this includes a plan to achieve one million efficient and electrified homes and up to one million electrification ready homes by 2030. In my opinion the sign of an “efficient and electrified” home is that it will have a heat pump installed. The following table shows that the Governor’s plan is 32% less than what the Draft Scoping Plan Integration Analysis projects is necessary.

She went on to say the plan is 200,000 decarbonized homes per year by 2030 as opposed to 20,000 now. Assuming that the sign of a decarbonized home is an installed heat pump the following table indicates that this estimate is much less than what is needed. It is not clear what the metric for today’s electrification metric is but 20,000 is not consistent with the Reference Case.

Affordability questions were asked numerous times. Cusik asked specifically whether there is a cost analysis in the plan at 14:34. The response was not direct: “Yes, certainly. Affordability is and will continue to be significant priority and a central focus of our implementation of the Climate Act.” Harris went on to say that NYSERDA programs are looking at upfront costs. Those programs found that all-electric homes are on the range of 2 to 4% higher than a building that would be constructed with gas infrastructure at this point”. She claimed costs will come down in the future but did not mention that the Draft Scoping Plan does not incorporate such a cost reduction.

In response to questions by Assemblyman Zebrowski about existing homes Harris noted that “as existing buildings turnover in ownership or replacement of installed equipment that’s when we would be addressing existing building stock”. This confirms my expectation that when a homeowner sells a home with gas-fired appliances after 2030 that the home will have to be upgraded to all-electric. Obviously that cost will be borne by the seller.

In response to Assemblyman Palmesano’s question about affordability Chair Harris claimed that the NYSERDA Building of Excellence found that a single family home built today for $350,000 added $17,000 upfront cost for heat pump and building shell (Video at 33:20).

At (40:49 in video) Assemblyman Lawler asked for a specific cost estimate to electrify a home. Chair Harris had to respond but only prattled on that she could not provide a specific price. She said that each home will be different and the building shell improvement for each house can only be determined by doing an energy audit. This is all baloney because we all understand that it is not possible to predict exactly what our individual home is going to cost to be electrified. However, the Draft Scoping Plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion” so there are costs estimates available in the Integration Analysis. It would have been interesting to see the reaction if the Chair Harris had been asked what the Integration Analysis device costs were and what the expected total costs for new housing units and retrofits would be.

Based on my evaluation of the Integration Analysis spreadsheets I can answer those questions. The 2030 Climate Friendly Homes Compared to Integration Analysis Homes with Heat Pumps table earlier in this post gives an example of the device costs available in the Draft Scoping Plan documentation. The Plan’s recommended electrification approach is electric heat pumps and building shell improvements (more insulation, infiltration improvements and better windows). Based on the information in the Plan, I estimate that for a single-family residence, an air source heat pump ($14,678) will need to be coupled with deep shell improvements ($45,136) totaling $60,954 or a ground source heat pump ($34,082) coupled with basic shell improvements ($6,409) totaling $40,491 will be needed to provide adequate comfort similar to those oft-referenced homes in the Nordic countries. These numbers are much higher than those quoted from the Buildings of Excellence program but the comments I submitted document that they are from the Draft Scoping Plan so it is incumbent on NYSERDA to explain the discrepancies.

A couple of assemblymen asked about grid upgrades and got another non-responsive reply. I recently submitted comments on the costs for residential electric service upgrades, electric distribution improvements when everyone is all-electric, and an estimate of the costs for de-commissioning gas service. The following table presents those numbers which are not based on the Draft Scoping Plan. Presumably, somewhere, someplace similar numbers have been developed but I have not been able to find them. The unit cost ranges for a single-family home is another $3,850 to $9,500.

In addition to the individual homeowner costs, I made a first-order approximation estimate of total costs for residential heating upgrades to all-electric. Using the Integration Analysis device costs described earlier I estimate the additional cost to electrify home heating and upgrade the building envelopes to the basic and deep shell standards will add $28 billion to new building housing costs between 2023 and 2050. Depending on the assumptions used for air-source vs. ground source heat pumps and basic building shell vs. deep building shell I project retrofit costs between $240 and $330 billion. Throw in $30 billion for electric service upgrades, distribution network modifications and residential natural gas disconnections the total residential heating upgrades to all-electric approach at least $300 billion. This does not include costs for other electric appliances, EV chargers, and all the other things necessary for an all-electric house.

Discussion

In my opinion the fact that the Co-Chair of the Climate Action Council did not provide the Draft Scoping Plan projections was an oversight. On the other hand, it could be indicative of a deeper problem. The Climate Action Council draft scoping plan is required to provide “The costs of implementing proposed emissions reduction measures, and the emissions reductions that the council anticipates achieving through these measures” in § 75-0103 (14) (b) (ii). In order to fulfill that mandate, I believe there should be a summary chapter in the Draft Scoping Plan that describes all the control measures, provides references for the assumptions used, lists the expected costs for those measures and lists the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios. I don’t believe that the Integration Analysis developers have provided these numbers to anyone. If this information was available then legislators would have ready access to the information that both parties requested but did not get at the hearing. Given the extreme reticence to provide specific numbers and the shenanigans I have uncovered related to the few numbers provided, I worry that this obfuscation is deliberate. I believe that the Legislature should be demanding this information be included in the Final Scoping Plan.

I want to make one other point. I have spent a lot of time evaluating the Climate Act Draft Scoping Plan and recently noticed something that is inconsistent with the NYSERDA story that everything is wonderful about heat pumps. According to the Integration Analysis modeling, sales of heat pump for the Reference Case grows to 4% of total sales by 2025 but stays the same until 2050 in the Reference Case Space Heating-Res table. If heat pumps are as good as NYSERDA claims then shouldn’t the rate of adoption be higher in the business-as- usual case? The fact that the NYSERDA claims no increased rate of heat pump sales either means that the modeling is wrong or that these heat pumps are not expected to be purchased by homeowners who make decisions based on economics.

Conclusion

Co-Chair Harris testimony was more about NYSERDA than providing useful testimony for the Assembly. There were many instances of statements that basically said trust us we have this under control but provided nothing to support those claims. She should have been able to tell the Hearing attendees the device costs in the Draft Scoping Plan and the explained just what is needed for the building shells. The lack of detailed cost measure information is a major flaw in the Draft Scoping Plan.

Climate Act Public Meeting in Syracuse

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. As part of their responsibilities the Council was required to hold public hearings as I described in March. This post describes my impression of the Syracuse Public Hearing.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented. 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 establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. The integration analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Public Hearings

The last of 11 public hearing was on May 12, 2022. Nine of the hearings were held in person across the state and there were two virtual meetings. I am aware of a couple of hearing summaries that also described impressions of the meetings.

Climate Action Council member Peter Iwanowicz attended every one of the meetings that I checked out. At 2:41:54 on the video (use the double arrow option to move to that point in the recording) of the All-Electric Building legislation hearing he gave testimony for the proposed legislation that included a summary of the hearings he attended. He said that the number of people who supported the Draft Scoping Plan “far outweigh” those speaking in opposition. For most of the meetings he said that it is typical that two thirds of the speakers support it. At the last virtual hearing 83% supported it.

Francis Menton writing at the Manhattan Contrarian wrote a couple of articles about his experiences at the Brooklyn public hearing. In his first article he described position of the commenters he heard speak:

A summary of the 60 or so comments before me will give you readers an idea of what we are up against. Of the 60, exactly 4 were not fully on board with the crash program to replace all fossil fuels in New York with some combination of wind and solar “renewables,” storage, and/or the magical not-yet-invented “DEFR” (Dispatchable Emissions Free Resource) often mentioned in the Scoping Plan. The four who were not fully on board consisted of two advocates for nuclear power (note that New York just closed its last downstate nuclear plant last year, well before the end of its useful life — so nuclear is clearly going nowhere), plus one representative of each of the two large utilities, Con Edison and National Grid. In the case of the utilities, the message was, of course we’re on board, but we’ll just have to work together, and maybe you might need to go a little slower and maybe allow for some so-called “green” hydrogen in the mix, or something.

I managed to sit through the entire Syracuse Public Hearing so I can give my impression of the commenters (video recording) there. Like Mr. Menton, I kept score on the positions of the speakers. My notes indicate that there were 79 speakers but I am not going to sit through the recording to check my numbers. Overall, three quarters supported the Climate Act.

I broke down the speakers as follows. Twelve were opposed and eight were opposed because they supported nuclear power. I count the eight nuclear supporters as “agenda-driven”. In other words, their comment was driven not directly because they oppose the Climate Act but because they have caught on that there are loud voices on the Climate Action Council that oppose nuclear power. I counted 26 in support of the Climate Act and another 17 supporters that supported it because they had an agenda that appeared to me to be the primary motive for supporting the net-zero transition. I was kind of surprised that only four crony capitalists showed up to encourage the state to fill their trough with more slop.

The Syracuse public hearing was held at the School of Environmental Science and Forestry so I expected that there would be a large number of students. There were only 12 and most of those came from a class at Cornell University associated with the Climate Change Minor. Apparently, the assignment for the class was to read a section of the Draft Scoping Plan and provide a comment. Everyone picked up on an inconsistency or other problem with the section they reviewed. It was a useful exercise for the students but I would put their class right up alongside my son’s courses in wine appreciation for future career applicability.

Speaker Themes

Menton also described the common themes of the supporters which I believe capture the beliefs of the supporters at the Syracuse hearing too:

The overriding message was an emotional plea to the Climate Council to please, please save us from these evil fossil fuels before it is too late for ourselves and our children and our planet. Several used the opening line, “I’m here today because I’m scared.” Multiple speakers choked back tears. Easily 20 speakers invoked Hurricanes Sandy (2012) and Ida (2021), as if reducing usage of natural gas could somehow end the risk of severe storms. An overlapping group of at least 20 went on about the increasing incidence of childhood asthma, as if atmospheric CO2 has something to do with that. Another overlapping group of at least 20 asserted that climate change was differentially harming what they called “justice communities” (when did that term come into vogue?); and therefore “justice demands” the elimination of fossil fuels. One lady focused specifically on the increasing rate of teen suicide, which she asserted was entirely attributable to fossil-fuel-induced climate change.

In his second post on the public meeting he described the drivers for those themes. As shown above fear was a driver. In the second post he explained that another emotional driver was anger that was also present at the Syracuse hearing. He explained that:

The anger is directed at the fossil fuel producers and distributors who the commenters, with near unanimity, seemed to believe were hell-bent on destroying the planet. A substantial majority of the 60 or so comments that I listened to expressed this anger in one form or another, and it was an implicit undercurrent in most of the rest.

He went on to explain that this anger with fossil fuels is despite that all of these peoples use them.

They use fossil-fuel-burning cars and furnaces and stoves because those vehicles and appliances are cheaper and/or work better than the alternatives. And yet, somehow these people have convinced themselves that they have no responsibility at all, and the use of gasoline and natural gas by them and others is a fault of evil producers and utilities.

Reflections

Climate Action Council member Peter Iwanowicz is the Executive Director of Environmental Advocates of New York. There are a couple of applicable points to be made about his complete video testimony for the all-electric buildings act. Organizations like his have turned the New York comment process into a charade because the political hacks that run the agencies use the number of supporting comments as an indication of how their preferred political base at the moment will vote so those numbers matter. Environmental NGOs are very good at getting out those numbers so his argument that most people support the Climate Act just reflects that reality. Iwanowicz mentions that the gas and oil PR campaign against the Climate Act seems to be “inspiring people” who have electrified their homes with limited incentives to come out and make comments at the meetings. He emotionally states “They come to share the true cost of electrification” and implies that those speakers represent reality. I have no doubt whatsoever that the environmental organizations put out a call to their minions to find people who have electrified their homes to ask them to testify. However, think about that subset of the population. In the first place you have to have disposable income to spend on the electric alternatives. To this point NYS subsidies have been for more efficient equipment and you can spend less on a furnace upgrade rather than a conversion. You have to have excess disposable income to pick the more expensive alternative. I also believe that many of those who have gone electric are signaling their virtue. I don’t think the inspired people represent most New Yorkers.

Menton and I agree that emotional anecdotes are a primary rationale for most of the speakers who voiced support for the Climate Act at the public hearings. The Iwanowicz testimony relies on emotional anecdotes because it is a very effective approach. Given the large number of people who turned out to support the Draft Scoping Plan, it appears to be working. The ultimate problem is that reality often conflicts with the dreams. For just one example, consider the magical not-yet-invented “DEFR” (Dispatchable Emissions Free Resource) mentioned by Menton. In the most recent New York Independent System Operator (NYISO) projections for the future, the power capacity for this not-yet-invented technology is projected to be approximately equal the total of today’s entire generation capacity. In addition, the projections for power capacity indicate an enormous amount of generation is also needed. Experts called that result “stunning” and asked whether anyone on the Council is looking at what this means. I believe that the number of people who provided comments supporting the Climate Act at all the public hearings and actually understand what the NYISO projections mean could be counted on one hand.

I ran into a colleague from long-ago at the hearing. His testimony at 3:22:15 of the video recording is worthwhile for two reasons. He made his point in a very effective and unique way and the energy transition point he made is very important. In particular, Gary Schoonmaker argued that the proposed energy transition to net-zero is very different than past transitions. He persuasively argued that in the past the transitions occurred because they were advantageous and cheaper so people wanted to do it. However, the net-zero transition has disadvantages and will be more expensive so now the government is going to have to force compliance. Gary and I agree that it is very unlikely that this will end well.

Conclusion

In my opinion, the Climate Action Council is going through the motions of the public comment process. I have no doubt that the final tally will show more support than opposition. That clearly will be used by supporters to say that we should proceed. The real question is whether anything will change in the final scoping plan.

There is a major flaw in the energy policy by popularity approach. Physics. The fact is that there are physical and technological constraints for an electric grid system that is dependent upon wind and solar generation needed for the Draft Scoping Plan transition. The Climate Action Council and the Advisory Panel membership included very few people who had the relevant education and background to understand those constraints. Consequently, the Council approved a Draft Scoping Plan that does not adequately address the risks and uncertainties of the proposed zero-emissions electric grid by 2040 target.

The ultimate question for the comment response is whether the minority comments that rely on physics to argue for changes to maintain current affordability and reliability standards will be considered. The environmental advocacy community is well-organized and can turn up the volume and quantity of comments at will. Is someone in the current Administration going to have the courage to step up and take the tremendous heat from the environmental advocates when they don’t get their way. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. That is exactly what we will be doing if the Council does not listen to the minority comments from the experts.

For what it is worth I described my comments in an earlier post. My high school speech teacher would be horrified to see how poorly I made my points at 43:50 in the video recording. I blame the two minute limit.