Author: rogercaiazza

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  This post highlights some of the aspects of the enabling strategies needed to meet the targets that I believe the general public does not know is headed their way.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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.

According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration for the Scoping Plan that will be used to achieve the necessary greenhouse gas (GHG) emissions reductions economy-wide.  Advisory panels were created to develop recommendations for the Scoping Plan and made presentations at the April 12, 2021 Meeting and the May 10, 2021 Meeting and recordings of the presentations are available.  I provide links to all those recommendations and my posts describing them here.  The following summarizes what has been suggested.

In the past month or so the same politicians who managed to foist the CLCPA upon the citizens of New York advocated for the Climate and Community Investment Act (CCIA) which was intended to provide funding to support the CLCPA implementation efforts.  I wrote several posts on the legislation and talked to my local assemblyman’s office about my concerns.  In that conversation a WHAM report that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon was mentioned as the main reason the assemblyman was not supporting the legislation.

The costs for the enabling strategies are not known but it will be expensive so this is going to prove very unpopular based on the response to the CCIA.  The Transportation Advisory Panel proposed a strategy to transition to 100% zero-emission light duty vehicle sales which I believe mandate that all light-duty vehicles sold starting in 2035 have to be electric.   The panel claims that by 2028 electric vehicles (EVs) will be comparable in cost to an internal combustion engine.  Of course, all the infrastructure to support EVs in public ($1 billion to the utilities so far) will have to be covered, homeowners who purchase the vehicles will have to purchase at home charging support, and when every home has an EV the local electrical distribution systems will have to be upgraded as I discussed in my comments on the transportation panel strategies.

The energy efficiency and housing advisory panel sector emissions were the highest of any sector.  As a result, the primary mitigation strategy is to phase out fossil fuel use in buildings.  A primary enabling strategy is to change codes and standards as shown in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require a plethora of specific requirements including solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025.  Note that a homeowner that chooses to an addition or alteration could be covered by the same requirements.    In 2030, gas/oil replacements will be prohibited when heating and hot water systems have to be replaced in homes and in 2035 electric stoves and driers are mandated replacements.  I expect that there is a requirement that when a house is sold after 2030 that it will have to be all-electric.  If you prefer to use natural gas for home heating, hot water, and cooking you will not have that choice.

The presentation notes that “Resilience is of critical importance”. There is a major disconnect between the advisory panel and the public in this regard.  For the public, a slogan does not keep the house warm.  In the event of extreme weather such as an ice storm many people had experience surviving because of fossil fuel options.  I doubt the public will willingly give up the resilient capabilities of natural gas and fuel oil for heating.  I described these issues in more detail in this post.

The Land Use & Local Government Advisory Panel proposed a theme facilitating “responsible siting and adoption of clean energy sources” apparently oblivious to the fact that clean energy siting requires much more land than available at any of the priority development areas simply because wind and solar energy are diffuse and require large areas to collect it.  The Agriculture and Forestry Advisory Panel proposed enabling strategies to avoid forest conversion and avoid agricultural land conversion because of the role of forests and farmlands in sequestering carbon. There is no recognition or plan to address the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last state impact statement that evaluated wind energy cumulative impacts.  Note that there are less than 2,000 MW of wind turbines today.  Responsible siting, minimizing conversion of sequestration land, and reducing cumulative impacts of thousands of turbines while developing the thousands of wind turbines is a significant challenge.

The waste advisory panel recommendations illustrate one overarching problem with these panels.  In light of the critical need for firm, zero-emissions resources and the fact that the methane emissions from municipal solid waste landfills, digesters at water resource recovery facilities, livestock farms, food production facilities and organic waste management operations are a major percentage of the total emissions, it only seems logical to address both problems by collecting and using that gas.  However, as I showed in my analysis of the waste strategies, there are passionate ideologues involved that don’t agree.  The meeting minutes note “concern regarding renewable natural gas, suggesting that there is a limited opportunity for it to contribute to Climate Act goals and believes that efforts in this area benefit the source without contributing additional environmental benefits”. Another member “expressed his concerns about how to move ahead with biogas if it is combusted as this would clearly increase net co-pollutants locally, and suggested the Council consider applications for biogas that would not be combusted (such as fuel cell technology at wastewater treatment plants)”.  

The Energy-Intensive and Trade-Exposed Industries Advisory Panel illustrates a less-than flattering aspect of the CLCPA.  The strategies for the small and declining industrial, mining, and manufacturing sector were described as “heterogeneous”.  This means that there are many different sources so economy of scale is not going to reduce costs.  Clearly New York’s unilateral transition off fossil fuels will increase relative energy costs relative to other jurisdictions and industries will have to leave to survive.  They conclude that this sector needs currently unavailable solutions to produce emission reductions and remain viable within the state.  It seems pretty obvious that this advisory panel was included as a political ploy to placate the industrial sector.  Unfortunately, there is not much that can be done to reduce emissions significantly or prevent the remaining industries from fleeing the state out of necessity.

The Power Generation advisory panel is arguably the most important because in order to meet the targets all the other sectors will have to be electrified. The recommendations are available in a slide presentation.  I did a review of final recommendations, and, because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations.  At the start of the process, I also posted on the membership of this panel.  The Albany politicians who nominated the members of the panel chose people whose ideological agendas are aligned with the CLCPA presumption that the transition away from fossil fuels is simply a matter of political will.  As a result, they included enabling strategies for the process of, for example, developing off-shore wind, but the related strategy did not include costs for actually developing offshore wind facilities or offer enabling strategies for it.

The ultimate problem replacing fossil fuels with renewable wind and solar energy is providing power during periods when both renewable resources are near zero.  In their presentation to the Power Generation Advisory Panel on September 16, 2020, E3 included the following slide that notes that illustrates the winter doldrum issue.  Incredibly, the panel recommendations did not specifically address this issue. 

Conclusion

This post highlights some of the aspects of the enabling strategies needed to meet the CLCPA emission reduction targets that I believe the general public does not know are headed their way.  Given the constant harping from politicians and the media about the existential threat of climate change many might believe implementing this law is appropriate.  However, the question is just how much is the public willing to pay and how many limitations on personal choice will they accept?

All these recommendations will be incorporated into the integration analysis modeling effort by the State.  Technical staff at the agencies will develop the scoping plan that outlines what is needed to meet the law’s requirements and maintain reliability.  The scoping plan goes to the Climate Action Council for review and comment and the public even gets a chance to respond.  Once the scoping plan is accepted State agencies will implement codes and regulations.  The proponents of the CLCPA are convinced that they have broad public support for these changes in personal choice and the inevitable higher prices.

This year’s CCIA legislation was intended to cover CLCPA implementation costs and the thought that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon apparently was too much to bear.  Those costs are a fraction of the CLCPA costs.  The proposed enabling strategy for residential home heating mandates that all new homes built after 2025 be all-electric and that when fossil appliances have to be replaced after 2030 that they be replaced by electric alternatives that the public will have to cover.  All new light-duty vehicles sold in 2035 will be electric.  In order to transition the electric grid Kevin Kilty points out “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.”  New Yorkers need to wake up and ask for the costs of this legislation sooner rather than later.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Power Generation Advisory Panel enabling strategy recommendations, including my impressions of the panel presentation itself.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.

Power Generation Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  A constant theme with this panel compared to others is a lack of critical information for stakeholders trying to understand their recommendations.  The ultimate reason for the recommendations is for emission reductions and this presentation does not provide all the numbers whereas most of the presentations included the values for each year.

The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph I estimate that the 1990 emissions are 100 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 60 MMt. 

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050.   The slide provides the percentage reductions so that the emissions can be estimated.  The projected total reductions emission reduction goals for this advisory panel are a 71% reduction from 1990 by 2030 and a reduction of 95% by 2050.  However, the power generation sector has its own goals: 70% renewable energy by 2030 and 100% carbon-free electricity by 2040.  No documentation is provided to substantiate the claim that 70% renewable energy is equivalent a 50% reduction from the 2018 levels.

The power generation sector was the third largest source of greenhouse gas (GHG) emissions in 2018.  Direct combustion emissions accounted for 57% of the total, imported fossil fuel 28%, oil and gas methane leakage 15%.  The inclusion of emissions by imported fossil fuels and leakage is mandated by law, ECL § 75-0101(13). These two categories represent an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption.  However, these sectors are not included in internationally accepted emission inventory procedures.  I am working on a post that addresses this issue specifically.

 Power Generation Strategies

According to the meeting presentation, the advisory panel proposed fourteen enabling strategies:

1             Growth of Large-Scale Renewable Energy Generation

2             Clean Energy Siting & Community Acceptance

3             Distributed Generation / Distributed Energy Resources

4             Existing Storage Technology

5             Demand Side

6             Reliability for the future grid

7             Access and Affordability for All

8             Workforce Development

9             Market Solutions

10           Technology Solutions

11           Long Duration Storage Technology

12           Energy Delivery & Hosting Capacity

13           Gas Infrastructure, Transmission & Methane Leakage

14           Retirement of Fossil Fuel-Fired Facilities

The recommendations are available in a slide presentation.  I am not going to critique each of these strategies individually because it would take far too long.  Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues.  Because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations.  I will also compare the proposed strategies to the draft strategies.

In September 2020 I also posted on the membership of this panel.  That post describes how this process was supposed to work.  I also described the background of the panel members.  I noted the members were mostly aligned with the ideological agenda of the Cuomo Administration rather than maintaining an affordable and reliable power generation system.  Sadly, the events of the last six months or so exceeded my expectations.  In order to make power generation recommendations it is necessary to understand how the power system works and how planning affects reliability and affordability.  Many of the members did not want to understand and did not try to understand the technological challenges.  Unfortunately, they were the loudest voices and their naïve insistence on speculative technologies has resulted in some risky enabling initiatives.

Discussion

One of the good things that this presentation did include were the category definitions.  Each mitigation strategy describes the potential effect of the strategy on GHG reductions by 2030, cost and funding expectations, and ease of implementation in three categories: low, medium and high.  The following tables define what they mean by low, medium and high.  This panel and the Energy Efficiency & Housing panel were the only ones to include these definitions and I note that there are subtle differences between them.  For example, the Power Generation panel defines the low mitigation strategy cost as <$250M total resource cost and most resources required for successful implementation are already on hand.  The other panel uses the same definitions but expresses the value as “equivalent annualized cost”.

I appreciate the inclusion of these definitions.  However, I don’t think some of the category definitions for the enabling initiatives are correct.  In particular, Initiative #1, Growth of Large-Scale Renewable Energy Generation states that the cost and funding considerations are $, <$250 million total resource cost for NYSERDA’s existing Tier 1, Tier 4, and offshore wind programs.  The only way those estimates can be correct is if they are referring only to the process for growing large-scale renewable generation.

The New York State Energy Research & Development Authority (NYSERDA) offshore wind website notes that the State’s five currently planned offshore wind projects total 4,300 MW.   The US Energy Information Administration (EIA) regularly assesses the levelized costs of all power sources, and only a year ago calculated that the cost of offshore wind was $115.04/MWh.  EIA claims a capacity factor of 45% which means that the 4,300 MW will generate 16,950,600 MWh.  Using the EIA levelized cost of electricity, see below, with that amount of generation yields $1.9 billion for the 4,300 MW of offshore wind.  Something else to keep in mind is that this projection does not include costs on the wholesale market, capacity market, or impacts on balancing and ancillary service markets which all add to the cost.  The biggest concern is providing power when the wind is not blowing.  It is hard to imagine how the authors of this slide managed to estimate that these costs would be less than $250 million unless they were only talking the process.  Then the question becomes where the heck do these costs show up in the recommendations.

Reliability

In general, the greatest threat to grid reliability is the transition away from fossil-fired power plants that provide dispatchable electricity whenever needed to intermittent and diffuse generation from wind and solar.  Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems associated with this transition.  In this post I am only going to address two CLCPA aspects.

The final recommendations to the Climate Action Council at least emphasized the need to maintain reliability.  Incredibly, the first presentation from the Climate Action Council on the advisory panels did not mention reliability.  There are extensive electric system reliability requirements in place and despite numerous requests, no presentation on New York’s requirements was provided to this panel. 

Moreover, enabling initiative #6, reliability for the future grid, misses the point.  As shown in the following description the cost and ease of implementation refer to the process for maintaining reliability, not the difficulty of making the changes needed to make the system reliable.  For example, in August 2019 there was a blackout in England.  Initially triggered by a lightning strike followed by “Two almost simultaneous unexpected power losses” from an offshore wind farm and a gas-fired power plant resulted in a “cumulative level of power loss greater than the level required to be secured by the Security Standards” and the blackout ensued.  My point is that as the system transitions to renewables I expect this kind of trial and error de-bugging of the system reliant on intermittent renewable energy.  For example, the North Park Solar proposal calls for a facility with up to 450 MW of solar panels covering 2500 acres.  What happens on a partly cloudy day when the incident solar radiation varies wildly?  Could that trigger an unexpected power loss? 

A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support services.  Earlier this year I wrote that no one seemed to want to take the responsibility to figure out was is needed to provide that support. 

Enabling initiative #9, Market solutions, is the only place in the recommendations where ancillary services is mentioned.  Similar to the problem for the reliability initiative, this recommendation discusses the market mechanisms rather than the problem itself.  The responsibility for the initiative is on the New York Independent System Operator (NYISO).  The barriers to success note that this “Will require several forward-looking market designs and the implementation of each design must be structured in a way that sends the correct price signal at the appropriate time”.  This panel unloads all the responsibilities onto the NYISO. Not only do they have to anticipate all the potential issues in an unprecedented system reliant on asynchronous generation but also have to create a market mechanism to get market participants to invest in that technology.  This is another trial-and-error exercise where the rate-payers of the state are lab rats.

Feasibility

I have always maintained that the fundamental flaw of the CLCPA is that it assumed it was only a matter of political will to completely transform the existing electrical system to one dependent upon renewable energy.  Clearly, it would be appropriate to define affordability and reliability metrics then do a comprehensive analysis to determine if the transition would threaten those metrics.  The following tables list the ease of implementation descriptions for all 14 enabling strategies.

There are three easy to implement strategies: Reliability for the future grid, Workforce Development, and Gas Infrastructure, Transmission & Methane Leakage. These strategies are supposed to have been implemented many times and/or can build off an existing NYS program, rely on Proven and widely available technology, and the key stakeholders are strong supporters, there were no strong opponents.  However, recall that the reliability strategy was more about the mechanics of assessing reliability than actually addressing the problem.  It is ludicrous for this panel to claim reliability for a wind and solar dependent electric generation system will be “easy”.

Most of the strategies had a medium ease of implementation defined as: strategy is new to New York State but has been successfully implemented in other comparable states/countries, proven technology with known GHG impact, but still small-scale, and key stakeholders are neutral, or balanced mix of supporters and opponents.  I think the biases of the panel members and their lack of technical backgrounds impact these ease of implementation estimates.  Consider the medium label for existing storage technology.  Despite all the fawning reports over Tesla’s utility-scale batteries, the press and this panel has not picked up on how they are being used.  The Australian Hornsdale Power Reserve battery system is making money for the operators and saving consumers money by providing frequency control ancillary support services.  It is not being used to provide meaningful energy storage for the system.  As a result I argue that claiming that utility-scale energy storage has been successfully implemented is dubious at best.

There are three initiatives that even this panel had to conclude would be hard to implement: long duration storage technology, energy delivery & hosting capacity, and retirement of fossil fuel-fired facilities.  I believe that both existing and long duration energy storage technologies should be difficult.  A recent article by Kevin Kilty “Why is Energy so Difficult to Store? Why is Stored Energy so Difficult to Use?” described the generic problems with energy storage systems. He concluded that “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.”  Long-duration storage is necessary so depending upon a technology that does not even exist in a pilot project is an incredible risk.

Energy delivery & hosting capacity refers to “planning and implementation processes to facilitate necessary energy delivery options for the renewable energy buildout”.  Like all the other strategies by this panel it is presumed that there are no technical challenges to accomplish this.  In fact, this reads like a wish list for the renewable energy developers on the panel. 

Retirement of fossil fuel-fired facilities engendered a non-consensus recommendation with majority support: “temporary moratorium on new or repowered fossil fuel-fired facilities until the full recommendation is adopted”.  The strategy description is to develop a plan and implement regulations to phase out fossil fuel-fired baseload and peaking generation resources as quickly as practicable while retaining system reliability by prioritizing efforts to lower emissions of co-pollutants in disadvantaged and environmental justice communities.   The current cause célèbre amongst environmental justice activists are power plants in disadvantaged communities because they just have to be causing health problems due to ozone and inhalable particulates.  The problem is that those are both secondary pollutants and form long after the precursor pollutants are emitted so any health effects are not due to neighborhood power plants.  The mitigating solution to this non-problem: “The recommendations from the Power Generation Advisory Panel focus on enabling strategies to assist in the transition away from fossil fuels. These include strategies to more rapidly deploy renewable technologies, including flexible resources, addressing barriers to renewables deployment, transmission and distribution upgrades, developing and deploying technology innovations, encouraging effective market structures, and ensuring a just and equitable transition.”  As near as I can interpret this, there is absolutely no inkling that there might be technological and physical barriers that could preclude any of these enabling strategies.

Affordability

The panel covers affordability with its own enabling initiative.  I find it rich that the panel presumes that Federal Relief Funds should be used first.  The problem is that similar efforts elsewhere have markedly increased costs.  According to Germany’s Enegiewende program, the share of renewables in electricity generation should reach 45 percent by 2030 and 100% by half century.  The costs have sky rocketed and now German electricity prices are three times higher than France.  The Global Warming Policy Foundation has analyzed the cost of Great Britain’s net-zero programs concluding that astronomical cost burden risks are becoming a “toxic issue” for the government. If CLCPA proponents could point to a single jurisdiction with high renewable energy use that did not experience a marked increase in costs, then I would not believe this is an insurmountable problem.

Conclusion

Two things about this advisory panel.  It is arguably the most import panel because achieving CLCPA will only be possible if zero-emission electric power is available.  It was inarguably the worst run panel by far.  John Rhodes “leadership“ was abysmal and by the time he retired the damage had been done.  A leader would have steered discussions to achievable solutions that could maintain current levels of reliability and affordability.  What happened is that the loudest voices in the room drove the recommendations and discussions. As David Zaruk, who writes at the Risk Monger blog, explains those voices are: “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”.  Rather than trying to understand the technological challenges these idealogues made recommendations for processes that would enable what they believe only requires political will.  “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.”– Thomas Sowell

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Energy Efficiency & Housing Advisory Panel enabling strategy recommendations.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Energy Efficiency & Housing Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph 1990 emissions are 103 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 115 MMt. 

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050.   The projected total reductions emission reduction goals for this advisory panel don’t meet either target only projecting a 27% reduction from 1990 by 2030 and a reduction of 83% by 2050. 

This sector was the largest source of greenhouse gas (GHG) emissions in 2018 but there are two caveats.  The New York emission inventory includes upstream GHG emissions and the emission rates for methane are high so over half the emissions relative to combustion come from imported fossil fuels.  In a rational world that observation would suggest an analysis to see why such an illogical outcome is observed but in the CLCPA it is a feature not a possible flaw.  The other factor is that refrigerants are a large component of the total because the global warming potential for HFC is high. 

Energy Efficiency & Housing Strategies

According to the meeting presentation, the advisory panel proposed the following four mitigating strategies and six enabling strategies:

• Mitigation strategy 1: Phase out fossil fuel use in buildings
• Mitigation strategy 2: Require benchmarking
• Mitigation strategy 3: Shift reliance on fossil gas to clean energy system
• Mitigation strategy 4: Shift reliance on HFC use as refrigerant and in all products used in construction
• Enabling strategy 1: Public financial incentives
• Enabling strategy 2: Public and private low-cost financing
• Enabling strategy 3: Workforce
• Enabling strategy 4: Consumer education
• Enabling strategy 5: Innovation
• Enabling strategy 6: Embodied carbon

The recommendations themselves are available in a slide presentation.  I am not going to critique all these strategies because it would take far too long.  Instead, I will comment on some of the strategies with an emphasis on inconsistencies and implementation issues. 

There is no question that meeting the CLCPA goals for this sector will be a challenge.  The presentation explains that there are 6.2 million buildings in New York State: 4.9m single family homes, 250k multifamily buildings, and 370k commercial/institutional buildings.  The first mitigation strategy is to phase out fossil fuel use in buildings.  Obviously “Eliminating GHG emissions from New York’s building stock by 2050 will require broad, systemic changes”.

The Energy Efficiency and Housing presentation to the Climate Action Council presentation summarizes the first initiative to modify building codes and standards in this strategy in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025 and for multifamily and commercial buildings by 2030. The presentation notes that by 2030, more than 200,000 homes per year will be upgraded to all-electric and energy efficient standards.

I suspect most people are like me and don’t understand what some of these terms mean and how it will affect my personal choices if I want to buy a new house or remodel my existing house in 2025. Solar panels will be required where “feasible” but feasibility is not defined.  Electric readiness means “The installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of electric equipment for space heating and cooling, hot-water, cooking, and laundry”.  This initiative proposes to prohibit (“at end of useful life”) gas or oil replacements of “heating, cooling and domestic hot water equipment” in single family homes by 2030 so it makes sense to install the electric infrastructure sooner.  Electric vehicle readiness is defined as the “installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of EV chargers”.  The transportation advisory panel has proposed that all new vehicles sold by 2030 will be electric vehicles so this is another consistent requirement. 

I was surprised that there was a requirement for energy storage readiness: “The installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of electric batteries”.  The biggest problem with solar energy is its intermittency and the advisory panel is proposing that homeowners help provide a solution by providing space for the batteries and footing the bill for the electrical service.  I suspect there will eventually be a requirement to install the batteries themselves but not to worry because the panel suggests that this will pay for itself by providing revenues.   The most intrusive aspect of this proposal is the requirement for grid-interactive electrical appliances “as feasible (e.g., batteries, hot water heaters)”.  For batteries the ability of the grid operator to call up your stored energy when needed makes sense but I am not comfortable having someone else decide when I can have hot water.  Moreover, heating and cooling appliances surely will eventually be grid-interactive too.  Proponents point out that capability would have helped reduce the impacts of the Texas February 2021 blackouts but cynics like me argue that the existing system does not need that capability because fossil fuels work better.

The presentation to the Climate Action Council notes that “Electrification of heating and hot water systems in nearly all buildings is a key strategy for building decarbonization and depends upon energy efficiency improvements in all buildings and 100% zero-emissions electricity by 2040 under the Climate Act”.  The second mitigation strategy sets benchmarking standards for building energy use.  New York State has a long history of support for energy efficiency.  I have long argued that the fatal flaw of the CLCPA is that it presumes that the targets are achievable despite the lack of a feasibility study to determine whether achieving the targets would adversely affect affordability and reliability.  In that context the question is where does the state stand vis-à-vis the energy efficiency needed for all-electric heating systems.  While converting to heat pumps is an overall energy use improvement, direct combustion on-site is more efficient actually warming homes because it provides hotter air.  The only way to be comfortable using heat pumps is to have an extremely well insulated building.

Also included in this initiative is another buried cost.  In particular, there are energy use disclosure requirements:

• Starting in 2025-Require owners of all residential and commercial buildings to obtain and publicly disclose, as part of sale or lease listing of a building, housing unit, or commercial space, the prior-year energy consumption of the building, unit, or space (e.g., at least 12 consecutive months of energy bill data).
• Starting in 2027–Require owners of single-family buildings to obtain and disclose an energy performance rating (e.g., a Home Energy Rating System (HERS) index) as part of sale listing.

The cost of these requirements will be borne by the owners.

The third mitigation strategy initiative is entitled “Gas System Transition”.  I believe it is included because the advisory panel knows that weaning the public off natural gas will be a challenge because of its advantages.  This difficulty is illustrated in the following slide listing the components required for delivery.  The first component states “Stop utilities advertising fossil gas as “clean,” “natural,” “climate friendly,” or in similar terms”.  The problem with not calling it natural gas of course is that it is called natural gas because it is a naturally occurring gas.  Wherever a geologic formation that contains natural gas is exposed to the air, natural gas can be released to the atmosphere.  For example, western New York’s Eternal Flame Falls has a vent that seeps natural gas, and someone, sometime lit it off.  Does this panel propose to change the signage there too?

The panel recommends six enabling strategies as shown in the enabling strategy summary slide below.  All but one are financial actions and two address only financial incentives and low-cost financing.  While the panel apparently realizes that cost is a major issue for this conversion, it is not clear whether they understand that general support for environmental issues evaporates when the personal impacts to costs and individual choices are explained.  This is illustrated by recent events in Great Britain where the implementation process for a similar net-zero target is further advanced than in New York.  When the government threatened to ban gas boilers in existing homes by 2035 and to fine homeowners if they met that deadline, the blowback was immediate.  Within hours the government backtracked and said there wouldn’t be any fines.  It will be interesting to see what happens now that the curtain has been pulled aside and the public starts to see all the costs to meet net-zero targets. 

Conclusion

The presentation slides suggest the difficulties facing this sector’s reduction targets:

• Eliminating GHG emissions from New York buildings by 2050 requires broad, systemic changes.
• Behavior and practice change lead to decarbonization
• Equitable transformation at this scale requires new resources.
• Private capital investment focused on highly efficient buildings
• Public incentives for early adoption
• Public investments in building efficiency and electrification in low and middle income homes, affordable and public housing, and disadvantaged communities
• Transformation at this scale and advancement of equity will require mobilizing private capital and a significant increase in public resources.
• The CAC should conduct an economy-wide analysis to identify resources and funding mechanisms to address the Scoping Plan, holistically.
• Advocate for Federal resources and policy support in the scoping plan.
• Continue PSC attention to rate design and retail rates for electricity and gas.
• Resilience is of critical importance. Amend State codes to enhance building-level resilience and grid reliability/resilience.
• Support recommendations of the Adaptation and Resilience group.
• Broad adoption of insulation/weatherization and energy efficiency in homes; increased funding for weatherization and energy efficiency in LMI homes; energy disclosures can inform future policy.

These are all aspirational gambits that on one hand are necessary but on the other hand are no means assured.  The comment stating resilience is of critical importance is a hollow gesture.  Fossil fuels provide more resilience in general and in the event of extreme weather such as an ice storm reliance on electric heat and renewable energy will have fatal consequences.  Importantly, the public gets that and I doubt will not willingly give up the capabilities of natural gas and fuel oil for heating.

One notable aspect of these recommendations is the inclusion of specific components that favor the interests of individual members of the advisory panel.  This is a common problem for all the advisory panels caused by the membership selection process.  For example, the gas system transition includes the following component: “Level the playing field for adoption of clean heating solutions by eliminating the “100-foot rule” which can bias customer decision-making around heating choices. (The 100-foot rule covers most or all of the cost of new gas connections for residential customers and significant costs for new non-residential firm gas customers).”  Given that all the clean heating solutions are directly subsidized and that when everything is electrified the distribution systems will likely have to be upgraded which represents an indirect subsidy, the “level the playing field” argument can only come from a vested interest blinded to the contradictions.

These panel recommendations and the facts that this sector has the highest emissions and the does not meet the projected targets is a problem for the CLCPA.  When I describe the limits on personal choices for energy use and added costs most people don’t accept that this could be possible.  I believe that public backlash will be similar to what has been observed in Great Britain when the implications and costs become readily known.  If the public response forces reconsideration of the enabling initiatives, then it will weaken the potential emission reduction strategies making achievement of the CLCPA targets that much more difficult.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Land Use & Local Government Advisory Panel enabling strategy recommendations.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.

Land Use & Local Government Emissions

This panel did not propose any strategies to reduce emissions. 

Land Use & Local Government Strategies

According to the meeting slide presentation, this panel’s recommendations encompassed the following themes:

• Promote efficient land use and smart growth that reduces vehicles mile traveled
• Maximize natural carbon sequestration potential
• Facilitating responsible siting and adoption of clean energy sources
• Provide local governments the tools and resources to lead on climate
• Commit to environmental justice, disadvantaged communities, and a just transition

After discussing each theme, the advisory panel presentation listed the following key strategies:

• Expand availability of hands-on support and training for municipalities across a range of climate actions with a focus on increased support to small, resource-constrained, and underserved communities.
• Develop a centralized portal that offers resources and information to assist communities in navigating, accessing and integrating state programs relative to sustainable community development and clean energy development.
• Explore options to simplify local government enforcement of evolving building codes such as a statewide permitting system, a tool kit with templates and guidance to assist local building departments, support for implementation of shared services agreements, and third party inspections for the energy code.
• Establish statewide policies that require consistent advancement on building decarbonization by adopting a highly efficient State Energy Code aligned with CLCPA goals as soon as possible, establishing energy benchmarking and performance standards for buildings, and creating innovative public benefit financing mechanisms.

More detail is available in the recommendations and you can listen to the presentation.   Note, however, that the recommendations are not the same as the key strategies and themes.  I will concentrate my comments on the presentation.

The efforts to reduce vehicle miles traveled overlap with the planning strategies from the Transportation Advisory Panel.  Guiding “future growth, redevelopment, and conservation at the multi-municipal scale through regional planning” sounds innocuous but when the planners recommend that all development occur where they want rather than where the public wants it to go, I suspect there will be friction.  I discussed transit-oriented development in my comments on the transportation panel concluding that while it might work outside of New York City elsewhere the development patterns preclude it from working.  In order to make these projects work they want to “empower local governments” by providing support and “align state funding priorities to prioritize smart growth”.  The smart growth illustrated was a “once-contaminated industrial site now being re-purposed to revitalize the Oswego waterfront with housing, retail and commercial space” (Climate Action Council Meeting Presentation May 10,2021).

This is supposed to illustrate a strategy to reduce vehicle miles traveled, but like so many of the enabling strategies it does not work out all the time.  Oswego is a beautiful location for much of the year and the picture shows one of those days.  Unfortunately, that is not true all year round and the following picture from one of my more memorable commutes to Oswego shows they can get clobbered by snow.   During those periods the idea that people would walk or bike to get groceries or go to work is absurd.  Bottom line you still need to have a car but in the best case you just use it less. 

Another theme was to maximize natural carbon sequestration potential.  They only discussed wetland sequestration and “blue carbon” which is carbon captured by ocean and coastal ecosystems.  The agriculture and forestry advisory panel had strategies for carbon sequestration in agricultural soils and forests.  This panel appears to me to cop out.  Wetlands and ocean and coastal ecosystems are already regulated so it is not clear how much additional planning is needed.  On the other hand, there is a looming issue vis-à-vis the space needed for all the solar panels and wind turbines.  Why land use and local government did not address this trade-off is not immediately obvious.

The next theme is facilitating responsible siting and adoption of clean energy sources.  Excuse my cynicism, but this theme appears to be the reason that the aforementioned tradeoff is not addressed in any meaningful way.  My impression of this theme is that it is not especially concerned with local concerns about renewable developments but more getting all the facilities built.  The strategy for guiding future growth states:

Develop criteria and incentives for regional entities and counties to identify priority development areas (including areas appropriate for clean energy siting) and priority conservation areas in consultation with local jurisdictions and communities. Priority Development Areas may include Brownfield Opportunity Areas, downtowns, central businesses districts, municipal centers, hamlets, former industrial districts, infill projects in developed areas, obsolete fossil fuel-based power plants, re-development/adaptive re-use of existing buildings, TOD/Equitable TOD, disadvantaged communities (as defined by the Climate Justice Working Group), dead/dying malls and vacant property clusters designated by land banks, among others. Priority Conservation Areas may include wetlands, riparian areas, forests, agricultural lands and other natural areas and working lands that preserve and restore vital habitats, landscape connectivity, biodiversity, natural water movement, local food security and passive recreation, among others.

This description seems oblivious to the fact that clean energy siting requires much more land than available at any of the priority development areas simply because wind and solar energy are diffuse and require large areas to collect it.  Throw in the incompatibility of wind turbines in developed areas and the result is there will be a conflict between the renewable energy development and the priority conservation areas.  This theme and the Guide Future Growth enabling strategy appear to willfully ignore this issue.

The two last themes are throwaways.  Not surprisingly they think local governments need the tools and resources to lead on climate.  One of the recommendations is for a dashboard “of community greenhouse gas emissions inventories to promote local climate action planning, monitor equity considerations, measure progress, and ensure data consistency at the county/municipality level”.  Years of trying to make numbers simple enough for a dashboard has made me complete distrust the value of such a system – it’s pretty but what is it for?  Finally, they propose to “Commit to environmental justice, disadvantaged communities, and a just transition”.

Conclusion

This panel is a specific requirement of the CLCPA but why?  Land use and local government policies don’t directly affect emissions.  On the other hand, those policies do affect implementation of the enabling strategies envisioned by the authors of the CLCPA.  I suspect that it was included to address the difficulties of permitting power generation facilities and all the other land use strategies necessary to meet the CLCPA targets of a 40% reduction in greenhouse gas emissions from 1990 levels by 2030 and an 85% reduction by 2050.

There is a major inconsistency in the enabling strategies vis-à-vis the agriculture and forestry enabling strategy to minizine the loss of farmlands and forests with their carbon sequestration potential versus the land needed to collect diffuse solar and wind energy necessary to meet the CLCPA targets.  Clearly, the land use and local government advisory panel should have addressed this as a priority.  It is a major flaw that it is mentioned only in passing. 

The other shortcoming and one that is consistent across all the enabling strategies is the recommendation for initiatives that work most of the time.  If you stop and think about it many personal choices incorporate some rare need such as people who buy pickups for the occasional big load.  For this panel the mixed-use development approach to reducing vehicle miles traveled was recommended.  However, there are very few locations where such a development is going to preclude the need for a car.  Residents may be using their cars less but the necessity of having a car minimizes the value of this strategy.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Transportation Advisory Panel enabling strategy recommendations.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.

Transportation Advisory Panel Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph 1990 emissions are 100 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 107 MMt.  Note that as other sectors decrease their emissions the relative percentage of transportation sector emissions to the total increases.

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050.   The projected total reductions emission reduction goals for this advisory panel are a 16% reduction from 1990 by 2030 and a reduction of 77% by 2050. 

Transportation Advisory Panel Strategies

The meeting minutes will not be available until the June Climate Action Panel meeting.  According to the presentation, the advisory panel proposed the following enabling strategies:

• Transition of vehicles/fleets to electric/zero-emission technologies.
• Enhancing the availability, accessibility, reliability and affordability of public transportation.
• Aligning and integrating transportation investments into land use/development to mitigate carbon emissions.
• Implementing market-based strategies to impact travel decisions and finance investments in clean transportation.

The recommendations are available in a slide presentation.  I am not going to critique these strategies individually because it would take far too long.  Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues. 

The Transition to 100% zero-emission light duty vehicle sales enabling strategy exemplifies what I think is a major disconnect between the transportation planners and the public.  I have attended stakeholder meetings for the Transportation Climate Initiative and listened to the true believers explain that there are so many advantages to electric vehicles that if only the public understood everyone would buy into the technology.  However, even this strategy recognizes that “Lack of consumer awareness/interest and consumer concerns about technology & charging/fueling” are barriers to success.  The ultimate problem with all of the clean energy technologies is that they all only work most of the time.  Most of the time a light-duty electric vehicle might work well for me but several times a year I want to haul a big load in my mini-van several hundred miles and range anxiety is a very real concern.  My wife’s car is a regular sedan and again most of the time an electric vehicle would work.  However, several times a year we drive down to see my son’s family in Brooklyn.  The joke is that is takes four hours to get to the George Washington Bridge, another hour to get to Brooklyn and then an hour to park.  I do not foresee any time in the future when that trip will be a realistic option with an electric vehicle.  I am sure my personal reservations are similar to most people.

Another reservation mentioned in enabling solution is the “Potentially high cost of supporting charging and fueling infrastructure and Zero Emission Vehicle incentives”.  Under cost and funding considerations the strategy notes that “Nearly $1 billion in ratepayer and NYPA funding is already committed for EV charging station installations”.  I believe that this $1 billion charge to the ratepayer will be buried in bills so there is no direct accountability to this initiative.  While I do see electric charging stations around town, I don’t see a lot of them so this funding is no where near what is necessary to provide charging support in public spaces.  Moreover, what about the need to charge at home?  While the cost for a simple charger is not that great, a faster charger, which I understand is needed to completely charge a depleted battery, is much more expensive. 

The final reservation mentioned is that “Unmanaged charging could have significant costs for electric grid operators/ratepayers”.   I live in a development that is on the order of 60 years old.  It is very rare that there is a house with only one car and there are many homes with adult children living at home that have more.  The personal charging infrastructure is going to be a challenge and that much additional load, and don’t forget they want to electrify home heating too, is probably going to require upgrades to the local distribution system.    Again, it may work most of the time but when homeowners really need heat are they going to be able to charge their cars too.  Finally, the challenge for charging in a housing subdivision is small relative to charging at apartment buildings and other public spaces and that challenge is small relative to providing chargers for people who have to park on the street in cities.

Ronald Stein recently described California warning signs that agree with some of  my anecdotes about electric vehicles and highlight other issues:

• The highly educated and financially well off are currently the primary owners of EV’s. 
• EV usage being slightly more than 5000 miles a year is a reflection that the EV is a second vehicle and not the family workhorse vehicle.
• The growing percentage of EV owners that are switching back to gasoline cars, is a message that may deflate EV growth projections.
• The larger and heavier gasoline driven SUVs are currently half of all the new car sales.

One of the key components of these plans is anticipated benefits and impacts to disadvantaged communities.  For this mitigation strategy the strategy states:

Enhanced incentives for residents of disadvantaged communities are essential for faster ZEV adoption in disadvantaged communities. Incentives that support used ZEV purchases and EV charging at multifamily buildings can be especially effective at increasing ZEV adoption among underserved populations. Local ownership of EV charging stations and workforce development can support economic opportunities in disadvantaged communities.

I think this is another major disconnect between the members of the advisory panel and reality.  Many people in disadvantaged communities cannot afford a new vehicle whatever the incentive.  Another electric vehicle concern is the market for used cars relative to battery life.  The common perception is that replacing the batteries is a major cost not necessary in a conventional used car.  It is not clear how the CLCPA can subsidize new vehicle purchases, used vehicle purchases, and public EV charging support in disadvantaged communities and keep the option of personal mobility available.

There is another enabling mitigation strategy: “Transition to zero emission medium/heavy duty vehicles and non-road vehicles”.  The summary claims that the ease of implementation and cost is similar for this sector has the same emissions impact, ease of implementation, and cost as for light-duty vehicles.  I disagree with all three comparisons.  Diesel vehicle emissions are a primary cause of inhalable particulates in urban areas so eliminating those emissions has more value than a comparison only to GHG emissions which could be the same for light-duty vehicles and this sector.  Similar ease of implementation is absurd.  There are electric cars that are at least arguably competitive to regular cars.  There isn’t any similar level of technological availability for heavy duty trucks and given the limits of battery technology it is a very heavy lift to assume that a zero-emission technology will ever enable the same use of trucks as today.  If you don’t have the technology, how can you possibly project costs?  Furthermore, charging a fleet of medium or heavy-duty trucks is going to require a lot of energy at freight terminals and service centers so upgrades to the distribution system, likely including new substations, will be required at a significant cost.

From a personal standpoint the transportation initiative does not mention recreational vehicles.  Since my retirement I have traveled over 60,000 miles, visited 40 states and been on the road about 20% of the time with a motor coach.  I don’t see how that life-style will be possible in the net-zero world.  Anyone who has driven I-95 in the winter has noticed a steady stream of campers headed south.  Based on my experience many travel over 300 miles per day which I expect to be the limit of the electronic technology.  The batteries necessary for that operating range will undoubtedly reduce storage space which will not be popular.  Finally, there are very few campgrounds that have any apparent surplus of electricity.  Upgrading campgrounds is another hidden cost.

Improvements to public transportation are a big component of the enabling strategies: 

Identify implementable strategies to significantly enhance the availability; accessibility; reliability; and affordability of public transportation services with an emphasis on unserved/underserved communities.

A major problem with mass transit in all but the largest cities is that it is inconvenient.  Outside of New York City I believe that using public transit basically doubles travel time.  In the early 1900’s there was an extensive interurban trolley system in Upstate New York that basically met the proposed vision for the future.  In Syracuse you could go to Utica, Rochester, and Oswego on those systems.  They all failed by the 1930’s because even though folks had to drive on dirt roads with little heat in the winter and no cooling in the summer it was more convenient than taking a ride on a trolley.  To dream that people will willingly give up that convenience when many have remote car starters is magical thinking.

The enabling strategy becomes even more detached from reality when they include plans for transit-oriented development which is “the creation of compact, walkable, pedestrian-oriented, mixed-use communities centered around high-quality train systems”.  There may be some locations outside of New York City where this might work because high quality train, or rapid transit buses for that matter, can haul commuters to the city where there is a dense network of transit routes available that can take people to a variety of jobs.  Upstate cities have no similar concentration of transit-friendly jobs in the center cities so how can anyone expect that people would want to live in a community that actively discourages ownership and use of a personal vehicle that does not have easy access to work.

Ultimately, the goal of the public transit strategies is to reduce the need for personal automobiles.  There is a fundamental problem though because population density puts limits on transit system success.  If there aren’t enough people living along the transit service then revenues will be insufficient to make them viable.  In order to address there is a strategy to expand biking, walking, carpooling, ride-sharing, and micro-transit opportunities and another for automated vehicles for smart mobility.   The idea is that if there were a convenient option people would be willing to consider transferring from, for example, an express bus to an automated vehicle for locations too far to walk from the main stop.  Transferring between subway lines in New York City is only viable because of the frequency of service.  Scaling that concept down to upstate cities with less dense ridership is unlikely to succeed. 

Of course, the transit systems will have to be converted to zero-emission fleets too.  According to a friend in the business new diesel buses cost ~$500,00, a new compressed natural gas bus costs ~$550,000, and a new electric bus costs ~$1,000,000.  That does not include the cost of infrastructure which, especially for bus electrification, is a significant transition cost.  Furthermore, the enabling initiative suggests making public transit “more attractive, accessible and user-friendly” but adding options to provide those services can run another $60,000 per bus.

Most of the other advisory panels avoided much detail on funding mechanisms and just suggested that some form of government funding would be necessary.  This panel did address potential mechanisms but did not estimate costs.  The strategy for “financing and market-based policies” includes nine potential policies: facilitating private financing, cap & invest or carbon pricing, clean fuel standards, electrification freebates, curb pricing, congestion/variable/demand parking pricing, mileage-based user fees, tax increment financing/special assessment districts, and registration fees.  Note that this spring the Climate and Community Investment Act was proposed to, in large part, provide a funding mechanism for the CLCPA.  However, when asked about the potential to increase gasoline prices by 55 cents per gallon, the Governor Cuomo said: “You can’t do it that way. I understand the concept, and the concept, it makes sense. But how does it work? What’s the economic impact? You’d have to ask all those questions.”   I look forward to the scoping plan’s assessment of CLCPA costs because I don’t believe there is any way that the costs will be as low as 55 cents per gallon for the transportation enabling strategies.  When combined with all the other advisory panel strategies, costs will be extraordinary.

Conclusion

I have three concerns with the transportation enabling strategies: feasibility, affordability and reliability. 

According to preliminary data, the transportation sector was the second largest source of emissions in 2018.  The projected total emission reduction goals for this advisory panel are a 16% reduction from 1990 by 2030 compared to the CLCPA target of 40% and a reduction of 77% by 2050 compared to the goal of 85%.  I can only conclude that the failure to meet these goals means that the CLCPA targets are not feasible particularly because I suspect that the enabling initiatives over-estimate emission reduction effectiveness.

As noted above the costs were not included in the enabling strategies but considering the scope, they are sure to be large.  On May 24 and 25 2021 a European summit met to discuss their net-zero plans and observers expect that that they had to concede that these plans will be very expensive.  I expect the same affordability issues in New York.

The ultimate problem is that the proposed “solutions” only work most of the time and society expects energy options that work all the time.  One of the initiatives proposes to “Expand the availability of low carbon transportation modes (biking, walking, carpooling, ride-sharing, micro-transit) statewide” which is an example of the personal impacts of “it will work most of the time” thinking.  Biking and walking several months of the year is not only inconvenient but also dangerous whenever roads are covered with snow and ice.  Electric vehicles will work when the power is available but what happens when there is an ice storm blackout?  No heat and no way out are a dangerous combination.