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.

Cuomo’s Promise to Free the New York State Fairgrounds of Fossil Fuels

On March 11, 2020 Glenn Coin at the Syracuse Post Standard posted a paywalled article at syracuse.com entitled Governor Cuomo’s big promise to free the state fairgrounds of fossil fuels: What’s the status?  This post addresses the prospects for a fossil-free State Fair.

Background

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have also spent a lot of time evaluating electric load and generation variability.  That background served me well preparing this post.  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.

Mr. Coin did a good job describing the problems involved, but he did not critically evaluate what he was told by the energy experts he interviewed.  On the basis of his interviews he concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective, heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  This post will concentrate on the claim that providing electricity from renewable resources would be “straightforward and effective”.

Coin quoted Chris Carrick, energy program manager for the Central New York Regional Planning and Development Board as saying that “solar is doable”. Carrick, who has overseen solar installations in Central New York, said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Coin pointed out that there would be a problem if the fair installed its own solar power because the electrical use isn’t constant throughout the year. Using monthly data provided by the Fair Data he found that it uses about a third of its annual electricity during the months of August and September.

Coin also interviewed a professor and renewable energy expert at SUNY College of Environmental Science and Forestry, Dr. Neal Abrams. “The fair uses a lot of power, but only for a small amount of time,” Abrams, “Installing solar and/or wind exclusively for the fair doesn’t make sense, but if it is part of a larger state- or utility-owned project, it could.”  Abrams said it might make more sense for the fair to tap into community based solar projects. If the state wanted wind power at the fair, he said, there’s no reason to build new turbines when wind farms are already in place in in Madison county and Tug Hill.

For the purposes of this post I am going to calculate what renewable resources would be required to meet the Governor’s proposal.  In my opinion the claim should stand on its own with new renewable resources.  What the fair does not need can be used elsewhere but it should not rely on existing sources or projects in development designated for other purposes.  Otherwise Governor Cuomo could already have said the State Fair gets all its electric power from renewables instead of a promise for the future.

In order to properly calculate the requirements to make New York State Fair electricity fossil-free detailed historical load information is needed.  I don’t have that information so I am going to have to explain what I am assuming about load and why I am assuming it.  Ultimately, I hope to show readers the difficulties glossed over by the renewable energy proponents that Mr. Coin interviewed.  If you don’t want to wade through the numbers then skip the analysis section and cut to the chase.

Analysis

I am going to focus on Chris Carrick’s claim that “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  I will show solar is not so doable or cheap unless you use his simplistic approach.

One of the difficulties explaining technical information is the need for background information.  Another problem is there is little room for the details and, frankly, no public appetite for the boring minutiae needed to check numbers so it is understandable why that information was not included in the article.  I don’t have any space restrictions and will try to keep readers awake long enough in this explanation section so that you understand my calculations and conclusions.

A primary problem with solar energy is that it is intermittent.  Obviously at night there can be no solar energy generated and when it is cloudy the amount produced is lower than on a clear day.  The capacity factor (the actual amount of energy produced divided by the maximum possible amount of energy produced) is a measure of the availability of any electric generation source.  I will use that parameter in this analysis to calculate how much energy can be produced for a solar farm of a given size over a given time.

I chose to use performance information from a local solar installation to evaluate the claim that solar is doable and would cost about $12 million.  I used the Onondaga County Oak Orchard Waste Water Treatment Plant (OOWWTP) which has data in the New York State Energy & Research Development Authority Distributed Energy Resources system.  The first data reported from this installation is dated 31 August 2018.  The facility was developed by Tesla Energy Operations, Inc. with a rated electric generation capacity of 2,523 kW.  Even though this is about ten miles away from the Fair I chose the site because it is relatively new, is at the same elevation as the state fair so there should be no problem with orographic cloud so cloudiness should be relatively similar, and because there wasn’t anything with data available really close to the fair grounds.

According to Coin’s article the fair used 9 million kilowatt hours in 2018-2019.  I will assume that is an annual number.   In 2019 OOWWTP generated 2,363,640 kW of electricity for a capacity factor of 10.7%.  In other words, it produced 937 kWh for each kW of capacity.  In order to produce 9 million kWh the facility would have to have a capacity of 9,607 kW.  The article did not give a capacity but did state that a 45-acre solar farm could provide the electrical energy needed. Assuming 66 square feet generates 1kW of solar energy 9,607 kW would require 14.6 acres of solar panels.  Another way to calculate the space needed from OOWWTP is by estimating the area of the solar array from a satellite view.  I estimate that the OOWWTP array itself covers 7.54 acres and scaling that by the kW capacity produces an area of 28.7 acres.  My annual estimate appears to be significantly different that the Carrick’s quoted 45 acres of panels so I assume he did not use the annual number to estimate the size of the needed solar farm.

Even though I cannot reasonably say that my estimates of the annual solar electric generation reasonably match the article’s estimate it does not matter much because using annual numbers is wrong.  I will show below that the time period used to estimate the necessary resources matters a lot.

The article notes that “The fair uses about a third of its annual electricity during the months of August and September”.  The annual number is 9 million kWh so for those two months 3 million kWh is needed.  The good news is that 2019 monthly capacity factors ranged between 2.14% and 19.44% and the higher numbers are in the summer.  The Monthly Solar Output Onondaga County Oak Orchard WWTP table lists all the monthly values.  I calculated that the capacity factor for the two months would be 14.13%.  In August and September 2019 OOWWTP generated 521,976 kWh of electricity.  Therefore, it produced 207 kWh for each kW of capacity.  In order to produce 3 million kWh the facility would have to have a capacity of 14,500 kW.  Based on the data for these two months the solar facility would have 1.5 times larger capacity than one sized based on annual data.  Assuming 66 square feet generates 1kW of solar energy 14,500 kW would require 22.0 acres of solar panels and scaling the size of the OOWWTP array would be 43.3 acres.  That is pretty close to Carrick’s 45 acres so let’s assume he used the monthly numbers to estimate the necessary resources.

Of course, most of the power is used during the 13-day run of the fair itself.  In order to estimate the daily requirements, I arbitrarily assume that the power used during the State Fair days is ten times the power used on the other 49 days in August and September.  I calculate that the average power used on a State Fair day is 167,598 kWh.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar System table lists the data used to calculate the average State Fair day electric energy need and the daily output and daily capacity factor from the OOWWTP.  Using the same methodology to determine how much electric energy could be generated for each 1 kW of capacity the table lists the capacity needed for each day of the 2019 Fair season.  There probably are daily difference sin energy use as a function of the attendance but I did not try to estimate that effect.  Nonetheless, we can see that even on the day with largest capacity factor (8/25/2019) the capacity needed for one state fair day doubles the monthly estimate and that a facility with a capacity of 30,415 kW would be needed. Importantly note that the day to day variation of the capacity factor.  On the worst day you would need to over 171,000 kW of capacity using these assumptions about daily load at the State Fair and that would require a solar facility nearly 12 times larger than one based on the monthly numbers.  I assume that would be an overestimate because on the day with the lowest solar capacity problem also was the lowest attendance day so probably was not only cloudy but raining.

Renewable proponents rarely acknowledge the time period problem shown here because it makes their cost estimate of the renewable resource worse.  There is an even bigger problem that is rarely mentioned.  The all renewable resource plan should also account for energy storage needed when winds are calm at night.  The Hourly State Fair Electric Energy (kW) Requirements and Estimated Deficit table lists estimated hourly loads and potential solar and wind hourly output.  In order to estimate the hourly load, I made assumptions about the hourly load in the State Fair Hours Weight column.  I assumed that hours 19 through 22 would be maximum load and that hour 02 through 06 would be 15% of the maximum.  The column lists the hourly assumed load as a percentage of the maximum load for all the hours.  I used that information and the assumed 167,598 kWh of a State Fair day value to calculate the hourly loads shown.

The table also lists the hourly renewable energy outputs which can be combined with the hourly load estimate to determine the margin between the two.  Remember that the Governor wants to make State Fair electricity all renewable so at the end of the day the cumulative margin should be positive.  In this analysis I estimated how much wind and solar would be available on the best solar capacity factor day.  I estimated that a solar facility (capacity of 30,415 kW) based on the previous daily requirement analysis combined would be needed and combined that with the OOWWTP output data for August 25, 2019 to predict solar generation.  I utilized the same approach to calculate the capacity that would be needed for a wind farm to power the same average daily load.  II used the capacity factor from all the onshore wind farms during the State Fair and calculated that 23,423 kW of wind capacity would be needed to provide 1,675,978 kWh.  Hourly wind data downloaded from the NYISO real-time dashboard were used to calculate the hourly capacity factors needed to estimate hourly availability of wind on August 25, 2019.

The analysis shows that there are five hours when the combined solar and wind energy resources are insufficient to power the State Fair.  The Governor’s promise to use only renewable resources should include energy storage costs for those five hours when winds are light at night. A recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark” provides information that can be used to estimate the costs of the energy storage option.  I explained how information from that report could be modified to estimate costs for any configuration in another posted essay.  In the Calculated Cost Breakdown $ per kWh Parameters for a U.S. Li-ion Standalone Storage System table I show how to estimate the costs for a solar-only system ($30.5 million) and a combined solar and wind system ($9 million) to meet the shortfalls for this example State Fair day.

There is another consideration with Li-Ion battery storage systems.  The National Renewable Energy Lab (NREL) report Life Prediction Model for Grid-Connected Li-ion Battery Energy Storage System  notes that in order to maximize battery life the batteries have to be operated such that a limited operating range is used.  In particular the report says that they must use “active thermal management and cycle the battery within a restricted 54% operating range”.  When the operating range limitation is included the battery storage costs increase to $55.7 million for the solar-only system and $16.8 million for the solar and wind system.  Don’t forget that is only for ten years!

 Conclusion aka The Chase

As noted before Chris Carrick claimed “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Using the information available in the article I was not able to reproduce those values exactly so I am not sure what assumptions were used.

I used historical data from a nearby 2,523 kW solar array to compare with Carrick’s numbers.  Using 2019 annual operating capacity in order to produce 9 million kWh the capacity of a solar array would have to be 9,607 kW.  However, the proportion of the size of the local solar array to the size of the array needed is 29 acres which is not particularly close to the size Carrick claimed would be needed.  I assume that even though he mentioned needing 9 million kWh that he did not use that value to calculate the size.

The fair uses about a third of its annual electricity during August and September.  Using the observed operating characteristics of the local array I determined that the size of the array necessary to provide the State Fair with that amount of power would have to be 14,500 kW.  The proportion of that amount of power to the local array indicates that new array would have to be 43 acres so I assume that Carrick sized his array based on the August and September data.

However, in order for renewable resources to provide all the electricity for the State Fair we need to look at the renewable resources and energy use on the ten days when the State Fair is open.  Using the best local data availability and my estimated daily energy usage the solar array necessary to meet the Fair’s needs would have to have a capacity of 30,415 kW, over twice as large as using a monthly estimate to determine needs.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar Systemtable shows that daily variation is high.  On the worst-case day, you would need a solar array of 171,000 kW capacity nearly 12 times larger than one based on a monthly value.

Proponents of renewable energy typically ignore the short-term renewable requirements but there is an even bigger problem.  Any plan to become 100% fossil free needs to account for the fact that energy storage is required at night when the winds are light.  On August 25, 2019 I determined that there were five hours when solar and wind energy resource output would be insufficient to power the fair and that energy storage would be required.  I estimated that 23 MWh of energy storage would be required to balance the deficits observed.  In order to maximize battery life the operating range of Li-Ion batteries is only 54% so that means that batteries capable of providing 43 MWh are needed.

 

I was not able to verify Carrick’s cost estimate of $12 million dollars.  However, using daily data instead of monthly data increases the solar power needed between two and twelve times his estimate so it will be more expensive than he claimed.  In order to minimize energy storage cost, I included output from a 24,423 kW wind farm which I would expect to be on the order of the same cost of the solar array.  Even with the wind farm, the energy storage cost to backup the solar array adds another $16.8 million dollars.  If we assume that the wind and solar resources can last 30 years then that means that the battery cost will be tripled.

 

In conclusion, I expect that the cost of the solar array will be at least doubled if the daily needs of the State Fair are considered, in order to minimize energy storage a wind farm costing about the same as the original solar array has to be included, and energy storage at about the cost of the original solar array will be needed three times over the lifetime of the solar array.  Add them all up and I estimate that the true cost of renewables is at least six times higher than Carrick’s estimate of $12 million.

Mr. Coin concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective”.  If costs are no object then it is “doable”, but I challenge the “straightforward and effective” conclusion.  The claim that all that is needed is a 45 acre solar facility is wrong if we are to provide the State Fair with all the electric power needed during the ten days the fair is open.  In the cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines and an energy storage array totaling 43 MWh would be needed.

I don’t have the time to comment on Mr Coin’s conclusion that “heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  However, all the problems that I found for the summertime use of electricity at the fairgrounds are compounded in the winter because the solar resource is so much lower.

Finally, there is one last aspect of Cuomo’s, dare I say it, grandstanding.  What about transportation at the State Fair?  With the exception of some of the buses that provide shuttle service, all the transportation servicing the Fair are powered by fossil fuels.  That includes trucks bringing food and material, moving the midway with all the carnival rides and attractions, and all the farmers bringing livestock to exhibit.  Finally even the on-site the trams used to get around are pulled by fossil-fired tractors.

Do not hold your breath waiting for a truly fossil free New York State Fair.

Regulatory Assistance Project Electric Vehicle Roadmap

The Regulatory Assistance Project (RAP) is an” independent, non-partisan, non-governmental organization dedicated to accelerating the transition to a clean, reliable, and efficient energy future”.  This post addresses their “Roadmap for Electric Transportation”.

I have run into RAP policy recommendations before.  Staff are “former utility and environmental regulators, industry executives, system operators, and other policymakers and officials with extensive experience in the power sector”.  After seeing this I wondered who supports their work and could find nothing on their web page.  Mark Krebs looked into RAP and concluded that RAP is effective and well funded but could not find any specifics who funds their work.  He suspects and I agree that “RAP is now being funded by the usual climate fear mongers, such as the Pew Charitable Trust, the Hewlett Foundation, etc.”

The intent of the roadmap is to provide legislators a “complete and useful resource for legislators interested in accelerating electric vehicle deployment”. RAP has developed a policy guide, “as well as a set of model legislative options with annotations noting their implications, a fact sheet and presentation slides”.  In other words, it is a slick lobbying effort.

The roadmap’s introduction prompted me to write this essay.  The introduction states:

“Electrification of the transportation sector (cars, trucks, buses, taxis, ports, etc.) provides an opportunity for states to save citizens money, increase local jobs and business, address national security concerns, improve public health and combat climate change. Real-world experience and studies show that these benefits are achievable, but proactive legislative action and state planning are needed to realize their full magnitude. Without an early and comprehensive approach, potential benefits will be lost.”

In particular, I had to scratch my head how electric vehicles (EV) would provide those benefits.  I address each benefit claim below.

Save Citizens Money

It is a matter of faith that electric vehicles will save consumers money.  The RAP Policy Guide states:

Consumers buy electric vehicles for a variety of reasons, ranging from environmental consciousness to enjoyment of the product. The costs of new EVs are higher than comparable gasoline vehicles, but the cost differential is dropping. EV owners currently save money after purchase because EVs are cheaper to operate and maintain than gasoline vehicles.  Maintenance costs of an EV are lower than for traditional vehicles due to fewer moving parts. Fueling costs are cheaper too; on a national average, it costs less than half as much to travel the same distance in an EV as in a conventional vehicle.

I don’t want to spend a lot of time doing a quantitative analysis of potential cost savings but will make some comments.  There is the obligatory claim that EVs are more expensive now but the costs are coming down and when they do boy oh boy then everyone will want one.  In the meantime, if people would just consider that maintenance and fuel costs are cheaper, then people would buy them.  So, on one hand consumers are supposed to total costs to guide their decision to buy but not all the costs.  What about the batteries?  The life of the battery affects the overall cost of the EV.  There are two factors that affect the life of the battery – calendar life and the number of charging cycles.  Temperature, rate of charge and discharge, depth of discharge, etc. affects the life of the battery.    Consumers like me either buy a new car and drive into the ground or buy used.  In either case I would have battery life anxiety given that a typical Li-ion battery lasts for 300-500 charging-discharging cycles.   One other cost detail is that users have to install a battery charging system.  A 110 volt charging system only costs $500 to $1,000 but takes 18 hours to charge to drive 100 miles.  A 240 volt charging system costs $2,000 to $5,000 and takes 4 hours to charge to drive 100 miles.

Increase Local Jobs and Business

The first contradiction is that the claim electric vehicles require less maintenance also means that there will be fewer maintenance jobs.  In addition, the RAP Policy Guide states “In Minnesota, a study found that installing 150 EV chargers would generate $14.2 million in economic activity, including $4.6 million in labor income”.  The reference for that claim says “The University of Minnesota Extension study indicates that installing just 75 50-kW and 75 150-kW DCFCs in Greater Minnesota would generate $14.2 million in economic activity.  This includes $4.6 million in labor income.  Communities and businesses that host charging stations may also see economic benefits as EV drivers eat or shop while their vehicles charge.”  However, there is no reference for the study to determine if this claim is justified.  The direct cost to construct 75 50-kW and 75 150-kW fast-charging electric vehicle chargers listed is $9.2 million.  Without the original reference to check the assumptions I will assume that each charger equals $9.2 million divided by 150 or $61,333 each.  The report claims that 50 people will be employed at a cost of $3.3 million.  I have no clue how to apportion that because I have no idea how many people would take how long to install a charger but we can add the labor cost to estimate that each charger will cost $83,333.  Somehow the study claims that spending will lead to indirect and induced output of $5 million.

I don’t know what you call grey literature that references grey literature that quotes an unreferenced study but suffice to say it is not peer reviewed science.  All this example and the other points made in the policy guide show is that government spending creates jobs but ignores the broken window fallacy – money spent on EV fast charges, for example, is “money that cannot be spent on food, clothing, health care, or other industries. The stimulus felt in one sector of the economy comes at a direct – but hidden – cost to other sectors”.

Address National Security Concerns

Just when you thought the claims could not get anymore ignorant the national security benefit is described:

In 2017, the United States imported about 19% of the petroleum it consumed. Because transportation accounts for nearly three-fourths of total U.S. petroleum consumption, using more energy-efficient vehicles like hybrid and plug-in electric vehicles can have a direct impact. When EVs plug in, they are mostly powered by a domestic mix of energy sources, including natural gas, coal, nuclear, hydropower, wind and solar. This is in stark contrast to gasoline-fueled vehicles, which depend solely on oil — which is subject to a range of global price and availability risks.

This studiously ignores the changes caused by fracking which have changed the import/export dynamic because in 2018 the US only imported 11% (or 8% less than in 2017) of the petroleum it consumed and I am sure that the 2019 imports will be even lower.  There also is another national security issue – not enough of the rare earth minerals necessary for EV batteries are produced in the US.  It is estimated that there’s about 63 kg of lithium in a 70 kWh Tesla Model S battery pack, which weighs over 1,000 lbs (~453 kg).  When asked if he worries about lithium supply, Tesla CTO JB Straubel once said that he worries more about cobalt, which is used in the cathode of Tesla’s battery cells. The resource is more problematic since the bulk of it overall supply has historically come from the conflict-prone Congo.  Clearly, if you look at the big picture national security concerns will be an issue if we try to electrify transportation compared to where we stand now with petroleum.

Improve Public Health

The fact is that ambient air quality levels have been coming down in the United States for years.  There still are ambient air quality issues and a switch to electric vehicles will help alleviate those health problems.  However, there will be diminished returns for future reductions simply because the concentrations are already so low.  In fact, the marginal improvements in the United States have to be weighed against health impacts elsewhere.

The public health improvements claimed by EV advocates immorally ignore the environmental and health impacts of rare-earth mineral mining elsewhere.  In particular, cobalt is problematic.  Unlike most metals, which are not toxic when they’re pulled from the ground as metal ores, cobalt is “uniquely terrible,” according to Gleb Yushin, chief technical officer and founder of battery materials company Sila Nanotechnologies.  “One of the biggest challenges with cobalt is that it’s located in one country,” he adds. You can literally just dig up the land and find cobalt, so there’s a very strong motivation to dig it up and sell it, and a a result there’s a lot of motivation for unsafe and unethical behaviour.” The Congo is home to ‘artisanal mines’, where cobalt is extracted from the ground by hand, often using child labour, without protective equipment”.

Combat Climate Change

Advocates for greenhouse gas reductions regularly pick and choose which numbers to include and which ones to exclude.  Until the electric grid operates only without fossil fuels, the CO2 emitted from the tailpipe is simply moved to an electric generating unit stack somewhere.  I would love to see a true life-cycle analysis of the 100% renewable energy system vs. the fossil-fueled energy system.  I suspect that the real observable environmental impacts of the renewable system with the enormous areas required to provide power as opposed to the fossil-fueled system of today are greater.

More importantly, transportation greenhouse gas emissions in, for example, New York are such a small fraction of global emissions any reduction will not provide any tangible benefits. In the New York Transportation Analysis of Carbon Dioxide Emissions and Potential “Savings” table I present the effects of completely eliminating the total NY transportation emissions of 73.98 million metric tons of CO2 equivalent in 2016.  The table shows that the transportation emissions are 0.23% of the total global emissions and that we could expect the global temperature in 2010 will only be 0.0023 degrees C if those emissions are eliminated.  These numbers don’t mean much but can be related to the facts that temperatures decrease as you go higher in elevation or temperatures increase as you go further south in latitude.  Specifically, temperature generally decreases three degrees Fahrenheit for every 1,000 foot increase in elevation above sea level and temperature changes three degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level.  In this instance, completely eliminating New York transportation emissions would be the same as a nine inch change in elevation or two tenths of a mile change in latitude.

Conclusion

There is another aspect of the EV policy that weakens the benefits arguments.  In A reality check on electric cars Bill Lynch and Dr. Jay Lehr crunched some numbers and show that the benefits of electric cars are based on weak numbers.  They also show that the goal of a longer range EV is unlikely simply because the weight of the additional batteries needed offsets the mileage gained.  The bottom line is that the prospects for improved EV performance are not as rosy as proponents suggest.

To summarize, the benefits claimed in this study are all either feel good virtue signals or demonstrably inaccurate.  There could be public health impacts but given current ambient levels of pollution they will be smaller than imagined in the descriptions of this report.  There will be climate change “benefits” but they are only feel-good measures because the impacts could never be measured.  Cost savings projections are based more on expected cost reductions and ignore the additional costs of installing a charging system.  The claims made for local jobs and business cannot be verified and ignore reductions that would necessarily occur in the existing vehicle service job market.  The claims for national security ignore the current status of petroleum imports and exports.  More importantly, they immorally ignore the very real horrific environmental and societal impacts of cobalt mining in the Congo as well as the fact that relying on that country for a critical component necessary for electrifying transportation would substantively increase national security concerns.

The RAP is a front organization for climate fear mongers.  This slick package of lobbying materials is based on shallow and inaccurate claimed benefits.  Sadly, I expect that it will find a ready audience for those convinced that we have to do something and unwilling to check the basis of the arguments.

EPRI Electrification Scenarios for New York’s Energy Future

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation. The Electric Power Research Institute (EPRI) recently released an “assessment of the potential role of electric technologies to meet energy needs and resulting impacts on end-use energy efficiency, electricity supply, and economy-wide emissions through 2050” for New York.  This post looks at the results of this analysis relative to the CLCPA and is another in a series of posts on this legislation.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker, specifically can I afford to continue to live here in retirement.  Given the results for other jurisdictions that have implemented renewable energy resources at far lower levels, I am convinced that the costs will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The politicians who passed the CLCPA mandated a reduction of New York’s GHG emissions to 60 percent of 1990 emissions levels in 2030 and that emissions from electricity production would be zero by 2040.  However, they just assumed that their targets could be met and only mandated that two years of the effective date of the legislation the climate action council would prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule.  In other words, this is a classic cart before the horse legislation example.

In the absence of a state plan I welcome any analysis of New York’s future energy system so I was happy to see this document.  The Executive Summary describes the report and notes the important caveat that it does not address the CLCPA requirements:

The analysis finds that electrification outcomes in New York, including the extent and timing of adoption, infrastructure and investment needs, and associated economy-wide emission reductions, will vary depending on a range of policy, economic, and technology factors. This study was conducted before the enactment of the state’s Climate Leadership and Community Protection Act and does not make policy recommendations or identify specific pathways to achieving the state’s greenhouse gas (GHG) targets. Instead, it illustrates that a portfolio of electric technologies could play a significant role in reaching the state’s energy goals. Furthermore, this initial assessment helps identify the areas in which legislators, regulators, utilities, grid operators, customers, and other stakeholders can work together on the next chapter of New York’s clean energy future.

Study Summary

The report describes the study methodology, assumptions, and limitations first.  Then it describes how NYS consumers use energy today. The study examines the evolution of electric technology adoption and the impact on the NYS energy system for four scenarios using EPRI’s NY-REGEN energy-economy

model.  The fourth section provides “an in-depth look at a variety of electric technologies, analyzes consumer costs and use cases, and identifies areas in which customer outreach and education may be needed in the future” .This approach is straight-forward and consistent with what anyone who is trying to project what may happen in the future would do.  There is one caveat I will mention though.  The NY-REGEN energy-economy model is simply a fancy packaging of what the model developers think will happen so it is only as good as the input assumptions.

For this type of analysis, the results have to be considered relatively.  Four scenarios were analyzed.

      1. The Baseline scenario reflects moderate improvement in technology costs and performance based on anticipated trends and EPRI research, and the attainment of pre-2019 NYS clean energy targets. Assumptions of economic growth, fuel prices, and service demand are drawn from the U.S. Energy Information Administration.
      2. The Carbon Price scenario maintains Baseline assumptions on technology improvements and cost decline. Under these conditions it explores the impact of hypothetical economy-wide carbon policy in which carbon dioxide (CO2) is illustratively valued at $50/ton CO2 starting in 20202 and escalating to $216/ ton CO2 in 2050.
      3. The Mandates scenario explores the impact of possible regulatory interventions for electric end uses and additional energy efficiency. The policies this scenario examines would require electric technologies for all installations of building heating equipment and new vehicle purchases in 2030 onwards. In addition to the Baseline assumptions, heating equipment performance improvements are accelerated by 15 years, but cold-weather breakthroughs are not assumed.
      4. The Transformation scenario combines the above Mandates with a hypothetical economy-wide carbon price of CO2 illustratively valued at $100/ton CO2 beginning in 2020 (escalating to $432/ton CO2 in 2050) with elements of the expanded clean energy targets in the state’s Climate Leadership and Community Protection Act.

Findings Summary

The report lists the following key findings with my italicized clarification comments

The results of this study are based on a suite of detailed assumptions and should be interpreted as directional in nature, helping to frame priorities for further study as New York State advances its energy goals. As noted previously the study developed a scenario for a baseline and then did three possible scenarios for the future.  Results should be considered by comparing the baseline results to the results of each of the scenarios.

      • The NYS energy system has large potential for electrification, which, in conjunction with low-carbon electricity, can achieve substantial CO2 reductions. Electricity’s role in the state economy will continue to grow over the next 30 years—the pace and extent of that growth will depend on policy decisions, technology improvement, market readiness, and economic conditions. Across the study’s four scenarios, electricity’s share in final energy use ranges from roughly 25% to 70% in 2050, up from around 20% today. If they had done an evaluation of the CLCPA then electricity’s share of final energy use would be even higher.
      • Energy efficiency is a key factor in reducing energy use, limiting CO2 emissions, and managing infrastructure needs. Even before accounting for electrification, the study finds that robust energy efficiency cuts total final energy use in NYS by 35% of what it otherwise would be in 2050; additional efficiency gains from electrification range from 9% to 21%. Energy efficiency gains are realized by both electric and direct fuel alternatives, with annual improvement rates ranging from 0.5% to 4% depending on the end-use technology.
      • After energy efficiency, electrifying transportation while decarbonizing the grid with renewable energy offers the greatest potential to cost-effectively reduce CO2 emissions in NYS. Electric vehicles (EVs) and plugin hybrid electric vehicles (PHEVs) are projected to become lower cost alternatives to conventional vehicles for most drivers within the next decade, even without additional economic incentives. Almost 30% of New York passenger vehicle miles are projected to be fueled by electricity by 2030 in the Baseline scenario, increasing to roughly 75% by 2050. EV charging infrastructure is an essential component to achieving a highly electrified transportation fleet in NYS. (According to Figure 2-6, there were 12,116,00 light-duty vehicles and 41,000 were electric in 2015 for 0.34%.)
      • New York’s winter climate and building stock call for advanced technologies and targeted approaches to heating electrification when compared to other areas of the United States (EPRI, 2018). While air-source heat pumps (ASHPs) are more efficient and cost-effective than oil-based heating, which continues to warm about one in four homes in New York, natural gas furnaces are currently more economic in NYS on an annualized capital and operating cost metric. Nevertheless, potential breakthroughs in cold-climate heat pumps—including ground-source heat pumps—have the potential to alter these cost and performance projections. Further study could assess the benefits, costs, and feasibility of these advanced technologies in conjunction with building envelope efficiency improvements. (Retrofitting ground source heat pumps is problematic so the more likely retrofit option is air source heat pumps.)
      • The adoption of electric end-use technologies will depend on individual customer decisions—market readiness, technology maturity, vendor-to-customer education, and appropriate incentives will be crucial to advancing electrification. While technology progress and carbon policy help to shift the market from fossil fuels toward electrified end uses, accelerating this transition may well require collaborative market interventions by policymakers, regulators, and utilities, with consideration of the needs of a diverse range of consumer situations—including low-income housing, older or landmarked buildings, and rural settings. (Collaborative market interventions could be construed as ramming what they want down the consumer’s throats.)
      • In all scenarios, New York’s statewide peak demand shifts from summer to winter and, if unmanaged, could increase substantially. Peak demands are expected to shift toward the early mornings of the coldest winter days, primarily due to increased EV charging needs in low temperatures plus electric heat pump adoption, while summer electricity usage drops as air conditioning efficiency improvements outpace growth in service demand. In the Mandates and Transformation scenarios, where customers electrify nearly all space heating and transportation but do not manage the timing of demand on the grid, peak winter demand in 2050 could be more than twice as high as today’s system peak. This highlights a key opportunity for New York’s electricity system stakeholders to develop and implement solution approaches such as cost-reflective time-of-use pricing, active load management of smart vehicle charging and other flexible loads such as space conditioning, behind-the-meter storage, and advanced cold-weather heating systems.
      • Flexible resources arising from a portfolio of advanced technologies and additional transmission will be critical to decarbonizing electricity generation. As more renewables are added to the generation mix to meet New York’s clean energy goals, dispatchable technologies will be needed to maintain reliability and balance variable generation, especially after 2030. Broadening the state’s portfolio of low-carbon, flexible generation assets can help reduce reliance on the gas generation fleet. EPRI’s new Low-Carbon Resources Initiative may provide important insights in this area. (The CLCPA likely remove the low-carbon resources initiative option from consideration.)
      • Customer adoption trends and electricity grid impacts are projected to vary across the state. Limited residential EV curbside charging, split tenant/landlord incentives, and variety across household characteristics and building types influence implementation in downstate urban areas, while affordability of converting to electric technologies may be a factor to consider in other parts of the state.
      • Electrification of specialized applications such as off-road vehicles (for example, forklifts), ground equipment at ports and airports, and industrial end uses may offer substantial benefits. Potential benefits include energy efficiency and reductions in emissions, noise, maintenance, and costs compared to the direct fuel alternative.

Motivated reasoning

There is a prevailing bias in this study that I believe motivates the reasoning and ultimately the results.  According to the document EPRI “brings together its scientists and engineers as well as experts from academia and industry to help address challenges in electricity, including reliability, efficiency, affordability, health, safety and the environment”.  There is no charge to EPRI from its funding organizations to consider all energy sources and determine the most affordable solutions for the future.  Consequently, they are all in for electrification.

This study was funded by the New York Power Authority (NYPA) and Consolidated Edison (Con Ed).  Both organizations have a vested interest in electrification and publicly supporting the CLCPA.  Increased electrification enhances their empires for lack of a better word so the more the better.  The Power Authority is an agency controlled by Governor Cuomo.  I can assure you that they cannot publicly question any action by any agency and certainly cannot raise questions about the viability of the Governor’s signature climate legislation.  Consolidated Edison is a corporation whose profits are dependent upon revenues determined by the Department of Public Services again controlled by Governor Cuomo.  Consequently, they too are reluctant to question the viability of the CLCPA.

According to the report “The study did not explicitly model recently adopted laws in New York City and New York State, such as New York City’s Local Law 97 or the State’s CLCPA. The study is not intended to identify explicit pathways to achieving the state’s GHG reduction targets. The scenarios presented here have been designed to illustrate the role of advanced technology alongside policy and regulatory drivers in reaching NYS’s clean energy requirements.”  I am confident that this language was vetted at the highest levels of NYPA and Con Ed to provide as much distance as possible from anything that could be construed as derogatory to CLCPA implementation.

One would think that a primary result from this analysis would be a comparison of the total costs for the four scenarios.  I did not read every word in the entire document but I did search for the word “cost” and the symbol “$”.  There are costs for options discussed in the electrification technology case studies but the total costs are not listed.  For example, the cost of air source heat pumps relative to natural and oil-fired furnaces are listed and it is shown that air source heat pumps are more cost-effective than oil-fired furnaces.  However, the study did not combine the number of fossil-fired furnaces that have to be converted and the cost of air source heat pumps to come up with a statewide cost. The absence of that obvious information certainly could be construed as a hiding a result inconvenient to the CLCPA.

Magical solutions

In my opinion, the findings include some results that are only possible if there are magical solutions.  In this category are technologies that are not currently available but are assumed to appear as needed in the future.  Also included are policies that have not succeeded as hoped so far but are also assumed to work as needed to meet the electrification scenario requirements.

In the electrifying transportation findings summary above I noted that in New York only 0.34% of the vehicles registered in 2015 were electric vehicles but the Baseline scenario assumes that almost 30% of New York passenger vehicle miles are projected to be fueled by electricity by 2030.  The latest NYSERDA electric vehicle registrations show that by October 2019 the number of electric vehicles was up to 64,588.  If we assume that the number of electric vehicles is proportional to the electric of vehicle miles traveled, then by 2030 there need to be 12,116,00*30% or 3,634,800 light duty vehicles so 3,570,212 electric vehicles have to be purchased in the next ten years.  The magical solution: “Even in the Baseline scenario, declining battery costs combined with lower fuel and maintenance costs make light-duty electric vehicles the economic choice for many households. The upfront cost premium relative to conventional vehicles is more than offset by lower total ownership costs of fueling and maintenance, driving economic adoption for many households and businesses.”  All this does is ignore the very real concerns of people who depend on their vehicles to provide transportation whenever they need it whatever the temperature to go wherever they need to go.  It also assumes that batteries will necessarily get cheaper.

In order to meet the CLCPA emission reduction goals electrification of home heating has to be increased.  EPRI points out that air-source heat pumps are more efficient and cost-effective than oil-based heating.  The problem is that below 20°F the “baseline ASHP system modeled for installation in 2020 provides full heating needs above 20°F only; at lower temperatures, supplemental heating by electric resistance, gas furnace, or oil-based heating equipment is required”.  Of course, all of New York has to have supplemental heating equipment because temperatures below 20°F are to be expected and that makes air-source heat pumps less attractive.  The magical solution: “potential breakthroughs in cold-climate heat pumps—including ground-source heat pumps—have the potential to alter cost and performance projections” that makes more widespread adoption the preferred approach.  This ignores the fact that heat pumps work by transferring energy from one place to another and that there just isn’t that much energy when the temperature is below 20°F.  The potential to alter cost and performance by much is not very likely absent repeals of the laws of physics.

The key findings note that “in all scenarios, New York’s statewide peak demand shifts from summer to winter and, if unmanaged, could increase substantially. Peak demands are expected to shift toward the early mornings of the coldest winter days, primarily due to increased EV charging needs in low temperatures plus electric heat pump adoption”. One of the promises of the future smart grid is that peak loads will be smoothed out so this is a problem.  The magical solution: EPRI claims there is a “key opportunity for New York’s electricity system stakeholders to develop and implement solution approaches such as cost-reflective time-of-use pricing, active load management of smart vehicle charging and other flexible loads such as space conditioning, behind-the-meter storage, and advanced cold-weather heating systems”.  Here is a news flash to EPRI – when residents are in the middle of a polar vortex cold snap that lasts several days, they will have to use whatever energy is needed to stay warm.  All of the solutions proposed will result in regressive costs hurting those who can afford it the least the most.

Conclusions

There are aspects of this report that have implications to CLCPA implementation that deserve more attention than I can include in this introductory post.  For example, the future scenarios specify values of the Social Cost of Carbon that increase over time.  I believe that is a necessary aspect for that kind of carbon pricing to work but this is the first instance where I have seen projections made for New York.  The problem I want to address is the fact that the Social Cost of Carbon is supposed to put a number on future damages from CO2 emitted today and the values they included exceed the published thresholds.  If the costs exceed the expected damages it doesn’t make sense. You wouldn’t spend more than a dollar to save a dollar.

As noted, these electrification scenarios do not “make policy recommendations or identify specific pathways to achieving the state’s greenhouse gas (GHG) targets”.  While this report has a vested interest in electrification, there also is a problem that they had to dance around or incur the wrath of the politicians that passed the CLCPA.  One of the findings noted “Flexible resources arising from a portfolio of advanced technologies and additional transmission will be critical to decarbonizing electricity generation.  As more renewables are added to the generation mix to meet New York’s clean energy goals, dispatchable technologies will be needed to maintain reliability and balance variable generation, especially after 2030”.  The most appropriate dispatchable technology (natural gas fired turbines) is a Voldemort technology which must not be named because it is evil.  Problem is when the wind is calm at night the only alternative to keep the lights on is energy storage which is horrifically expensive.  EPRI, NYPA, and Con Ed know this but could not say it, hence the obfuscatory language.

The bottom line for any of these electrification scenarios is that intermittent energy, i.e., wind and solar, cannot fuel our society on its own.  The whole concept of the CLCPA net-zero energy future is flawed.   There is currently no alternative to fossil fuels for efficient cost-effective transport and the only near-zero-carbon fuel which can meet electrical generation needs is nuclear, which New York state policy is explicitly rejecting.

3 March 2020 New York Climate Action Council Meeting

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  The legislation set up the Climate Action Council to figure out how to implement the rule.  This post summarizes the first meeting of the Council.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  Given the results for other jurisdictions that have implemented renewable energy resources to meet targets at far lower levels I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The politicians who passed the CLCPA mandated a reduction of New York’s GHG emissions to 60 percent of 1990 emissions levels in 2030 and that emissions from electricity production would be zero by 2040.  However, they just assumed that their targets could be met and only mandated that two years of the effective date of the legislation the Climate Action Council would prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule.  In other words, this is a classic cart before the horse legislation example.

The Albany Times Union described the first meeting of the Climate Action Council as “uneventful” with cordial interactions, they did note “remarks by members signaled the tough questions the group will be grappling with in coming months and years”.  “How do we assess the cost of all this?” asked Donna DeCarolis, president of National Fuel Gas, a western New York energy company.

The New York Climate Act web page appears to be the new face of the program.  It includes a sign-up link to be on the contact list for new developments, and a fact sheet for the Climate Act.  There also is a general description of the Climate Action Council and a list of members.  Finally, there is a link to the first meeting materials and a recording of the session.

March 3, 2020 Climate Action Council Meeting

The web page for the Climate Action Council included meeting materials for the first meeting:

Update March 6, 2020: There is a video of the meeting available at the Climate Action Council website.

The agenda had the following items listed:

      • Welcome and Introductions
      • Co-Chair Remarks
      • Presentation: Climate Science Considerations, Radley Horton, Columbia University
      • Presentation: Climate Act Requirements
      • Climate Act Goals
      • Bylaws
      • Advisory Panels
      • Next Steps

The meeting presentation was a power point covering the agenda items and the climate act requirements presentation.  I am not going to reproduce all the slides in this presentation but will call your attention to some items.  The slide entitled New York’s Climate Leadership list five items including “Groundbreaking Environmental Support: Restore Mother Nature Bond Act – $3 billion “Restore Mother Nature” Bond Act to restore our state’s environment and improve resiliency.”  I think that the presentation should have noted that this is a proposed bond and has not been approved by the public.  For a state that has serious water quality problems my personal opinion is that the majority of those bond revenues should go to those problems rather than climate initiatives but only time will tell how that works out.

One thing that caught my eye was the slide entitled major roles and responsibilities that listed the following items:

      • Climate Action Council: Prepare and approve a scoping plan of recommendations to achieve 40×30, 85×50, carbon neutrality
      • Climate Justice Working Group: Establish criteria to identify and develop a list of disadvantaged communities
      • Just Transition Working Group: Conduct a study on job creation and workforce disruption related to the transition to a low carbon economy
      • PSC: Establish a program requiring load serving entities meet 70×30 and 100×40 targets
      • DEC: Promulgate the statewide greenhouse gas emissions limit regulation; establish a value of carbon; issue annual reports on statewide greenhouse gas emissions; promulgate regulations to implement the scoping plan
      • All Agencies: Implement strategies to reduce emissions; consider consistency with the Act in agency decisions

The climate justice working group will develop criteria for and list of disadvantaged communities and will report on barriers and opportunities for clean energy.  They will “ensure no increase in co-pollutant emissions or disproportionate burden on disadvantaged communities” and “DEC shall establish a community air monitoring pilot program in at least 4 disadvantaged communities”.  There also is a requirement to “Invest or direct available and relevant programmatic resources in a manner designed to achieve a goal for disadvantaged communities to receive 40% of overall benefits of spending on:

    • Clean energy and energy efficiency programs
    • Projects or investments in the areas of housing, workforce development, pollution reduction, low-income energy assistance, energy, transportation, and economic development

This legislation sets very aggressive targets to combat the supposed existential threat of climate change.  Nevertheless, the politicians still established these requirements which dilute resources from the primary goal and may spend money in ways that might not be the most cost-effective way to reach the targets.

I look forward to more information about the PSC responsibility to “establish a program requiring load serving entities meet 70×30 and 100×40 targets.  On the face of it, this is puzzling.  New York is de-regulated and the load serving entities do not generate much electricity so what are they supposed to do?  As a cynical New York resident, I suspect requiring them to meet the targets could ultimately transfer blame when things don’t work out.

Dr. Horton’s presentation “Climate Hazards, Impacts and Opportunities” included the usual litany of scary statistics and catastrophic projections used as rationale for the CLCPA.  One of my pragmatic environmental principles is the Baloney Asymmetry Principle first defined by Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”  There is so much BS in this presentation that I could spend weeks listing the caveats to claims, showing how data shown is often cherry picked to show the worst case, and how some of the information is mis-leading.  A simple list of examples of each will suffice.  The sea level trends and projections slide should be caveated to note that there are plenty of data showing none of the acceleration of sea-level rise that would be needed to reach the scary projections shown.  There are several references to climatic trends but note that the figures start in 1930, 1950 and 1958 which suggests that the starting points were cherry-picked to maximize the effect.  The global temperatures projections slides uses representative concentration pathway 8.5 which is mis-leading “The misuse of RCP 8.5 involves the transformation of what is more accurately described as a worst-case scenario into the sole ‘business as usual’ or baseline scenario that has become a centerpiece of climate policy discussions.”

Conclusion

So it begins, stay tuned.

NY GHG Emissions Status and Climate Leadership and Community Protection Act Targets

UPDATE March 4, 2020:  I mis-interpreted the 2030 GHG emissions reduction target.  I thought it was supposed to be a 60% reduction but it is only a 40% reduction.  As a result the sector reductions needed to meet that target have been modified.

In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  I recently summarized the historical Green House Gas emissions (GHG) and CLCPA targets.  This post looks at the historical data relative to the 2030 target.

Background

As noted in the historical New York State GHG emissions post the New York State Energy Research & Development Authority (NYSERDA) does an annual inventory of GHG emissions.  Their most recent report, Greenhouse Gas Inventory 1990-2016 contains a detailed inventory of historical greenhouse gas emission data from 1990-2016 for New York State’s energy and non-energy sectors.  Table S-2 New York State GHG Emissions 1990–2016 (MMtCO2e) from that report lists emissions from different sectors in million tons of CO2 equivalent (MMtCO2e).

The CLCPA GHG Emissions Targets 2016 Update table presents the emissions status for the 2030 CLCPA target to reduce GHG emissions 40% from the 1990 level and the 2050 CLCPA target to reduce GHG emissions 85% from the 1990 level.  According to the NYSERDA methodology, 1990 GHG emissions were 236.2 million metric tons of CO2e. The 2030 target limit is 141.7 million metric tons of CO2 equivalent (MMtCO2e) and in 2016, the last year of the NYSERDA inventory, NYS emissions were 205.6 MMtCO2e.  Therefore, in order to meet the CLCPA target in 2030 another 63.9 MMtCO2e have to be reduced.  This post addresses the fact that New York state reduced GHG emissions 30.6 MMtCO2e in the 26 years between 1990 and 2016 but has to reduce them another 63.9 MMtCO2e in 14 years to meet the 2030 CLCPA target.

Analysis

The New York State GHG Emission Reductions 1990 to 2016 table extracts the 1990 and 2016 data from NYSERDA Table S-2.  It is instructive to look at where the reductions were made over that 26-year period.  In the energy category total emissions were down 17% (36.16 MMtCO2e).  The largest reductions came from the electric generation sector but there were also reductions from the residential, commercial and industrial sectors.  Transportation, net imported electric, and waste incineration increased.  For non-energy sources the emissions went up 21% but only 5.6 MMtCO2e.  Although the waste sector went down agriculture and industrial process sector emissions went up.  Overall the State GHG emissions went down 30.58 MMTCO2e

The CLCPA 2030 target of 141.7 MMtCO2e requires a reduction in the fourteen years from 2016 of 63.9 MMtCO2e.  As shown in the New York State GHG Emission Reduction Projections 2016-2030 table, if every sector in the economy was required to make the same percentage reduction, then each sector would have to reduce emissions 31%.  Of course, it might be possible to reduce some sectors to zero.  The CLCPA proposes to eliminate GHG emissions from the electric sector by 2040 so what if that schedule is accelerated and we also reduce industrial GHG emissions to zero.  The same table also includes a scenario showing those reductions and shows that all the other sectors would still have to make 14% reductions.

A more reasoned approach to possible reductions would be to look at the reasons why there were reductions in the past.  For example, there are detailed numbers for the electric sector from the EPA Clean Air Markets Division Air Markets Program Data website. The website includes a query tool that I have used for years to extract specific data from national emission monitoring programs.  For this analysis I downloaded CO2 emissions data, operating time, heat input and load data as well as unit-specific information on fuel use and unit type so that I could show what changes caused the emissions reductions.  In the Last 20 years (2000 to 2019) New York State CO2 Emissions table, annual CO2 emissions for the last 20 years by the primary fuel type reported to EPA are listed.  Note that the total emissions in this table is greater than the NYSERDA number.  This is because the EPA data includes some sources that are not electric generating units included in the EPA data.

Clearly the primary cause for the reductions observed is decrease use of coal and residual-oil.   New York is unique in that there are five relatively new large residual oil-fired boiler units in the state.  The primary driver for the reductions was the cost of oil relative to natural gas coupled with the fact that there is much less CO2 emitted by natural gas firing.  At this time these units survive because they can provide 1000s of MW when necessary and their operational costs are low enough that the payments to be able to provide that capacity are sufficient to be viable.  Note, however, that they cannot reduce emissions much more because they still have to run a couple of times a year to prove that they can provide capacity.  Coal-firing units in New York were older and were required to install extensive controls over this period to continue to operate.  The cost differential between natural gas and coal was the final blow to viability.  The Cuomo administration requirement to close these units by 2020 was symbolic only because the reality is that despite the opposition of the Cuomo Administration, fracking reduced the cost of natural gas so that it was cheaper than coal. If coal-firing was cheaper than natural gas then those units would have been needed to provide economical electric energy and there would have been significant pushback to banning coal in New York.

I estimated what I expect would be a reasonable projection for possible reductions in the electric sector.  Coal is easy because the last coal plant has already shut down.  Frankly I don’t see how the State can shut down the residual oil-fired plants by 2030 without endangering capacity reliability but we can assume that the 2019 value is de minimus.  Doing the same thing with the other fuel and other oil categories brings the expected reduction to 3.51 MMtCO2e.  Finally, assuming that enough renewables come on line that natural gas emissions are cut by a quarter, I think the maximum you could possibly expect to get out of the electric is 9.76 MMtCO2e.

The largest source of GHG emissions in 2016 was the transportation sector.  New York is currently a member of the Transportation and Climate Initiative (TCI) which is currently considering “a new draft proposal for a regional program to establish a cap on global warming pollution from transportation fuels and invest millions annually to achieve additional benefits through reduced emissions, cleaner transportation, healthier communities, and more resilient infrastructure.”  While I have my doubts about the efficacy of their proposals the key point for this analysis is that they propose a series of actions that could reduce transportation sector emissions only up to 25%.

The reduction projections table also estimates the emission reductions necessary if electric sector were reduced by 9.76 MMtCO2e and transportation sector emissions were reduced by 25%.  Because these reductions are for two large sectors the remaining sectors would have to make much higher reductions.  I estimate 80% from all the other sectors.

Conclusion

This analysis shows that the 2030 40% reduction target is a stretch.  If every sector in the economy was required to make the same percentage reduction, then each sector would have to reduce emissions 31%.  If electric sector and industrial GHG emissions went to zero, then all the remaining sectors would have to reduce emissions 14%.  If electric sector emissions went down an amount I believe is reasonable based on historical emissions and transportation sector emissions went down by the highest percentage proposed by the TCI, then all remaining sectors would have to reduce emissions by 34%.

 Incredibly it is even worse because in my analysis I assumed that the emission reduction programs would be implemented over the 14-year period 2016 to 2030.  CLCPA § 75-0103 establishes the New York state climate action council.  It will consist of 22 members who have the charge to develop a scoping plan.  Two years of the effective date of the legislation the climate action council will prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule.  On or before three years of the effective date of the legislation, the council shall “submit the final scoping plan to the governor, the speaker of the assembly and the temporary president of the senate and post such plan on its website”.  In other words, the State will finally have the plan to meet the 2030 target of a 40% reduction in emissions in the summer of 2022 which leaves eight years to meet the emission reductions.

In the summer of 2022, the residents of New York will finally get an estimate of how many renewable resources will be necessary to displace the existing GHG emissions.  Not until then will we see how many wind turbines and how many solar panels will have to blanket the countryside, how much energy storage will be required to support these intermittent sources of energy, and how much transmission will be need to move the diffuse renewable energy from where it is produced to where it is needed.  Obviously, we will also have to wait until then to get an estimate of the costs projected to meet this aspirational goal.  Based on these preliminary first-guess numbers, the 2030 target of a 60% reduction by 2030 is so daunting that only the energy innumerate could possibly think that it can be met.

While some may say that once the plan is unveiled that a more reasonable target will be adopted, I disagree.  The zealots who have advocated for this virtue-singling law will never be satisfied and will be the first ones to litigate the State to meet these goals however unreasonable and expensive implementation may be.  Absent a magical solution, the only reasonable recourse is to repeal the CLCPA and start over by developing the plan first and then setting the targets.

NY Climate Leadership & Community Protection Act Emissions Targets

UPDATE March 4, 2020:  I mis-interpreted the 2030 GHG emissions reduction target.  I thought it was supposed to be a 60% reduction but it is only a 40% reduction.  As a result the sector reductions needed to meet that target have been modified.

In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In one of the first implementation tasks the New York State Department of Environmental Conservation (DEC) has started the process to calculate a statewide Greenhouse Gas emissions (GHG) limit for this law.  This is a background post that defines the emissions targets that I will  reference in future posts about the reductions necessary.

Emissions Inventory

New York State greenhouse gas emissions are available from the New York State Energy Research & Development Authority (NYSERDA) in their annual inventory of GHG emissions.  The most recent report, Greenhouse Gas Inventory 1990-2016 contains a detailed inventory of historical greenhouse gas emission data from 1990-2016 for New York State’s energy and non-energy sectors.  Table S-2 New York State GHG Emissions 1990–2016 (MMtCO2e) from that report lists emissions from different sectors in million tons of CO2 equivalent (CO2e).  They use this unit of measure in order to include all greenhouse gases in the control strategy as a function of global warming potential (GWP).  Despite the fact that this is a perfectly good emissions inventory the law mandates a new inventory with slightly different methods.

The CLCPA inventory requirements are included in § 75-0105: Statewide greenhouse gas emissions report.  The regulation states that “No later than two years after the effective date of this article, and each year thereafter, the department shall issue a report on state-wide greenhouse gas emissions, expressed in tons of carbon dioxide equivalents, from all greenhouse gas emission sources in the state, including the relative contribution of each type of greenhouse gas and each type of source to the statewide total”.

There are two methodological differences between the CLCPA inventory requirements and the methodology used for the NYSERDA report.  Firstly, the legislation states “§ 75-0105(3): The statewide greenhouse gas emissions report shall also include an estimate of greenhouse gas emissions associated with the generation of imported electricity and with the extraction and transmission of fossil fuels imported into the state which shall be counted as part of the statewide total.”  Secondly, in the definitions § 75-0101(2) “Carbon dioxide equivalent” is defined as “the amount of carbon dioxide by mass that would produce the same global warming impact as a given mass of another greenhouse gas over an integrated twenty-year time frame after emission”.

I have not quantified how those differences will affect the emissions relative to the NYSERDA report.  The lifecycle approach to the GHG inventory has not been used to date by the agencies to estimate extraction and transmission of fossil fuels emissions.  Presumably this will increase the historical numbers.  I was not familiar with the nuance of global warming impact time frames so did some internet research.  The GHG Management Institute “What is global warming potential and which one do I use?”  states:

The second complication is one that occasionally trips people up. Remember above when we defined GWP by saying “cumulative radiative forcing…integrated over a period of time”? Well, that means that we have to define a time period for the integration to occur. You have to know what the integration period is to make sure you are using the correct GWP. The typical periods that the IPCC has published are 20, 100, and 500 years (the latest report quit publishing values for 500 years).

Now, to be clear, everyone pretty much universally uses 100 year GWP values, so you often never see the time period even cited. It is just assumed you know it is 100 years. But occasionally, someone will use something different, not realizing that they are breaking convention. It is also possible to compute an infinite time horizon GWP value, which would basically mean that accounted for every bit of radiative forcing of every molecule of gas as long as it existed in the atmosphere.

It is notable that this author says: ”everyone pretty much universally uses 100 year GWP values” but the CLCPA uses 20 year values.  In Intergovernmental Panel on Climate Change fifth assessment report Chapter 8 IPCC Table 8.7 GWP and GTP with and without inclusion of climate–carbon feedbacks lists GWP values for methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and carbon tetrafluoride but not sulfur hexafluoride which is a listed chemical in the CLCPA.  The 20 year GWP is greater than the 100 year GWP for methane, hydrofluorocarbons, and perfluorocarbons.

Emissions Targets

The CLCPA specifies reductions in the future from 1990 emission levels per “§ 75-0105(5): The statewide greenhouse gas emissions report shall also include an estimate of what the statewide greenhouse gas emissions level was in 1990”.  As noted above these levels will have to be re-calculated using the CLCPA methodology but we can get an idea what is needed by looking at the NYSERDA inventory.

The CLCPA GHG Emissions Targets 2016 Update table presents the emissions status for the 2030 CLCPA target to reduce GHG emissions 40% from the 1990 level and the 2050 CLCPA target to reduce GHG emissions 85% from the 1990 level.  According to the NYSERDA methodology 1990 GHG emissions were 236.2 million metric tons of CO2e. The 2030 target limit is 94.5 million metric tons and in 2016, the last year of the NYSERDA inventory, NYS emissions were 205.6 million metric tons.  Therefore, in order to meet the CLCPA target in 2030 another 63.9 million metric tons have to be reduced.  By 2050 emissions have to be reduced 170.2 million metric tons from 2016 levels.

Conclusion

This post specifies the CLCPA emission targets for future reference.  Originally, I was going to develop these numbers and combine them with the observed cost efficiency for existing NYS GHG emission reduction investments to estimate the potential cost of the program but there are other things to look at too.  For example, New York state reduced GHG emissions 30.6 million metric tons in the 26 years between 1990 and 2016 but has to reduce them another 63.9 million metric tons in 14 years to meet the 2030 CLCPA target.   That deserves analysis and its own post. Rather than a huge post covering all the aspects of these numbers I will prepare shorter posts on each aspect that reference these numbers.  Stay tuned.

New York Accelerated Renewable Energy Growth and Community Benefit Act

Updated March 1, 2020 to clarify and correct typographical errors.

In February 21, 2020 New York governor Andrew Cuomo proposed a 30-day budget amendment that will “streamline the process for environmentally responsible and cost-effective siting of large-scale renewable energy projects across the state”. The proposed legislation, if adopted, will create a new Office of Renewable Energy Permitting to streamline the consenting process for large-scale projects across New York.  This post addresses this latest hypocritical over-reach of the Cuomo Administration.

Permitting Process

New York’s Environmental Conservation Law requires NY regulatory agencies to consider environmental impacts equally with social and economic factors when making permitting decisions and that they must balance those factors when making a decision to approve an action.  New York has different rules for different sized projects.  For any electric generating facility greater than 25 MW in capacity the permitting requirements are specified in Article 10.  The Power NY Act of 2011 established the process for siting generating facilities in Article 10.  That law established a multi-agency siting board and was supposed to streamline the permitting process.  Unfortunately, its requirements are so strict that it is still unwieldy and cumbersome.

As on February 25, 2020 there are 49 projects under permitting review in the active Article 10 queue   and five projects have been certified. There are 16 wind facilities proposed with 899 turbines generating 3,117 MW.  There are 25 solar projects proposed for 3,914 MW of capacity and 4 solar projects with storage proposed for 740 MW of capacity covering at least 11,324 acres.  There also are three gas-fired projects and one waste energy project.  Since the new requirements were established only five projects have been approved with two completed in 3.2 years, two completed in 3.5 years and one in 4.5 years.

The governor’s office said the state’s existing process for energy-generating sites was designed for plants that used fossil fuels and created before new clean-energy standards were put in place.  The existing Article 10 process is cumbersome but the insinuation that only fossil fuel facilities have significant enough environmental, social and economic impacts to warrant a complete review of the potential impacts is a stretch in my opinion.

Cuomo’s Environmental Impact Hypocrisy

There is no better illustration of the Cuomo’s administration hypocrisy than the decision to block the Finger Lakes LPG project.  On July 12, 2018, New York State Department of Environmental Conservation (NYSDEC) Commissioner Basil Seggos issued a decision for a proposal to construct and operate a new underground liquefied petroleum gas (LPG) storage facility for the storage and distribution of propane in the town of Reading in the Finger Lakes region of New York.  The decision denied the permit applications for the proposed project on the grounds the facility would have a significant adverse impact on community character in the local area and the Finger Lakes region.  In my post on that decision I pointed out that the community character rationale was based on the State Environmental Quality Review Act section: “impacts to noise and aesthetic resources as revealed on the current record are essential components in the evaluation of impacts on community character in the context of this proposed project”.

So how did the Finger Lakes LPG project affect community character? The project proposed modifications during the application process to reduce the scale and environmental impacts of the project in response to local stakeholder concerns.  The modifications eliminated the proposal to store liquid butane at the facility and reduced the underground propane storage capacity from 2.1 million barrels to 1.5 million barrels; eliminated the project’s rail and truck loading facilities so all deliveries of liquefied petroleum gas would be by pipeline; eliminated one of the brine ponds; and, for lack of a better term offered bribes as they proposed to “provide resources ranging from financial resources to technical resources (mining data) to support community initiatives for the preservation and improvement of water quality in the area, including Seneca Lake”.  The unacceptable aesthetic community character of final proposed plan of the Finger Lake LPG Storage project was a brine pond, a compressor station, and a support building.  The unacceptable noise community character of the project was two electric 75 horse power pumps to pump product from the tanks into the pipeline to the electronically driven injection pumps despite the likely use of insulated walls and advanced fan technology to dampen sound.

It is unclear how an Administration that claimed that Finger Lake LPG Storage project’s minimal aesthetic and noise projected impacts affected community character so badly that the project could not be permitted but can somehow claim that industrial wind and solar project don’t also affect community character.  As noted, there are at least 899 wind turbines and solar panels covering at least 11,324 acres in the existing permitting queue.  Consider, for example, the aesthetic impact of the Ball Hill Windpark.  This facility has been approved (note that it was not permitted under Article 10) to install 29 wind turbines generating around 100 MW with 13 miles of access roads, 5.7 miles of above-ground utility lines, a substation, a switchyard and an operations and maintenance building.  According to the 2018 Proposed Modifications Summary of Environmental Impacts wind turbines will be visible in 33.9% of the area within the 5-mile viewshed.  According to the 2008 Environmental Assessment Form the smaller turbines originally proposed would be visible from greater than 5 miles from a parcel of land which is “dedicated to and available to the public for the use, enjoyment and appreciation of natural or man-made scenic qualities” and “an overlook or parcel of land dedicated to public observation, enjoyment and appreciation of natural or man-made scenic qualities”, and a “site or structure listed on the National or State Registers of Historic Places” and between ½ and 3 miles to a State Wildlife Management Area.

 Environmental Protection

Cuomo is quoted as saying: “Climate change is the existential challenge of our time, and New York State has risen to the occasion by enacting the strongest laws in the nation to protect and preserve our environment” It is utter hypocrisy to claim to protect and preserve our environment while simultaneously proposing to circumvent the permitting process that “Requires environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws”.

As far as I can tell the State Administrative Procedure Act (SAPA) and the State Environmental Quality Review Act (SEQRA) requirements for environmental reviews do not apply to the Climate Leadership and Community Protection Act (CLCPA).  One of the requirements of an air quality assessment for a new fossil-fired electric generating unit is to consider the cumulative impact of all local emitting sources as well as the new source itself.  While I think that while an individual industrial wind facility or solar facility Article 10 application analysis may conclude there isn’t a significant environmental impact the cumulative impact of all the facilities required by the CLCPA to provide enough power to meet the reliability needs of the state will likely have significant environmental impacts.  I don’t think it is fair to ask each renewable energy developer to consider cumulative impacts but I also don’t think that cumulative impacts can be ignored.

The obvious solution would be for the state to evaluate cumulative impacts.  Note, however, that the first step for such an analysis would be to determine how many wind turbines and solar panels would be required and where they would be located.  The CLCPA is just starting the process to prepare a scoping plan that will document the state’s plan to implement the law.  First problem is that scoping plan won’t be available for a couple of years.  In the meantime, I have prepared my own estimate of the renewable resources necessary to meet this legislation.  In order to meet the mandate that all electricity will be generated by non-emitting sources in 2040 and provide enough power to cover the needs of an example winter peak period I estimate that New York will require 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind.  If the on-shore wind turbines are rated at 4.8 MW that mean that over 3,845 on-shore wind turbines.  Using numbers from one of the solar permit applications, I estimate that 176 square miles will be needed to meet the 16,117 MW of utility scale solar estimate.  The bottom line is that while an individual industrial wind facility or solar facility may not have a significant environmental impact the cumulative impact of 176 square miles of utility-scale solar panels and at least, 3,845 on-shore wind turbines certainly could have negative environmental impacts.  I also determined that for a fifteen-hour period from January 3, 2018 at 1600 until January 4, 2018 at 0600 there was a storage deficit totaling 134,545 MWh which would require energy storage which also needs to be considered in a cumulative environment impact analysis.

Conclusion

The Niagara County Legislature recently passed four resolutions directed squarely at an amendment to revise the Article 10 rules.  The amended rules only said that if there were minor changes to the proposed facility it did not require the entire application process to be opened up again.  In other words, it was a relatively innocuous change as opposed to the Governor’s plan to entirely ignore the Article 10 process.  Niagara County and other Upstate New York municipalities are already upset that Article 10 has taken away control of local siting decisions.  This proposal to remove the checks and balances included in Article 10 will not be appreciated.

The CLCPA is all style and no substance.  There is no plan to convert all energy sectors away from fossil fuels only a mandate to do it.  If there is no plan then there are no costs, no quantified benefits, and no starting point to balance environmental impacts with social and economic factors for the state as a whole.  The Article 10 permitting process requires that kind of assessment on the local level.  Cuomo’s proposal to remove that check would mean that anyone, anywhere in New York State that could possibly be affected by anything related to the ambitious plan to convert the New York energy to carbon-free resources will have no recourse.  I suspect that when the folks who whined their way to get the Finger Lakes LPG project cancelled are going to be more than a little upset when industrial wind and solar facilities blanket their community.

NYSERDA Toward a Clean Energy Future – A Strategic Outlook 2020-2023

Alicia Barton, President & CEO of the New York State Energy Research & Development Authority (NYSERDA) recently announced the release of NYSERDA’s 2020-2023 Strategic Outlook which is their overview of their plans for the next several years.  This is important because the plan to implement the aspirational Climate Leadership and Community Protection Act (CLCPA) is supposed to be developed in this timeframe and NYSERDA staff will undoubtedly play an important role in that effort.  This post provides an overview of this report and costs.  Subsequent posts will address NYSERDA’s missions in more detail.

Background

On February 11, 2020 the following email was sent from NYSERDA.

Last year was a landmark year for climate action in New York. Governor Cuomo’s nation-leading Green New Deal and the signing of the New York State Climate Leadership and Community Protection Act (CLCPA) have put us at the forefront in lowering carbon emissions and advance a clean energy future with a just and equitable transition that is addressing the most pressing issue of our time – climate change.

Building on the momentum of our accomplishments, New York State is on the path to achieving a carbon free electricity system by 2040, an 85 percent reduction in greenhouse gas emissions by 2050, and ultimately a carbon-neutral economy, touching on all sectors including transportation, buildings and industrial production. With climate action featured prominently in Governor Cuomo’s annual State of the State and Executive Budget addresses this year, NYSERDA’s work to combat climate change, preserve the environment, and grow the green economy is more important than ever before.

I am therefore excited to share NYSERDA’s 2020-2023 Strategic Outlook, which presents our key objectives and strategic focus areas while placing them into the broader context of New York’s long-term energy policies and market landscape. The report highlights our increasing efforts to support New York’s energy transformation through decarbonization of transportation, energy affordability and equity, electrification of buildings, and building a resilient energy system in support of NYSERDA’s five mission outcomes:

            • Greenhouse Gas Emissions Reduction
            • Renewable Energy
            • Energy Efficiency
            • A Distributed and Resilient Energy System
            • Building a Clean Energy Economy.

I hope you will take the time to review the Strategic Outlook and understand we cannot be successful in accelerating action to meet the needs of a changing energy landscape without participation from stakeholders like you. Together we will seize the opportunity to make Governor Cuomo’s vision for a clean energy future a reality.

Message from President and CEO

The strategic outlook report includes an introductory message from the President.  According to this message the rationale for action on climate change “reached new heights during the September 2019 Climate Week, with the youth movement and climate strikes in New York City and across the nation driving home the urgency and importance of addressing one of the most pressing matters of our time.”  Color me unimpressed.  According to this children and activists are responsible for setting New York policy.  What could possibly go wrong?

Funding Commitments

At the top of my list of issues for this regulation is costs which, by the way, is not usually a concern of children and activists.  According to the document: “Several funding sources help NYSERDA advance the State’s clean energy goals and achieve the Authority’s mission. NYSERDA invests these funds in a fiscally responsible manner that maximizes benefits to New Yorkers, fills critical gaps, and addresses the needs of the market.”

Per the document there are four funding mechanisms.

Clean Energy Fund

Authorized by the Public Service Commission (PSC) and derived from an assessment on retail sales of electricity by State utilities — it is comprised of four portfolios: Market Development, Innovation and Research, NY-Sun, and NY Green Bank.

Clean Energy Standard

As authorized by the PSC, these funds are realized by NYSERDA through the sale of Tier 1 Renewable Energy Credits (RECs), Offshore Wind Renewable Energy Credits (ORECs), and Zero Emission Credits (ZECs) as well as receipt of Alternative Compliance Payments from New York’s Load Serving Entities (LSEs). Through PSC orders, LSEs are obligated to meet annual compliance obligations for RECs, ORECs and ZECs. As needed, utility financial backstop collections may be called upon to meet funding shortfalls.

Regional Greenhouse Gas Initiative (RGGI)

Derived from sale of carbon emission allowances as set forth in 6 NYCRR Part 242 and 21 NYCRR Part 507.  The amount of revenues available is dependent on the variable auction prices for the allowances. Per requirements in 21 NYCRR 507, RGGI funds are used to advance energy efficiency, renewable energy, and carbon abatement projects in New York State.

Other Funds

Includes sources provided by various sponsors used for specific purposes. Public funds are leveraged considerably with private sector funding through NYSERDA programs.

For the first time that I have been able to find, the State admits how much some of this might cost.  The NYSERDA Strategic Outlook Anticipated Commitments (April 1, 2020 – March 31, 2023) table states that the total 3-year investment level cost is $14,255,988,000.  Importantly, this is not the entire cost just the cost of the State’s programs to fill critical gaps and address the needs of the market.

The Clean Energy Fund is the largest source of funding.  It is “derived from an assessment on retail sales of electricity by State utilities” which means that the ratepayers are on the hook for the $4.75 billion annual costs.  If all that funding were new charges to the utility bills and my guesses how it should be apportioned, then the average cost per residential customer is on the order of $200 per month for electricity and $200 for gas.  The state should provide that number but note the utility companies have been forbidden to show those numbers in their bills.  Make no mistake however, increases in utility rate cases undoubtedly include these added costs.

Although NYSERDA claims that they invest these funds in a fiscally responsible manner that maximizes benefits to New Yorkers their results to date do not auger well for the cost to implement the CLCPA.  The State has started to do the scoping study to determine how to meet the emission reduction targets, but that won’t be available for three years.  In the meantime, I have evaluated the cost effectiveness of New York’s CO2 investments using the New York Clean Energy Dashboard and NYSERDA’s RGGI-Funded Programs Status Report – Semiannual Report through December 31, 2018.  As shown on the table of anticipated commitments I expect that the CO2 reduction benefit will only be 44,669,559 tons based on the results of those programs to date.  More importantly, there are few indications that these investments will be fiscally responsible because most investment programs described in the investment reports do not meet the social cost of carbon[1] cost effectiveness threshold.

One last item of note is that the priority initiative for energy storage is funded at just under $160 million.  In my table I did not claim any expected reduction in CO2 emissions because energy storage does not directly displace fossil fuel emissions.  On the other hand, energy storage is absolutely needed to backup renewable wind and solar when the wind does not blow at night. When someone claims that wind and solar costs are comparable to a new gas-fired power plant they ignore the added costs necessary to get power to your home whenever you need it.  That requires energy storage and those costs will be enormous.  In particular, for the period 2040 to 2050 I found the energy storage necessary to cover the wind and solar deficit when the wind was not blowing at night for the example period of January 3-4 2018 was a staggering $176.3 billion.

[1] The Social Cost of Carbon is supposed to represent the future cost impact to society of a ton of CO2 emitted today.  Therefore, it is entirely fair to use it as a metric to determine if the investments made from carbon pricing income are cost effectively reducing CO2.  I believe New York will base their carbon pricing on a $50 global social cost of carbon at a 3% discount rate so that is the cost benefit effectiveness threshold metric I use.

 

NYSERDA RGGI-Funded Program Results

The New York State Energy Research and Development Authority (NYSERDA) report New York’s RGGI-Funded Programs Status Report – Semiannual Report through December 31, 2018 (“Status Report”) describes how New York invested the proceeds from the RGGI auctions.  I previously described the report by summarizing the results by sector.  This post provides results by program.

Background

The Regional Greenhouse Gas Initiative (RGGI) is ten years old and has been touted as a successful example of a “cap and dividend” pollution control program.  New York State has been involved in the program since its inception and touts its success.  I have written extensively on the results and have shown that in fact its successes have been limited.   For example, the fundamental assumption for any carbon pricing program is that the proceeds can be invested effectively.  However, the observed results for New York’s experience in RGGI suggests that this may not be the case.

The Social Cost of Carbon (SCC) is supposed to represent the future cost impact to society of a ton of CO2 emitted today.  It is a policy tool that attaches a price tag to the long-term economic damage caused by one ton of carbon dioxide, hence the cost to society.  It was extensively by the Obama Administration to justify the Clean Power Plan, has been proposed for use in the New York Independent System Operator carbon pricing initiative and is included in New York’s Climate Leadership and Community Protection Act.  In that law § 75-0113. Value of carbon, states that

      1. No later than one year after the effective date of this article, the department, in consultation with the New York state energy research and development authority, shall establish a social cost of carbon for use by state agencies, expressed in terms of dollars per ton of carbon dioxide equivalent.
      2. The social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions. As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero.
      3. In developing the social cost of carbon, the department shall consider prior or existing estimates of the social cost of carbon issued or adopted by the federal government, appropriate international bodies, or other appropriate and reputable scientific organizations.

Therefore, it is entirely fair to use it as a metric to determine if the investments made from carbon pricing income are cost effectively reducing CO2.  I believe New York will base their carbon pricing on a $50 global social cost of carbon at a 3% discount rate so that is the cost benefit effectiveness threshold metric I will use.

NYSERDA RGGI Program Status

The key table in the Status Report is Table 2 Summary of Expected Cumulative Annualized Program Benefits through 31 December 2018.  It provides costs, energy savings, electricity savings or renewable energy production, greenhouse gas emission savings and the calculated cost benefit ratio.  The $/ton reduced metric is presented on an annual basis and as expected lifetime savings.  For the purpose of this post I use the annual numbers because all the reduction targets are based on an historic annual level (usually 1990).  In order to have an appropriate comparison it has to be annual to annual.

The NYSERDA RGGI Status Report Table 2 – Ranked Cost Benefit Ratio Datatable lists all the programs in the NYSERDA report ranked by the annual cost benefit ratio with just that parameter.  It lists 19 programs with associated CO2 reduction benefits and another 18 programs with no claimed CO2 reductions.  None of the 19 programs with CO2 reduction benefits meets the $50 SCC metric for cost effective investments.  Clearly the 18 programs with no claimed reductions would not be able to meet the metric either.

I prepared a brief summary overview of each of the programs in NYSERDA RGGI Program Cost Effectiveness  After reading the report and summarizing them for the overview I am not impressed and in fact I question the results.  The most cost-effective program, Multifamily Performance Program Assessments in the Green Jobs Green New York sector, had a cost effectiveness value of $58/Ton CO2e.  The program provides financing and co-funding for comprehensive energy assessments and the development of an Energy Reduction Plan, serving market-rate and low- to moderate-income residential buildings with five or more units to increase adoption of clean energy in NYS. Accomplishments.  According to the summary table, they managed to do a total of 316 assessments through December 2018 that resulted in 61,795 residential units served with installed measures for a cost of $3.3 million in “total incentives” and another $1.4 million in “total associated costs”.  Summing the incentives and associated costs and dividing by the 61,795 residential units yields $76.06 per unit.  The summary indicates that this is the cost the comprehensive energy assessment and development of a reduction plan and that rate per unit is reasonable.  But this also means that the actual costs to implement the energy reduction are not included.  So how did NYSERDA claim any CO2 reduction benefits and what are the chances that the actual CO2 reductions were double-counted?

There is another concern. A quick perusal of the programs listed with no reduction benefits demonstrates justifiable cynicism of yet another government program controlled by politicians.  The programs range from practical to clear pork barrel.  New York wants to be able to track emissions from generation sources within the State and from imported sources to create “tradable generation attribute certificates”.  Rather than fund this through the general fund it is easy to justify this as a necessary expense for these funds.  The research projects are another segment of funding where there is a justifiable rationale for funding projects that have no reduction benefits short-term because they could lead to long-term reductions.  At the extreme of clearly unjustified funding is the Brookhaven National Laboratory Ion Collider.  I have no idea the tortured logic that was used to justify spending any RGGI funds on this.

Conclusion

Advocates for carbon pricing schemes assume that the investments from the proceeds are worthwhile.  I think these results and the results from New York’s Clean Energy Dashboard demonstrate that is not the case.  The Regulatory Analysis Project (RAP) study: Economic Benefits and Energy Savings through Low-Cost Carbon Management notes that “Many advocates of carbon pricing begin with the proposition that the main point is to charge for carbon emissions “appropriately” and that carbon reductions will surely follow in the most efficient manner. While carbon pricing is a useful tool in the fight against climate change, there is now substantial experience to suggest that wise use of the resulting carbon revenues is equally important, or even more important, if the goal is to actually reduce emissions at the lowest reasonable cost.”

The other concern is the cost of the New York program relative to the social cost of carbon. The NYSERDA RGGI Status Report does not include a single program that reduces carbon dioxide more cost efficiently than $50 per ton.  Because I have shown that eliminating New York CO2 emissions that would provide a reduction, or a “savings,” of approximately 0.0026°C by the year 2050 and 0.0054°C by the year 2100.  Because you cannot measure that small a temperature difference there will be no tangible benefit of the CLCPA.

My primary concern with New York’s clean energy mandates is the cost.  If the cost is small then signaling New York’s virtue might have value. According to the Clean Energy Dashboard, New York has invested $1,051,359,837 through the third quarter of 2019 but can only claim 3,057,131 tons of reductions giving a CO2 invesment efficiency of $343.90 per ton of CO2 equivalent reduced.

It is not clear how advocates of these programs can justify the costs given these results.  The cost efficiency does not even approach the supposed appropriate cost of carbon dioxide and the there is no tangible expected change to global warming.

CLCPA Implementation Part 1

In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In one of the first implementation tasks the New York State Department of Environmental Conservation (DEC) has started the process to calculate a statewide Greenhouse Gas emissions (GHG) limit for this law.  This post addresses that rulemaking.

DEC Rulemaking

DEC recently released a stakeholder draft for their statewide greenhouse gas emission limit rule.  This barebone draft lists six gases that will be considered in the inventory and lists potential economic sectors that might be covered.  As part of this process DEC announced a webinar for February 14 and again on February 28 to provide the public the opportunity to learn and ask questions about the rulemaking.  During the first webinar DEC said that they would post a recording of the webinar.  If you are unfamiliar with New York’s rulemaking process the webinar provided a good summary.

Existing New York GHG Inventory

The New York State Energy Research & Development Authority (NYSERDA) works with DEC to prepare an annual inventory of GHG emissions.  The most recent report, Greenhouse Gas Inventory 1990-2016 contains a detailed inventory of historical greenhouse gas emission data from 1990-2016 for New York State’s energy and non-energy sectors.  I have been involved with all aspects of emissions inventories from developing emission factors, using inventories for air quality modeling, to preparing reports for regulatory agencies over my entire career.  I can assure you that this is a non-trivial task.  Although I have some quibbles with the NYSERDA numbers I believe that it represents New York’s emissions adequately for all purposes.

CLCPA Inventory Requirement

The CLCPA requires a report on GHG emissions, § 75-0105: Statewide greenhouse gas emissions report.  The regulation states that “No later than two years after the effective date of this article, and each year thereafter, the department shall issue a report on state-wide greenhouse gas emissions, expressed in tons of carbon dioxide equivalents, from all greenhouse gas emission sources in the state, including the relative contribution of each type of greenhouse gas and each type of source to the statewide total”.  The law specifies reductions in the future from 1990 emission levels so this section includes “§ 75-0105(5): The statewide greenhouse gas emissions report shall also include an estimate of what the statewide greenhouse gas emissions level was in 1990”.  DEC is interpreting this legislation to mean that they have to implement a new regulation that codifies the GHG emission inventory process.

It is not clear to me how much difference there is between the CLCPA inventory requirements and the methodology used for the NYSERDA report with one exception.  In particular, the legislation states that “§ 75-0105(3): The statewide greenhouse gas emissions report shall also include an estimate of greenhouse gas emissions associated with the generation of imported electricity and with the extraction and transmission of fossil fuels imported into the state which shall be counted as part of the statewide total.”  NYSERDA does not try to estimate extraction and transmission of fossil fuels emissions.

Lawmaking without Technical Expertise

I have no experience lobbying politicians to influence legislation and, frankly, have no desire to do so.  If I had been involved in this instance, I would have said that the legislation should specify the use of the NYSERDA inventory.  It has all the numbers you need, no development is necessary, and represents GHG emissions well.  Unfortunately, someone, somewhere convinced somebody to include the requirement for “an estimate of greenhouse gas emissions associated with the generation of imported electricity and with the extraction and transmission of fossil fuels imported into the state”.  At a minimum this component will have to be added to the NYSERDA inventory.  I do not know what else, if anything, DEC has deemed to be incompatible between the CLCPA law and the existing NYSERDA inventory.

As a numbers guy, I oppose including extraction and transmission emissions because the uncertainty bounds on the extraction and transmission values are large today and much worse for 1990.  In 1990 coal and oil generation was much higher than today and it is not clear to me how you could figure out the source and methodology used to extract the fuel.  The fuel specification data needed to estimate that information has been purged from company records, not only because it was so long ago but also because most of the companies who operated the 1990 facilities no longer own them.

Because including the extraction and transmission provision was a political decision, it is appropriate to discuss possible motives with the caveat that this has never been considered a skill of mine.  Clearly, including these numbers will increase the 1990 baseline and current emissions.  Note that the language says transmission and not transportation.  Coal and oil in New York are transported but natural gas is transmitted.  Therefore, my guess is that it was included by someone who wanted to make natural gas look bad by showing higher emissions.

Conclusion

The extraction and transmission emissions requirement has unintended consequences.  NY has a perfectly good emissions inventory but that provision means a lot of work has to be done to include those emissions. And DEC has no choice but to try to follow the requirements of the legislation.  As I noted above emissions inventories are difficult under any circumstances but when handicapped by requirements to adjust the numbers for ulterior motives the result is going to be significant effort for very little tangible benefit.

If it is correct that the extraction and transmission provisions were included by anti-natural gas advocates then I have to laugh.  I am convinced that the New York State anti-natural gas position is only supportable if the numbers are ignored or mis-understood and this is a vivid example.  In particular, the addition of extraction and transmission emissions to the 1990 baseline is going to show a larger relative decrease for coal and oil than natural gas.  Extracting coal has to be more GHG intensive than drilling and fracking a natural gas well.  Transporting the coal by rail or oil by pipeline to a refinery and then residual oil by ship or train to the power plants have much larger emissions than a natural gas pipeline to a power plant.  Worse still for the individuals who got this included is the fact that the higher baseline means that % reduction limits will also be higher.  In other words the CO2 limits will be higher so more CO2 can be emitted.