Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public can comment until June 10, 2022.
The overall question for the speakers was whether the state can meet its energy needs under the new law and what will be the cost to New Yorkers? Six speakers made brief presentations followed by questions and answers addressing those questions. I have described my impressions of the speaker presentations below. If a recording of the meeting is provided, I will update this post.
Introductory remarks
James Hanley, Senior Policy Analyst, Empire Center for Public Policy gave some brief introductory remarks but focused on his new research. Hanley recently completed an analysis he did for the Empire Center titled Cold and Dark? New York’s Risky Energy Future. It is a good summary of the essential problem that the Climate Act will increase demand at the same time New York is retiring existing nuclear and natural gas-fired generation. He shows that the state is on track for an energy shortage equal to “almost three New York Cities without power”. He explains that wind and solar cannot make up the gap because of their variable output. The Draft Scoping Plan notes that 15 to 25 GW of installed dispatchable emissions-free generation capacity is “needed in 2040 to meet demand and maintain reliability”. However, as Hanley points out, the Plan does not identify a source for this generation capacity. The report is well-researched and gives a good overview of the problems inherent in the net-zero transition.
Panel Discussion: Meeting New York’s Energy Needs Under Climate Act.
Three speakers addressed the question: How do we deliver what’s needed and how soon can we get there?
Donald Chahbazpour, Director of Policy and Regulator Strategy, National Grid talked up the National Grid plan that was recently announced. He explained that there are three components of their plan: energy efficiency, hybrid heat pumps, and a fossil free gas network. Among the benefits expected are that it is more cost-effective and will require 60 GW less electric generation capacity. At some point I will try to do a post on the plan but want to point out a couple of points he made about the natural gas system. The gas peak load is 3 to 4 times higher than the size of the electric peak load. That makes sense because heating makes up such a large proportion of natural gas load. He also said that heating with natural gas is cheaper: thirty cents on the dollar cheaper than electric with natural gas. Part of the National Grid plan is to use renewable natural gas and he admitted that will be more expensive than natural gas. The last statistic that I wanted to mention is that he gave a number for the daily conversion rates necessary to meet the Scoping Plan for just New York City. I did not get the exact number but it was so large that it was clearly unreasonable.
Gavin Donohue, President of the Independent Power Producers of New York is a member of the Climate Action Council. He said his top issue with Climate Act was that there was no funding mechanism. He also made the point that there is no dispatchable emissions-free resource available today so the schedule is ambitious. Gavin has been arguing since the beginning that reliability is critical but he pointed out that it still has not received adequate attention. He made another point that is often overlooked. New York City has special considerations that have not been addressed. He claimed that one hidden cost is that 25% of homes will require electric service upgrades. Donohue also made the point that the Climate Action Council does not make the final decision on the strategies. At the end of the year the Scoping Plan goes to the Governor and legislature for them to pick policies for implementation in 2023.
Ken Pokalsky, Vice President of the Business Council of New York, was the third speaker on the panel. He pointed out that most business owners are unaware of implications. When told about it they go through the five stages of grief: denial, anger, bargaining, depression, and acceptance. He explained that New York businesses are finally starting to get involved.
Panel Discussion: Consumer Effects Of Climate Act;
The second panel discussion addressed costs, benefits and consumer impacts. Due to a scheduling problem, there were only two speakers.
Michael Butler, Mid-Atlantic Regional Director of the Consumer Energy Alliance discussed consumer effects. His presentation is available. He made the point that the reason that emissions have gone down so much is because of natural gas. Therefore, he argued that it is inappropriate to ban natural gas at this time. He also commented on Pennsylvania’s recently joining the Regional Greenhouse Gas Initiative by executive decree. He thinks that the Pennsylvania governorship will flip Republican next election and that will end the state’s membership in RGGI
Commissioner John Howard, New York State Public Service Commission, made some interesting points and his answers to questions were very illuminating. If there is a recording, I will do a post just on his remarks. One of the great mysteries to me has been how this will affect rate payer costs. He said that he thought the existing REC, ZEC, OREC programs and possibly some other similar programs currently add 10% to consumer bills. He emphasized the four tenets of Public Service Commission concern are safe, reliable, just and reasonable electricity for all rate payers. He noted that New Yorkers are intolerant of blackouts for any reason. After claiming that peaking power plants have significant health impact, he said he thought that they would be needed much longer than many want. By the way I am working on a post about that issue to follow up my latest post describing the New York City peaking power plant controversy. One of his best comments was that he said that unelected bureaucrats should not be in control of the scoping plan. He clearly he has figured out that there are issues with the ambition and schedule of the Plan.
I asked the penultimate question.
We have heard a lot about costs today and the large number of pages in the scoping plan and appendices. I am a numbers guy and want to point out that in addition of the upwards of 600 pages in the text documentation there are two spreadsheets with over 100 tables provided. Based on my analysis of those spreadsheets there are no control measure cost numbers provided. I think the Scoping Plan should describe, list the costs, and estimate the emissions reductions for all the control measures. What do you think should be provided?
Commissioner Howard responded. He basically said that it does seem that they are obfuscating the costs. He also said that people should be outraged that those numbers are not available.
Conclusion
Unfortunately, attendance was light so there was not a lot of coverage. That is too bad because the speakers made some excellent points that deserve wider coverage. If a recording is provided I will update this post with more information.
The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. I recently used my pragmatic environmentalist principles to show that there are very few aspects of the Climate Act that represent a pragmatic approach to climate change mitigation. I recently read an article about green hydrogen that described it as a process that is technically feasible, but highly undesirable. I am going to add the description of that type of process to my list of pragmatic principles.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. Unfortunately, I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.
My primary concern is that the Climate Act over-simplifies the problem and the solution. There are serious challenges for the transition to a zero-carbon grid that have not been adequately addressed by the Draft Scoping Plan. In my opinion the biggest issue is intermittency of wind and solar. In order to address those times when the wind is not blowing at night, for example, energy storage is required. The ultimate problem is that there are multi-day renewable resource drought periods when the wind resource is low and, especially in the winter, solar resources also can be reduced. It is especially concerning because those periods can coincide with the highest expected future loads after homes and cars are electrified. In order to help meet these requirements a generating type called Dispatchable Emission-Free Resource (DEFR) has been identified. The Draft Scoping Plan proposes the use of “green hydrogen”, that is to say produced by wind and solar hydrolysis, as a placeholder for this technology.
Green Hydrogen Swindle
A recent article in the Telegraph by Andrew Orlowski describes the United Kingdom’s hydrogen initiatives and the issues surrounding the use of hydrogen as has been proposed there. The introduction described a principle that I hadn’t heard before, “Kicking a dead whale down the beach”:
Engineers will rarely tell you something is impossible, even when your proposal is a very bad idea. Computer scientists at Stanford and MIT in the 1970s came up with a wonderful expression for this, an assignment that was technically feasible, but highly undesirable. They called it “kicking a dead whale down a beach”. The folklore compendium The Hacker’s Dictionary defines this as a “slow, difficult, and disgusting process”. Yes, you can do it like that. But you really don’t want to.
The article continues on to describe two big problems with hydrogen that turn any project into a dead whale exercise.
The first is that pure hydrogen doesn’t exist – it’s both everywhere and nowhere. We must generate all the hydrogen we can then use, and this requires a lot of energy. This is fine when the output of the process is something very valuable to us, such as fertiliser. But less so when the output of the process must compete with much cheaper commodities, as it must in an energy market.
Secondly, hydrogen’s intrinsic physical properties create a whole range of unique problems. It’s a tiny atom that easily escapes confinement. Keeping it captive for storage is expensive, and moving it around safely even more so, because in liquid form it must be very cold.
Hydrogen advocates tend to shrug off these issues – solving them will be someone else’s problem, they reckon. Individually, none of these factors make hydrogen as an energy carrier or storer impossible, but the whale-like properties are becoming harder to ignore.
The rest of the article is a highly recommended summary of the many issues that make a hydrogen economy technically feasible but highly undesirable.
Conclusion
All of the issues that are being raised in the United Kingdom related to the hydrogen economy envisioned there will inevitably also come up in New York as the Climate Act transition unfolds. Orlowski describes our fate well:
The “dead whale on the beach” principle is a great example of pragmatic environmentalism. Just because a so-called solution is technically feasible it may not be desirable for a whole host of reasons.
This post describes the comments submitted on the Draft Scoping Plan by Herschel Specter. If I knew how to do guest posts on this site, I would have made this a guest post. My apologies but I am going to have to wing it.
Herschel Specter is the President of Micro-Utilities, Inc. and holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the New York. He is a passionate supporter of nuclear power. While I don’t agree with everything in his comments there are many great points. I asked Herschel if I could make his comment letter into a post and he agreed. The following text is from his cover letter. I have posted his comments here.
Overall Conclusions
(A) The largest challenge facing the CAC and NY State is to regain the confidence of the people of New York that its energy plan is fact-based, technically agnostic and sound, and is forward looking, free of any past political or ideological influences. The Scoping Plan does not convey such confidence-building characteristics, and
(B) The scoping plan fails to implement the Community Protection (CP) portion of the Climate Leadership and Community Protection Act (CLCPA), detailed below. Even if this NYSERDA scoping plan could work, what good is it if most people cannot afford the electricity this scheme would produce, and,
(C) The claim in Section 3.1 of the scoping plan that NY State is a leader in dealing with climate change is unsupported by the facts. For years NY State has favored imported fracked gas over building renewable energy infrastructure, while also opposing further expansion of clean nuclear power. (See Appendix C, page 43, of the attached critique). It is not convincing that NY is a leader in climate change when a major state agency, NYISO, recently reported that the State, and especially New York City, face dangerous shortages this decade in electricity generation and in electricity transmission. (See Reference 2 of the attached critique).
Specific Comments
1.High Costs. Electricity is a critical commodity, but its cost is regressive. High electricity prices disproportionately burden LIM (low income-to-middle income) families. The scoping plan places near exclusive reliance on renewable energy (solar and wind). Yet other studies have shown a mix of variable energy sources (solar and wind) joined with firm energy sources (nuclear and/or fossil fuels with no net carbon) are far less expensive. In one study a mix of energy sources reduced the electricity costs of a proposed all renewable electricity future from 15 cents/kilowatt hour to 9 cents per kilowatt hour. (See Table A4, page 20, of the attached critique). NYSERDA should have investigated which combinations of variable and firm energy sources are the least burdensome for low and middle income families. High electricity costs can cause businesses to relocate outside of New York, causing job losses.
2.Jobs-1. How many jobs will actually be created in New York when developing offshore wind capacity compared to jobs outside of New York? The Empire Wind Project is instructive. Two huge oil companies, British Petroleum (UK) and Equinor (Norway), have secured a contract from NY State to build the Empire Wind Project. Not being in the wind turbine business, these oil companies turned to Vestas, a Danish wind turbine company, to build a huge (600 to 700 feet tall) wind turbine off of NYC. This assumes that the conditions of the Jones Act can be met. British Petroleum and Equinor recently filed a request with the Federal Energy Regulatory Commission for a one and a half year delay. Delays do not produce jobs. Importing wind turbines produces jobs, overseas.
3. Jobs-2. It takes a special type of ship, called a jack ship, to lift the very heavy offshore wind turbine hub (the nacelle) and football field length turbine blades into place while at sea. New York does not make or own such jack ships. There is only one jack ship under construction, for a different state in the USA, large enough to install the huge 15 MW Vestas design. This specialized ship has a cost of $500 million dollars and requires three years to construct. However China makes such huge specialized ships with the latest one deployed off of the east coast of England. It takes an enormous crane to lift the nacelle and turbine blades. New York does not manufacture such huge cranes, but many overseas companies do. What is the NYSERDA plan to install these very large offshore wind turbines? How many MWs/year can be installed considering the limited number of jack ships? Per NY taxpayer dollar, how many pennies go to New York workers to build and install this mammoth offshore project and how much money goes out of state?
4.Jobs-3/ land use. According to the Daily News [“State reaffirms Alle-Catt wind farm”, Matt Surtel, September 30,2020] the 30,000 acre Alle-Cat wind farm will employ 182 jobs during construction, but this will decrease to just 13 permanent jobs to operate the facility. At that rate, a million acres of onshore wind farms would only create 400 permanent jobs, less than half the number of jobs lost when Indian Point was closed. This 340 megawatt wind farm will need 125 times the area of the Indian Point site to produce less than 5% of the electricity that was generated at Indian Point.
5.Public anger-1 Upstate communities have taken NY State to court because they were stripped of Home Rule protection while solar and wind farms are being imposed on them. This hardly seems like implementing the Community Protection portion of the CLCPA. Fishermen off of Long Island are similarly aggravated with the State’s offshore wind program and complain of being ignored by the State. Where is consent-based siting? About 1,000 high paying jobs were lost, as well as substantial tax revenue, as a result of NY State’s actions to press for the closure of Indian Point nuclear plants and replace these two nuclear units with gas. Citizens of New York have not forgotten that they were told by former Governor Andrew Cuomo that Indian Point would be replaced by non-carbon sources. That never happened. Such actions are not confidence building. After years of reducing the carbon intensity per KWh of NY’s electricity, it is on the rise again because clean electricity from Indian Point was replaced by gas. The price for electricity and home heating and making hot water with gas has skyrocketed. This is partly due to world conditions, but as newspapers in the Hudson Valley point out, it is also due to the closure of Indian Point which did not burn fossil fuels, but rather produced 80% of the carbon-free electricity in downstate New York..
6. Public anger-2 The Danskammer plant in Newburgh, NY, originally was an old coal burning plant that was shutdown. It was refurbished to run on gas, but a special regional surtax on people was set up to pay for this refurbishment. If the people are paying for new gas infrastructure, why don’t they own this gas infrastructure? Moreover, people were told that this refurbished plant would only be used infrequently; during times of peak demand. Later there was an effort to allow Danskammer to run full time, which angered local people, many of whom live in nearby environmental justice areas. Thanks to Governor Hochul and the DEC, this expansion of Danskammer use was not permitted, nor was a large new gas plant in Astoria, Queens approved. But as NYISO makes clear, this compounds the dangerous electricity reliability issue. No State agency has come forward with a plausible plan to provide clean electricity while reducing greenhouse gases in a time frame that would avert the potential blackouts this decade that NYISO has warned about. How does NY State simultaneously deal with climate change and continue to meet reliability requirements using realistic renewable energy manufacturing and installation capacities? This emerging crisis NYISO identified would not be pending if the Indian Point units were still operating.
7. Still more public anger-3. It appears that the CPV gas plant has been allowed to operate without all required permits and this plant has EJ areas nearby. If this lack of all necessary permits is still true, the DEC should require full compliance or shut CPV down.
8. Security issues. Increased use of natural gas for electricity production, home heating, and in making hot water has prompted gas delivery utilities to seek additional pipeline infrastructure. The former Governor was opposed to this, which led to open conflict between the former Governor and these gas utilities. This has been temporarily resolved by allowing some gas to be delivered by trucks, even though pipelines are safer and less expensive. This compromise has created a new class of terrorist targets; “truck bombs” that drive on our neighborhood streets.
9. Land use. In order to implement the NYSERDA scoping plan an estimated 24.4 million solar panels, each 25 square meters in size, would be needed. (See page 43 of the critique). A “rule of thumb” published in recent solar literature is that each megawatt of solar energy capacity requires about ten acres of land. At that rate it would take about 950 square miles. of New York farm and forest lands to accommodate this massive solar buildout. What will be the reaction of upstate New Yorkers to such a huge expansion? Yet solar energy is the least attractive choice for dealing with climate change. It is inherently less resilient to climate change than firm energy sources (See section 6.3 of the attached critique) It has the lowest capacity factor of any clean energy source, around 14%, as reported by NYISO, while nuclear is over 90%. Without expensive storage It is not dispatchable and is incapable of reducing the peak demand in winter which occurs after sunset. As NY State moves towards being a winter peaking state, this winter limitation of solar energy becomes an even larger negative attribute. Further, such extensive reliance on solar energy furthers upstate/ downstate friction. Upstate people are to make sacrifices in values they hold dear, such as not being a victim of renewable energy industrialization in their back yard, just to provide electricity to downstate areas and NY City. NYSERDA should clearly and completely discuss the future use of present upstate nuclear plants which many upstate people support, particularly since their land use per KW hour is far less than renewable energy sources and jobs at these units pay well..
Land use is a highly charged subject. Not only is it an issue in upstate NY, it shows up everywhere. For example, people in White Plains recently rejected the installation of solar panels in a cemetery because doing so would have required the cutting down of a large stand of trees. The two nuclear units at Indian Point supplied enough clean electricity to power 25% of the electricity in New York City and Westchester County, yet their land use was less than one half of one square mile.
10.Data errors. The NYSERDA plan has serious data errors in the capacity factors it used (See Section 8 of the attachment) . These data errors, collectively, would produce a capacity shortfall are almost the size of the whole NY State present electricity capacity.
11. Modeling errors. In 2021 an estimated 702 people died and almost $200 billion dollars worth of damage occurred in Texas when there was a gap in the supply of electricity during a polar vortex. Two things are happening simultaneously which call for a careful analysis of what is needed to design a NY future electric grid. We will experience extreme temperatures, hot and cold, more frequently and for longer durations. Also, we are moving towards a more electrified future we are far more dependent on electricity.. When there is an electricity gap during a time of extreme heat or cold, people may die. It appears that the NYSERDA draft plan is not based on preventing an energy gap during extreme conditions like a polar vortex or very high statewide temperatures, but is just designed to meet the typical energy needs during a week of cold weather in January, 2050. (See Section 9.2 of the attachment). To prevent loss of lives the grid should be designed to cope with extreme temperatures, with an additional margin for unanticipated losses of generation and transmission. Further, NYSERDA did not account for very large and long duration wind lulls like that which occurred last year over all of northern England (See Reference 6 in the attached critique). There are other modeling errors identified in the attachment, as well as very questionable assumptions about the rate renewable energy devices, like offshore wind turbines, can be built and installed.
12. Energy storage. Unlike nuclear plantswhere energy storage is built right into the uranium pellets in the fuel rods, renewable energy needs energy storage because of its variability and for times when the sun is not shining and/or the wind is not blowing. Unlike other New York energy future studies which relied on Renewable Natural Gas, an undeveloped technology, NYSERDA turned to hydrogen for energy storage. It is hard to imagine a more difficult material to work with. Because of its very small molecular size, hydrogen has a much higher propensity than natural gas to leak out of piping and storage systems. Hydrogen leakage is important from a safety point of view; hydrogen has an ignition range six times wider than what natural gas has. (See TABLE A-8 of the attached critique.)
The volumetric energy density of hydrogen is very low. In order to achieve economically attractive volumetric energy densities, hydrogen would either have to be compressed to pressures in the 10,000 to 15,000 PSI (pounds per square inch) range or cooled to minus 253 degrees C, which is approaching absolute zero. Because of the required very high pressures, hydrogen cannot be distributed through the present natural gas piping or used in present gas storage infrastructure. It takes a significant amount of energy to cool hydrogen down to an extremely low temperature and to maintain this very low temperature. Hydrogen also embrittles steel. How did the NYSERDA plan account for this?
These challenging attributes of hydrogen make it difficult to store or distribute at reasonable costs. In practice, when hydrogen is used in industry, its source and the end user, like a refinery, are co-located on the same site. This co-location minimizes hydrogen storage and distribution issues. The distributed nature of NYSERDA’s energy sources and NYSERDA’s end users greatly limits co-location opportunities. The scoping plan describes a process of using solar energy to make hydrogen from water by electrolysis. This (compressed?) hydrogen would be stored for months then, assumedly, burned in some kind of a hydrogen fueled gas turbine (now under development) or fuel cells to convert the stored hydrogen back into electricity. NYSREDA assigns a 50% round trip energy loss for this process. It is not clear if this includes hydrogen losses through leakage while in storage, or the energy it takes to compress or cool the hydrogen, or the energy losses in the gas turbine. If the source of electricity is solar energy and NYISO’s 14% solar capacity factor is used, the overall efficiency of the solar/hydrogen storage/ burning in gas turbines to get back to electricity would be, at best, about (0.14)((0.50) = 0.07. Would a 7% efficient energy storage system result in a low-cost electricity as needed by LIM families? If it becomes obvious that hydrogen storage is unworkable, what is NYSERDA’s backup storage plan?
About the Author
Herschel Specter, President of Micro-Utilities, Inc., holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the State of New York. At the Atomic Energy Commission in the 1970s he was responsible for the licensing of the Indian Point 3 nuclear power plant. In the 1980s the New York Power Authority hired Mr. Specter to defend its Indian Point 3 nuclear plant in a federal adjudicatory trial. He and his team of experts prevailed in court. Mr. Specter served at diplomat rank for 5 years at the International Atomic Energy Agency in Vienna, Austria where he led an international effort writing design safety standards for nuclear power plants.
Mr. Specter has been Chairman of two national committees on nuclear power plant emergency planning and was a guest lecturer for several years on emergency planning at Harvard’s School of Public Health. He analyzed emergency responses for a hypothetical terrorist attack on the Indian Point power plants which were located in the nation’s highest population density area. Mr. Specter has presented testimony at the National Academy of Sciences on the Fukushima accident and on other nuclear safety matters and has been a guest speaker at many universities on matters of energy policy.Today he is one of 14 Topic Directors in Our Energy Policy Foundation, a group of about 1500 energy professionals who seek to bring unbiased and comprehensive energy information to our political leaders and members of the public.
Mr. Specter has been active in social and environmental matters. He has been a Big Brother and in 1971 had the honor of being selected as “Big Brother of the Year” for all of the USA and Canada. While voluntarily serving as President of Big Brothers of Washington, D.C., the number of boys the agency helped was doubled. He also received a personal letter of commendation from the President of the United States for his work with the Youth Conservation Corps.
Mr. Specter was born in White Plains, NY and lives there now.
The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 but is anything but a pragmatic approach. Everyone wants to do right by the environment to the extent that they can afford and not be unduly burdened by the effects of environmental policies. Similarly, there certainly is a risk associated with climate change that popular opinion wants to address. This post highlights a couple of recent articles that I believe should be incorporated into a pragmatic alternative to the Climate Act.
I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
As shown in the following overview summary. the Climate Act establishes a “Net Zero” target by 2050, various renewable energy mandates, a social equity component, and, of particular concern to me, a requirement for zero-carbon electricity by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that describes the strategies to achieve the mandates. It was released for public comment on December 30, 2021, and comments on the draft can be submitted until June 10, 2022.
Alternate Climate Change Policies
My Citizens Guide to the Climate Act is intended to be a layman summary of the difficulties of a net-zero transition. I have posted articles recommending books that do a much better job than I have done to explain the problems here and here. Unfortunately reading a book is a big commitment and recently I described an article, Inconvenient Truths About Energy, that describes most of the issues that worry me. In brief, the consensus of all the authors of these recommendations argue that New York’s plans will cost a lot, hurt the world’s poor, and fail to fix the issues.
This post highlights two articles that are consistent with what I think would constitute a pragmatic approach to climate change. In “A ‘Plan B’ for addressing climate change and the energy transition” Judith Curry describes problems with all net-zero energy transition programs. On March 10, 2022 Doomberg published “A Serious Proposal on US Energy” that described four energy priorities.
Plan B
Judith Curry’s article describes the popular narrative that there is a climate change crisis and sums up the problem with the Climate Act and all net-zero energy transition programs:
“In a nutshell, we’ve vastly oversimplified both the problem of climate change and its solutions. The complexity, uncertainty, and ambiguity of the existing knowledge about climate change is being kept away from the policy and public debates. The dangers of manmade climate change have been confounded with natural weather and climate variability. The solutions that have been proposed for rapidly eliminating fossil fuels are technologically and politically infeasible on a global scale.”
She continues the discussion of the current state of the science and makes another important point that argues for a more pragmatic approach to potential climate change impacts. The Intergovernmental Panel on Climate Change (IPCC) modeling “projections neglect plausible scenarios of natural climate variability, which are acknowledged to dominate regional climate variability on interannual to multidecadal time scales”. Natural climate variability accounts for most of impacts of the extreme weather events that “prove” the need for immediate action. Ultimately “emissions reductions will do little to improve the climate of the 21st century – if you believe the climate models, most of the impacts of emissions reductions will be felt in the 22nd century and beyond”. The emotional plea that we have to do something immediately for our children and grandchildren is not supportable.
The article goes on to address the urgency for the energy transition. She defines Plan A as the attempt to reach net-zero in carbon emissions by 2050. It is based on the precautionary principle that “rapidly reducing CO2 emissions is critical for preventing future dangerous warming of the climate”. The Climate Act rationale is that there is a crisis. However, Curry points out:
Note that the IPCC itself does not use the words ‘crisis’, ‘catastrophe’, or even ‘dangerous’; rather it uses the term ‘reasons for concern.’ Apart from the scientific uncertainties, the weakest part of the UN’s argument about manmade global warming is that it is dangerous. The highest profile link to danger relies on linking warming to worsening extreme weather events, which is a tenuous link at best.
Curry raises another important point:
All other things being equal, everyone would prefer clean over dirty energy. However, all other things are not equal. We need secure, reliable, and economic energy systems for all countries in the world. This includes Africa, which is currently lacking grid electricity in many countries. We need a 21st century infrastructure for our electricity and transportation systems, to support continued and growing prosperity. The urgency of rushing to implement 20th century renewable technologies risks wasting resources on an inadequate energy infrastructure, increasing our vulnerability to weather and climate extremes and harming our environment in new ways.
The article goes on to discuss a Plan B:
The problem is with the urgency of transitioning away from fossil fuels, driven by fears about global warming. By rapidly transitioning to this so-called clean energy economy driven by renewables, we’re taking a big step backwards in human development and prosperity. Nations are coming to grips with their growing over dependence on wind and solar energy. Concerns about not meeting electricity needs this winter are resulting in a near term reliance on coal in Europe and Asia. And we ignore the environmental impacts of mining and toxic waste from solar panels and batteries, and the destruction of raptors by wind turbines and habitats by large-scale solar farms.
She goes on to argue:
Here’s a framework for how we can get to a Plan B. A more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation. Whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.
So what does a Plan B actually look like? Rather than top-down solutions mandated by the UN, Plan B focuses on local solutions that secure the common interest, thus avoiding political gridlock. In addition to reimagining 21st century electricity and transportation systems, progress can be made on a number of fronts related to land use, forest management, agriculture, water resource management, waste management, among many others. Human wellbeing will be improved as a result of these efforts, whether or not climate change turns out to be a huge problem and whether or not we manage to drastically reduce our emissions. Individual countries and states can serve as laboratories for solutions to their local environmental problems and climate-related risks.
A Serious Proposal on US Energy
As good as Dr. Curry’s article is, it is short on specifics for an alternate implementation plan. The Doomberg article provides some specifics. The article proposes four priorities to address the direct connection between energy and economic power. My proposed plan incorporates three of the priorities.
Not so long ago the idea that natural gas could be used a bridge fuel until aspirational technology that had zero emissions but could maintain current reliability standards was generally accepted as a rational approach. Doomberg quotes EQT CEO Toby Rice with what has happened to the natural gas industry: “You’re in a situation today where I think it’s very hard pressed for companies to be incentivized to go out and develop this large-scale infrastructure that this country needs, this world needs because of the regulatory uncertainty and just the pressure we get from anti-fossil fuel, keep-it-in-the-ground groups that are out there.” Doomberg argues that “It is time to put an end to nuisance lawsuits, regulatory inertia, and environmental radicalism” because expanding the use of natural gas provides immediate benefits. “It borders on criminal negligence that much of the Northeast burns oil to heat their homes” New England relies on foreign sources of not only oil but natural gas because of a lack of infrastructure. New York State decisions blocking pipelines have materially contributed to this negligence.
Doomberg’s second priority would expand the production of a crucial component of solar cells:
With the natural gas industry unleashed, the President should make co-located production of polysilicon another national priority. The US blundered into allowing China to secure a dominant position in this critical market, and it is time to reverse that error. Making solar cells is incredibly energy-intensive, and cheap natural gas is the ideal feedstock. There’s going to be huge demand for solar in the decades ahead, and the only thing stopping the US from being the preferred global supplier is a lack of polysilicon production capacity.
The single stupidest New York decision related to zero-emissions energy is the closure of two nuclear stations. The Shoreham plant was completed but closed in 1989 before it operated. Indian Point was closed before its operating license expired removing 2,000 MW of the only zero-emissions capacity that can be expanded at the scale needed for New York’s electric system. The third Doomberg priority proposes a commitment to nuclear power. In particular, “accelerate the development and deployment of small modular reactors (SMRs), which are safer, cheaper, and quicker to bring online than traditional nuclear power plants”.
Finally, Doomberg argues that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead”. The reason: “there simply aren’t enough battery materials available to support the conversion of a substantial portion of our automotive fleet to full electric.” It is ludicrous to not recognize that battery materials are a constraint, and that we must manage to that constraint.
Pragmatic Environmentalist Alternate Plan
The basis of my recommendations is my belief that the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology, that there is little additional risk for a policy that emphasizes innovation over implementation at this time, and that doing “good enough” will address many of the problems that the Climate Act purports to address. In short, my alternate plan would incorporate the natural gas, nuclear, and pivot away from BEV Doomberg priorities. A recent article summarizes my fears that the Climate Act “solutions” are worse than the problem and his alternative priorities are more appropriate.
The ultimate problem with a transition of the electric grid that depends upon intermittent wind and solar generation is that there are extended periods when those resources are low. Electric resource capacity planners have identified the need for a dispatchable emissions-free resource (DEFR) for those periods. Unfortunately, there is nothing available at this time that meets the characteristics needed for that resource.
I recently published an article describing my pragmatic principles as they relate to the Climate Act and I will mention several here. Gresham’s Law of Green Energy shows that reliance on subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth. I recommend a deployment plan that makes wind and solar implementation conditional upon the development of viable DEFR before any further deployment. There is no sense going down that path until the required technology is unavailable. In the meantime, inherent subsidies should be discarded. New York’s electric markets should pay very little for any generating resource that is not dispatchable and discount “semi-dispatchable” resources that cannot guarantee availability during periods of high expected demand. In this approach solar net metering would be eliminated and the subsidies for the Champlain Hudson Express project would be much reduced because power is not guaranteed during the winter.
The Pareto principle or 80-20 rule states that 20% of efforts or inputs can yield 80% of the results or outputs and exemplifies “good enough”. The Doomberg priority that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead” is a great example of the value of that principle. I also believe that going all in for natural gas as suggested by Doomberg should be a priority. New York’s irrational jihad against natural gas is not in the best interests of the state.
One of the problems highlighted in the Draft Scoping Plan is the effects of diesel exhaust on environmental justice communities. The aspirational goal to convert tractor trailer trucks to zero-emissions BEVs is such a great leap forward in technology that it could be years, if ever, before it could be viable. Conversion to PHEV trucks could resolve some of the issues but the development and deployment of compressed natural gas (CNG) trucks is further along. Encouraging CNG trucks and cars would provide immediate reductions in inhalable particulate and ozone ambient concentrations. This is a real problem as opposed to the contrived problems claimed from the use of natural gas that are incorporated into the Climate Act.
There is another viability aspect of the need for DEFR that should be considered. One of my pragmatic principles is that we can do almost anything we want, but we can’t do everything. New York’s reliability experts are worried about the quantity of generating capacity that is needed to meet the 2040 goal of a zero-emissions electric grid in general. However, the fact that recent analyses project that the quantity of DEFR needed is on the order of the entire existing generation capacity raises a financial concern. The only time that DEFR is needed is when there is lull in wind and solar resource availability. When the costs for that high quantity but low-capacity requirement are determined it may be so high that New York will be unable to address other pressing environmental issues.
I believe that existing technology is just not ready to meet the ambitions for a zero-emissions economy embodied in the Climate Act. I concur with Dr. Curry that a “more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation” and that “whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.” My pragmatic approach would make deployment of wind and solar contingent upon the development of a viable DEFR technology. The development of a new and hopefully more viable nuclear generating technology such as small modular reactors should be a priority even if a DEFR solution is found. There are many advantages of natural gas that make it ideal for intermediate and peak load uses on the electrical grid; residential heating, cooking, hot-water, and backup electric generators; and as vehicle fuel. It is not perfect because there are some emissions but when considered on a fair reliability, affordability, and environmental impact basis it deserves to be part of a sustainable solution to minimize overall global impacts and improve human well-being.
I have no illusions that the Climate Act will be modified to incorporate nuclear and natural gas as priorities with the current administration and legislature. However, when the costs are finally publicized to the general public or even worse show up on utility bills, we will see how much New Yorkers are willing to pay for achieving greenhouse gas emission reduction objectives and whether that willingness has limits. I have long maintained that the costs will be too much and that there will be “yellow-vest” protest response.
The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. I recently was given the opportunity to brief my New York State Senator, John Mannion, about my concerns related to affordability and reliability in the Climate Act Draft Scoping Plan. This post describes the slide presentation and provides a link to the documentation handout for it.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.
Presentation
I list the presentation slides below. The documentation summarizes what I said for each slide and provides references for the statements. I highlight some of the key points I tried to make in this description of the slides.
I tried to make the point in the following slide that most New Yorkers are unaware of the Climate Act. Not only that but fewer still understand the scope and magnitude of the changes required in order to meet the Climate Act targets and even fewer are aware of the costs, benefits, and threats to reliability inherent in the massive transition of our existing energy system to the net-zero targets of the Act. The presentation hit the points that I think the public should understand.
In my presentation I explained that I think the root problem of the Scoping Plan approach is over simplification of possible solutions. Reality is that there are many issues with every aspect of the proposed energy transition. I said that there are two particular problems with the proposed solutions: they don’t work all the time and they are more complicated than existing technology. As a result, there are ramifications that need to be considered.
I included this slide to just hit the highlights of the Act. I mentioned that the 100% zero-carbon electricity by 2040 target was a particular worry of mine.
This slide more or less presented the material in the Climate Act Background section above. I did mention that 10 public hearings have been scheduled.
The point of this slide was to point out that the transportation vision requires massive changes to the transportation system and significant limitations on personal choice. I believe that most people recognize that there are limitations to electric vehicles and have decided that they are not a viable option as the primary household vehicle even if they could afford one. The primary limitation that people in Upstate New York understand is that electric vehicles don’t work so well in cold weather. In addition, electric vehicles are more complicated because at-home charging has infrastructure requirements and another daily chore to hook the car up for charging. This is a concern for those of us who have the option to charge at home but what about all those people who park on the street or in a parking lot? Providing infrastructure for them will be very expensive.
In order to prove the Climate Act is in the best interests of the State, the Scoping Plan claims benefits. I explained that I thought that the proposed health benefits were exaggerated, that I have been unable to verify their estimates and that they are all societal benefits that will not directly affect consumer costs.
The largest benefit proposed is for avoided GHG emission impacts on climate change. I estimate that these benefits should be on the order of $60 billion dollars based on eliminating New York’s maximum annual GHG emissions overnight and multiplying by New York’s value of carbon. The Scoping Plan claims benefits of at least $235 to $250 billion by counting the benefits multiple times. This is the same as claiming that a weight loss of ten pounds five years ago represents a 50-pound reduction. Obviously, that is wrong and if that error is corrected the costs are greater than the benefits.
This graph has been shown at public comment hearings and is the support for the Draft Scoping Plan claim that “The cost of inaction exceeds the cost of action by more than $90 billion”. I explained that there were issues with cost numbers in addition to the benefits problems described previously. In particular, it is necessary to parse the language to understand how the Integration Analysis presents the costs. They are presented as net direct costs because the cost to use fossil fuels are subtracted from the costs to meet the reduction targets. The bigger issue is that the net present value of benefits and costs are presented relative to Reference Case. I admit that I did not pick up on the implications of that condition for five months. It turns out that vehicle electrification costs appear to be included in the Reference Case because the electric vehicle legislative mandate was an “implemented policy”. However, the $700 billion costs to electrify the transportation investment category are a necessary cost for the net-zero transition. I don’t think they should be included in the Reference Case because those costs are a necessary transition expense. If those costs are moved from the Reference Case to the mitigation scenarios where they belong, the costs are much greater than the benefits.
I also made the point that this graphic is representative of the abysmal cost documentation in the Scoping Plan. For the most part the only numbers provided are in bar charts like this and none of the cost category values are quantified. This inexcusable shortcoming of the Draft Scoping Plan is the subject of a post which provides more information. I believe that the cost for every category in the Draft Scoping Plan should be listed in a spreadsheet and that costs for each measure that make up the category costs should also be included. Without this information it is impossible to provide meaningful comments on the financial viability of the scenarios.
The following slide explains that corrections to the inaccurate benefits and misleading costs presented in the Scoping Plan invalidate the claim that the benefits are greater than the costs. Approximately $700 billion should be added to the net system costs column in the revised section of the table and the avoided GHG benefits should be only $60 billion. The costs are greater than the benefits by at least $760 billion.
In 2040 the electric grid is supposed to be converted to zero emissions. In order to describe potential reliability issues associated with that transition this slide and the following two slides discuss the electric grid. The point of this slide is that the electric grid is big, complex and currently dependent upon generating resources that can be dispatched by the operators who match load with generation on a minute-by-minute basis.
This slide explains that significant infrastructure is required for the transition and that it will complicate matching generation and load. Wind and solar are not dispatchable without energy storage, transmission and ancillary services resources. I pointed out that short-term variations in wind and solar require an energy storage resources that is relatively small but will be used frequently. The Li-Ion 4-hour storage batteries work well for this requirement. There are significant diurnal variations in renewable resources if solar is a major component. This needs to be addressed by energy storage resources that are on the order of the size of the solar capacity in the system. In my opinion this resource has not been implemented on a commercial scale. In addition, additional energy storage is needed for cloudy days. The resources needed for both these applications will be used regularly. The biggest problem is the energy storage needed for infrequent but extended periods of low wind and solar output. A large amount of long-term storage capacity is needed to cover a multi-day renewable resource drought but it will not be used a lot. If it is not used much how will the market pay for the resource?
If the grid operators cannot match the load with available generation, then blackouts similar to the February 2021 blackouts in Texas are inevitable. The operators task is made more difficult because load is not constant. Ultimately the problem of most concern is that the periods when the renewable resources are lowest are also periods when load is expected to be highest once home heating is electrified. This is an enormously important issue but I don’t think it has received the appropriate level of consideration by the Climate Action Council.
I recently posted an article that highlighted the content (Presentation) and conversations at a NYISO meeting on March 24, 2022 that addressed the System & Resource Outlook Update effort with the Electric System Planning Working Group. I prepared the table that shows the existing capacity, the capacity proposed for the three Draft Scoping Plan scenarios, and the base case for the Update options discussed at the meeting. One of the concerns at this meeting of New York State reliability experts was the amount of new infrastructure needed. The total of new generation required is around three times the 2021 total existing generation. That does not include the ancillary services and transmission upgrades needed. The other concern was the Zero-Carbon Firm Resource. This is the “large amount of long-term capacity needed to cover a multi-day renewable resource drought that it is not used a lot” resource needed when the loads are predicted to be highest in the future. The problem is that there isn’t any commercially demonstrated resource available today or expected for this resource in the near future. The table shows that this resource is need to provided capacity that is greater than current installed capacity. The conversation that caught my attention is when the experts said: The results are “stunning” and “Is anyone listening”. They are clearly worried and the Climate Action Council has shown no sign of concern about this issue.
There is another issue for the Council. Comparing the Draft Scoping Plan capacity resource distributions with the NYISO projected capacity shows significant differences. It is not clear how will those differences will be resolved.
Unfortunately, the Climate Action Council seems to be more concerned about activist claims to stop all new fossil fuel infrastructure than the critical need for a proven replacement. It seems to me that it would be prudent to make the implementation schedule conditional upon the availability of the necessary technology. That Council leadership has not stepped up and said that fossil fuel infrastructure is needed until we have a viable alternative is necessary is not a good sign.
Even though electric grid reliability is an important topic it also it is one that most people don’t have any experience with so I included a description of reliability and affordability related to home electrification that we all understand. Because the buildings sector is the largest source of GHG emissions, decarbonization is a primary strategy. My primary residential reliability concern is what happens when there is an extended electric outage? There is not a lot of information available about the cost affordability for residential home heating so I added slides discussing residential heating sector costs.
The primary solution for residential home heating in the Draft Scoping Plan is heat pumps: “Modern heat pumps that work in very cold weather are commercially available and able to keep homes and businesses comfortable year-round, as long as they are properly chosen, sized, and paired with an energy-efficient building envelope. “ Frankly, everything I have seen on social media from NYSERDA about heat pumps is propaganda because it only shows the benefits and does not mention any downsides. The Plan notes three caveats for success: properly chosen, sized, and paired with an energy efficient building envelope or building shell.
The unmentioned downside is the building shell requirement. The Scoping Plan analysis included two levels: basic shell – 27-44% reductions and deep shell – 57-90% reductions. The Integration Analysis projects that residential building stocks will be 66% basic shell and 26% deep shell by 2050. In my opinion the description of what is required for the two levels is inadequate. I assume that the deep upgrade must meet the international standard for passive buildings that includes following measures: Improved thermal insulation, considerably improved airtightness, use of high quality windows, reduction of thermal bridges, and ventilation with highly efficient heat recovery. In my opinion deep shells will be needed more than the Plan assumes and bringing homes up to that level will be difficult and costly.
The upper half of table in the following slide shows the Retrofit Costs based on the referenced Integration Analysis spreadsheet. According to the device costs in the Draft Scoping Plan an air source heat pump plus electric resistance backup will cost $15,818. The other option is a ground source heat pump and that costs $40,491. The unpublicized costs are $6,409 for a basic building shell improvement or $45,136 for a deep building shell improvement. Combining the two, the air source heat pump option totals $22,227 for the basic shell and $60,954 for the deep shell. For a ground source heat pump the totals range from $40,491 for a basic shell to $79,218 for a deep shell.
The lower half of table subtracts out the replacement costs of the existing system to calculate the retrofit costs. In 2030 when you can no longer purchase anything but a heat pump you won’t have to buy the replacement appliance so you can subtract that cost. For example, if you own a distillate boiler the $9,260 replacement cost can be subtracted from the component costs – an air source heat pump with a basic shell is $12,967 instead of $22,227. As with all other aspects of the implementation there is a complication. In 2030 you will have to replace your existing appliance when it breaks with a heat pump. If it breaks during the winter, you won’t necessarily be able to do a deep shell retrofit at the same time because it is a big investment in time and effort. That will be a serious imposition on the homeowner.
It is also relevant that we keep the context of New York’s emissions relative to the rest of the world vis-à-vis global warming in mind. Although activists claim New York should do something because the state is “large” relative to other countries when it comes to our economy (9th), we should also consider the fact that our emissions are small relative to many others (35th). Moreover, when you consider GHG efficiency (the country’s emissions divided by its GDP) we are already doing a good job -New York ranks third behind only Norway and Sweden.
More importantly, New York’s 2016 GHG emissions were less than one half of one percent of global emissions in 2016 and global emissions are increasing by more than one half of one percent per year. Because global emissions are increasing so much, they will replace all of our emissions completely in about a year. Therefore, I expect no change of global warming effects on weather.
The presentation concluded that everybody wants to do something about climate change and do right by the environment. However, it is important that we don’t do something that will do more harm than good when we try to address climate change. Based on my analysis of the proposed strategies in the Scoping Plan it will do more harm than good. It boils down to the fact that existing technology is just not ready for the magnitude and schedule of the transition outlined in the Scoping Plan.
Recommendations
I did not prepare a slide with my recommendations. I think that politicians worried about the issues raised in this presentation should submit comments to the Climate Action Council but also send a copy to Co-Chairs Doreen Harris and Basil Seggos. The Council has to be made aware that there are real concerns from the public and I encourage public comments to the comment portal.
I suggest comments on a couple of topics. There have been suggestions that the Council will setup workshops on particular issues. I am going to submit a comment that includes a request for full disclosure on particular issues. Too often in the past only one side of the story has been heard. I think the workshops should be used to provide stakeholders with a venue to ask questions and get answers. When the meeting is announced it should offer an opportunity for stakeholder questions to be submitted before hand so that they can be addressed during the workshop. In my opinion workshops on the following topics would be appropriate: how reliability concerns in the electricity sector will be addressed and resolved, cost benefit calculations, residential electrification, and transportation strategies.
I am also going to submit a comment arguing that the Council has to make reliability and affordability a priority. As shown in the presentation it seems prudent that the implementation schedule should be conditional based on the availability of proven technology needed for reliability per experts from NYISO and NYS reliability council. The Council has to make it a priority to listen to the experts who are responsible for New York reliability. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. That is exactly what we will be doing if the Council does not listen to the experts.
I am also going to submit a comment saying that the Draft Scoping Plan cost documentation is inadequate. The cost categories for every cost in every figure in the Scoping Plan should be documented in a spreadsheet that lists the totals, the cost categories within the total,s and the costs for each measure that is included in the cost categories.
The Council should also establish criteria for reliability and affordability. The reliability criteria should define the implementation schedule conditions. They should provide guidelines for the NYISO and NYS Reliability Council definition of acceptable technology such as for the “Zero-carbon firm resources”. For example, technology X has been proven commercially on the scale necessary for New York’s requirements so we can proceed with implementation that requires it. Until a technology is available there has to be a hold on the schedule. Similarly, the Council should define affordability thresholds. For this parameter, the number of service disconnects or percentage of New Yorkers in fuel poverty should not be greater than value X would be appropriate conditions.
Conclusion
I listened to the introduction of one of the public hearings and the overview presentation was mostly an advertisement for the Climate Act. There was no suggestion that there might be issues associated with reliability. The machinations that “prove” that the benefits are greater than the costs indicate that the analysis was done so they claim a pre-determined conclusion. I hope that this overview gives readers a taste of the reasons why I am convinced that without changes the impacts of this so-called solution will be worse than the effects of climate change. Anything we do will be displaced in a year, cost a lot of money and risk catastrophic blackouts.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.
Pragmatic Environmentalist Principles
I put together my principles for pragmatic environmentalism to describe a pragmatic approach to environmental issues. So far, I have listed 13 principles that exemplify pragmatic environmentalism. Five of these principles are my own but the rest have been developed by others. I am going to describe four principles that directly relate to climate change and four that indirectly affect Climate Act implementation in this post. This post will also be used to support an upcoming post on my pragmatic recommendations for the Climate Act.
All four of the relevant principles that directly relate to climate change have been developed by others. The Climate Act does not correctly differentiate between weather and climate. Frequently events that are simply extreme examples of normal weather variation to climate change are used as “proof” that climate change effects are apparent now. The first principle addresses this issue. Dr, Cliff Mass’s Golden Rule of Climate Extremesstates that the more extreme a climate or weather record is, the greater the contribution of natural variability. Dr. Mass explained why this happens in a series of posts on the Pacific Northwest heatwave of 2021. He concluded in his analyses that global warming was responsible for only 1 to 2o F of the observed 30 – 40o F anomaly above normal.
There are two principles related to climate change economics. Gresham’s Law of Green Energy is named after Sir Thomas Gresham, a 16th-century British financier who observed that “bad money drives out the good.” Jonathan Lesser has coined “Gresham’s Law of Green Energy” to describe the green economy. The transition to a zero-emissions energy system relies on green energy subsidies that transfers wealth and does not create wealth. The subsidies or “bad” money take money out of the system that was “good” inasmuch as it was being used productively. In particular, Lesser argues that “subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth”. The second economic principle, Ridley’s Paradox, states that economic damage from man-made ‘climate change’ is illusory whereas damage from man-made ‘policies’ to fight the said change is real. Both principles suggest that issues lie ahead for the Climate Act net-zero transition.
Roger Pielke, Jr’s Iron law of climate simply states that while people are often willing to pay some price for achieving environmental objectives, that willingness has its limits. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. However, at this time this requirement is not being met. There is insufficient information to determine how much New Yorkers will have to pay for achieving the net-zero targets. Consequently, we will have to wait to see how his principle plays out.
I authored one of the four principles that indirectly relate to the Climate Act. It is pretty obvious in industry but I haven’t found anyone who has made the Air Pollution Control Costs point that as air pollution control efficiency increases the control cost per ton goes up exponentially. If we were only trying to reduce our GHG emissions by 50% the costs would be much less than the net-zero 85% reduction combined with 15% sequestration target.
That principle is related to the Pareto Principle or 80-20 rule that states that 20% of efforts or inputs can yield 80% of results or outputs. If the Climate Act did not mandate net-zero, then we could get most of the benefits for the “easy” emission reductions. Accepting that outcome removes most of the affordability and reliability risks associated with the radical transformation of the energy system needed to meet Climate Act targets.
The resources necessary to implement the Climate Act are rationalized as necessary to fight climate change. However, the necessary actions are not considered relative to other environmental and social issues. For example, there are water infrastructure issues across New York that must be addressed before systems break down completely. There are disadvantaged communities that have lead pipes and lead paint in their homes. Advocates have not considered that in order to implement Climate Act initiatives these other environmental issues may not be addressed simply because the resources available are finite per the principle: We can do almost anything we want, but we can’t do everything:
“In a nutshell, we’ve vastly oversimplified both the problem of climate change and its solutions. The complexity, uncertainty, and ambiguity of the existing knowledge about climate change is being kept away from the policy and public debates. The dangers of manmade climate change have been confounded with natural weather and climate variability. The solutions that have been proposed for rapidly eliminating fossil fuels are technologically and politically infeasible on a global scale.”
Conclusion
There are very few aspects of the Climate Act that represent a pragmatic approach to climate change mitigation. The rationale for the Climate Act frequently refers to extreme weather events that are more likely due to natural variability than climate change. The Draft Scoping Plan is littered with glittering generalities that carry conviction without supporting information or reason.
The economics in the Draft Scoping Plan are not pragmatic. The reliance on subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth. The economic damage from man-made ‘climate change’ in New York is illusory whereas damage from the Climate Act ‘policies’ to fight the said change is real. When the costs are finally publicized to the general public, we will see how much New Yorkers are willing to pay for achieving greenhouse gas emission reduction objectives and whether that willingness has limits.
Given that air pollution control efficiency increases the control cost per ton goes up exponentially and that 20% of efforts or inputs can yield 80% of the results or outputs, a more pragmatic approach would be to determine some lower level of “good enough” that will achieve emissions reductions without risking current standards of reliability and affordability. Ultimately, we can do almost anything we want, but we can’t do everything so the enormous commitment to the Climate Act net-zero targets has to be considered relative to other pressing environmental and social problems.
The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. On April 1, 2022 the Department of Environmental Conservation’s Strategic Communications Director for Climate sent an email to the mailing list of people who have signed up to learn about climate news and developments. On the same day I ran across a superb summary entitled Inconvenient Truths About Energy. This post summarizes the Denver Gazette perspective piece by Chris Wright in the context of the Climate Act.
I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.
Climate Action Council Draft Scoping Plan Comments and Toolkit
In 2022, the Climate Action Council is required to finalize the Scoping Plan. At the first Climate Action Council meeting on March 3, 2022 (recording here) the activity plan overview shown below mentioned a plan to rollout communications and educational materials. The email sent on April 1 under the title “Climate Action Council Draft Scoping Plan Comments and Toolkit” is part of the rollout of those materials.
I agree with the letter’s point that encouraging all New Yorkers to review the Draft Scoping Plan and share comments by June 10, 2022 is important and necessary. According to the text:
This email serves as a resource and toolkit on how you can comment and be involved in the process, and to help the Council spread the word and encourage others to weigh in on the Draft Scoping Plan. An overview of the plan for your review and use can be found here. Additional overview slide decks specific to each sector are forthcoming. There are several ways to provide public comments, with oral and written comments receiving equal weight.
1. The Council will be holding 10 public hearings, eight in-person and two virtual, in April and May. Additional information on the public hearings and the option to pre-register for hearings can be found here.
3. Comments can also be sent via U.S. Mail to Attention: Draft Scoping Plan Comments, NYSERDA, 17 Columbia Circle, Albany, NY 12203-6399.
I believe that one of the problems with the Climate Action Council is that they do not recognize the complexity, uncertainty, and ambiguity of the existing knowledge about climate change and naively believe that transitioning to zero-emissions solutions will be simple. In no small part that has been reinforced by the ignoring anyone who does not subscribe to that narrative. I think that the rollout of these communications and educational materials will continue to disregard any inconvenient issues.
The email also notes:
If you would like to request a presentation on the Draft Scoping Plan for your group or organization, please email ClimateAct@dec.ny.gov. Requests will be accommodated based on staffing and scheduling.
If you would like to be more involved in the process and help in our efforts to increase awareness about the Scoping Plan and the state’s overall climate efforts, please see the social media toolkit below, or email haley.viccaro@dec.ny.gov with additional opportunities and/or questions. Spreading the word about this opportunity and increasing awareness of the Climate Act is crucial to the successful implementation of the law.
Unfortunately, there is every indication that the public comment process is intended to simply fulfill the requirement to have a public comment period and not develop information to improve the transition plan. Soliciting help to increase awareness and “spreading the word about this opportunity” suggests that a primary purpose for the communications rollout is propaganda. I doubt very much that the Strategic Communications Director for Climate intends this public awareness campaign to address risks to reliability and affordability.
My Citizens Guide to the Climate Act is intended to be a layman summary of the net-zero transition. I developed it to try to highlight transition risks. I have posted articles recommending books that do a much better job than I have done to explain the problems here and here. Unfortunately reading a book is a big commitment and I have been looking for a more concise description problems with the net-zero transition. I am happy to point out that Inconvenient Truths About Energy describes most of the issues that worry me.
Chris Wright is chairman and CEO of Liberty Energy, a Denver-based hydraulic fracturing company. Much of the material in this is also included in his company’s 2020 ESG report. If the article described here interests you then I recommend that report as well. There is a wealth of more detailed information supporting his assertions there.
The energy transition is not happening. Or not nearly at the pace that everyone believes or wishes. At current rates the “transition” is set to finish in the mid-2600s. The U.N. Rio Convention and subsequent Kyoto Protocol launched the energy transition drive in 1992. Global energy consumption from hydrocarbons has grown massively since then, with market share only declining by four percentage points over the last 30 years from 87% in 1992 to 83% today. I am not celebrating this fact as I have spent years working on energy transition technologies.
Using the latest available data for New York, hydrocarbon market share has decreased from 82% to 71% over the last 30 years.
The energy transition isn’t failing for lack of earnest effort. It is failing because energy is hard, and 3 billion people living in energy poverty are desperate for reliable and scalable energy sources. Meanwhile, 1 billion energy-rich people are resistant to diminishing their standard of living with higher cost and an increasingly unreliable energy diet.
That the energy transition is hard is not recognized by most members of the Climate Action Council.
There is no “climate crisis” either. If there is a term more at odds with the exhaustive literature surveys of the Intergovernmental Panel on Climate Change (IPCC) than “climate crisis,” I have not heard it.
Climate change is a real global challenge that is extensively studied. Unfortunately, the facts and rational dialogue about the myriad tradeoffs aren’t reaching policy makers, the media, or activist groups. Or are they are simply ignoring these inconvenient truths?
For example, we hear endlessly about the rise in frequency and intensity of extreme weather. This narrative is highly effective at scaring people and driving political action. It is also false. The reality is detailed in countless publications and summarized in the IPCC reports. Deaths from extreme weather have plunged over the last century, reaching new all-time lows last year, an outcome to be celebrated. This is not because extreme weather has declined. In fact, extreme weather shows no meaningful trend at all. Deaths from extreme weather events have declined because highly energized, wealthier societies are much better prepared to survive nature’s wrath.
I completely endorse this summary. The 2020 ESG report documents these facts.
Recognizing reality
You are not supposed to say out loud that there is no climate crisis or that the energy transition is proceeding at a glacial pace. These are unfashionable and, to many, offensive facts. But let’s be honest. Energy transition ambitions must recognize reality. Otherwise, poor investment decisions and regulatory frameworks will lead to surging global-energy and food prices. This is exactly what is happening. We are here today in large part because energy transition efforts that previously encompassed solely aggressive support of alternative energy policies, economics be damned, have recently supplemented this strategy with growing efforts to obstruct fossil fuel development. Fossil fuels make the modern world possible.
The real crisis today is an energy crisis. It began to reveal itself last fall with a severe shortage in globally traded Liquified Natural Gas (LNG). The LNG crisis has not abated and it gives Russia’s Vladimir Putin tremendous leverage over Europe. Without Russian gas, the lights in Europe go out. Amid war, public outrage, and intense sanctions, Russian gas flows to Europe remain unchanged. Russian oil exports have continued with minimal interruption. The world can talk tough about sanctioning Russian energy exports, but those exports are vitally needed; hence they continue. Energy security equals national security.
The world energy system, critical to human wellbeing, requires meaningful spare capacity to handle inevitable bumps in the road. In the electricity sector, which represents only 20% of global energy but 40% in wealthy countries, this is called reserve capacity. In the oil market, spare production capacity today is shrinking and concentrated in OPEC nations like Saudi Arabia and the United Arab Emirates. Also, there is a massive global storage network in both surface tanks and underground caverns. In natural gas markets, there are both extensive underground storage reservoirs and typically spare export capacity through pipelines and large industrial LNG export and import facilities.
The last several years have seen this spare capacity whittled away due partly to lower commodity prices and poor corporate returns shrinking the appetite to invest. Excess capacity has also shrunk due to regulatory blockage of critical energy infrastructure like pipelines and export terminals. Roadblocks for well permitting and leasing on federal lands, together with a mass public miseducation campaign on energy and climate alarmism, are also stymieing hydrocarbon development. Investment capital is further constrained by a corporate Environment, Social and Governance (ESG) movement, and divestment campaigns. These factors are shrinking hydrocarbon investment below what it otherwise would be in response to price signals and outlook for supply and demand. The net result is a constrained supply of oil, natural gas, and coal, which means higher prices and greater risk of market dislocations like the one unfolding today.
High energy and food price inflation is the cruelest form of tax on the poor. After a few specific examples, I’ll return to what we should do now to reverse these damaging and deeply inequitable trends.
The Scoping Plan strategies will inevitably impact affordability and reliability and those least able to respond will be affected the most.
In denial about demand
Why does the world today suffer from a severe shortage of LNG? Demand for natural gas has been growing strongly for decades. It provides a much cleaner substitute for coal in electricity production, home heating, and a myriad of industrial and petrochemical uses. Rising displacement of coal by natural gas has been the largest source of GHG emission reductions. Unfortunately, the aforementioned factors have prevented supply from keeping pace with rising demand. Energy shortages drive rapid prices rises and have cascading impacts on everything else. Energy is foundational to everything humans do. Everything.
Perhaps the most critical use of natural gas is nitrogen fertilizer production. Roughly a century ago, two German chemists, both subsequently awarded Nobel Prizes, developed a process to produce nitrogen fertilizer on an industrial scale. Before the Haber-Bosch process innovation, nitrogen content in soil was a major constraint on crop productivity. Existing nitrogen sources from bird guano, manure, and rotating cultivation of pea crops were limited. Today, elimination of natural gas-synthesized nitrogen fertilizer would cut global food production in half.
The now six-months-long LNG crisis translates into a worldwide food crisis as skyrocketing fertilizer prices are cascading into much higher food prices. Wheat prices are already at a record high and will likely head higher as spring plantings suffer from under fertilization.
Global LNG markets are tight because rising demand has outrun the growth in LNG export capacity in the United States, now the largest LNG exporter. We have an abundance of natural gas in the United States. Unfortunately, we have a shortage of pipelines to transport this gas and LNG export terminals, preventing us from relieving the energy crisis in Europe and around the world. These pipeline and export terminal shortages are due in large part to regulatory blockage. The result is that natural gas prices in the United States and Canada are five to ten times lower than in Asia and Europe. This deeply disadvantages consumers and factories (like fertilizer factories) in Europe and Asia that rely on LNG imports to fulfill their needs.
Failed energy policies
Russia’s invasion of Ukraine did not cause today’s energy crisis. Quite the reverse. Today’s energy crisis is likely an important factor in why Russia chose to invade Ukraine now. Europe’s energy situation is both tenuous and highly dependent on Russian imports. Russia is the second-largest oil and natural gas producer after the United States. Russia is the largest exporter of natural gas, supplying over 40% of Europe’s total demand. Additionally, Russia is the largest source of imported oil and coal to Europe. Europe put itself in this unenviable position by pursuing unrealistic, politically-driven policies attempting to rapidly transition its energy sources to combat climate change. Europe’s energy pivot has been a massive failure on all fronts: higher energy costs, grave energy insecurity, and negligible climate impacts.
New York’s unrealistic, politically-driven Climate Act policies attempting to rapidly transition our energy sources to combat climate change will inevitably follow Europe’s massive failure on all fronts: higher energy costs, grave energy insecurity, and negligible climate impacts
Germany is the poster child of this failure. In 2000, Germany set out to decarbonize its energy system, spending hundreds of billions of dollars on this effort over the last 20 years. Germany only marginally reduced its dependence on hydrocarbons from 84% in 2000 to 78% today. The United States matched this 6% decline in hydrocarbon market share from 86% in 2000 to 80% today. Unlike in the US, Germany more than doubled its electricity prices — before the recent massive additional price increases — by creating a second electric grid. This second grid is comprised of massive wind and solar electric generating sources that only deliver 20% of nameplate capacity on average, and often less than 5% for days at a time. The sun doesn’t always shine and the wind doesn’t always blow. Hence, Germany could only shrink legacy coal, gas and nuclear capacity by 15%. It now must pay to maintain both grids. The legacy grid must always be flexing up and down in a wildly inefficient manner to keep the lights on, hospitals functioning, homes heated, and factories powered. Outside of the electricity sector, Germany’s energy system is largely unchanged. It has long had high taxes on gasoline and diesel for transportation, and lower energy taxes on industry. Germany subsidizes industrial energy prices attempting to avoid the near-complete deindustrialization that the UK has suffered due to expensive energy policies across the board.
If the Climate Action Council ignores the requirements for reliable and affordable in Public Service Chapter 48, Article 4 § 66-p. Establishment of a renewable energy program then the result will be same here.
Over the last 20 years, the United States has seen two shale revolutions, first in natural gas and then in oil. The net result has been the U.S. producing greater total energy than consumed in 2019 and 2020 for the first time since the 1950s. The U.S. went from the largest importer of natural gas to the second-largest exporter in less than fifteen years, all with private capital and innovation. The shale revolution lowered domestic and global energy prices due to surging growth in U.S. production. Surging US propane exports are reducing the cost and raising the availability of clean cooking and heating fuels for those in dire energy poverty still burning wood, dung, and agricultural waste to cook their daily meals. U.S. GHG emissions also plunged to the lowest level on a per capita basis since 1960. Imagine the world’s energy situation today with the American shale revolution.
We are starting to hamstring and squander the enormous benefits of the shale revolution. The same misinformed anti-hydrocarbon crusade that impoverished Europe and made it heavily dependent on Russia is now sweeping the US. California and New England had already adopted European-style energy policies driving up electricity prices, reducing grid reliability, and driving manufacturing and other energy-intensive, blue-collar jobs out of their states. Colorado is not far behind.
This article ignores New York but the Liberty ESG 2020 report calls out New York’s irrational war on hydrocarbons.
California, a state with a plentitude of blessings, managed to create the highest adjusted poverty rate in the nation with an expensive, unstable power grid increasingly reliant on coal-powered electricity imports from Nevada and Utah.
New England’s proximity to Pennsylvania’s clean low-cost natural gas resources was a stroke of luck. But it refused to expand the natural gas pipelines running from Pennsylvania, leaving it chronically short of natural gas, its largest source of electricity and cleanest option for home heating. Instead, it remains heavily reliant on fuel oil for home heating and occasionally imports LNG from Russia to keep the lights on. Last winter New England burned copious amounts of fuel oil to produce electricity which went out of fashion in the 1970s elsewhere in the US.
New York’s pipeline policies have also contributed to this absurd situation.
Texas has not been immune from energy illiteracy and collateral damage. Texas’ poorly designed electric grid, structured to encourage investment in renewables, led to hundreds dying last year in the Uri cold spell. No one would pay the same price for an Uber that showed up whenever convenient for the driver and dropped you off wherever they desired. But that is what Texas does with electricity: paying the same price for reliable electricity that balances the grid as they do for unreliable, unpredictable electricity. No wonder the reliability of the Texas grid has declined and is headed for more trouble.
Misplaced faith
The common thread in these cases is unrealistic beliefs in how rapidly new energy systems can replace demand for hydrocarbons, currently at all-time highs. Political intervention and miscalculation have led to over-investment in unreliable energy sources and, far worse, under-investment in reliable energy sources and infrastructure. The full costs of this colossal malinvestment have been somewhat hidden from view as spare capacity in the global energy network has mostly kept the train on the tracks. Now that excess capacity has shrunk to a critically low level, more impacts are hitting home.
New York’s environmental community fully subscribes to the naïve belief that today’s wind, solar, and energy storage technologies are capable of rapidly replacing hydrocarbons and are advocating for legislation to accelerate the transition requirements in the Climate Act.
Like the disease itself, the cure takes years to run its course. But that longer time frame is no excuse not to act now in a thoughtful fashion to begin rectifying historical blunders. Steel, cement, plastics and fertilizer are the four building blocks of the modern world and all are highly reliant on hydrocarbons.
Most critically this means removing the growing myriad obstacles to hydrocarbon development, justified in the name of fighting climate change. This is nonsense. Overly cumbersome hurdles to hydrocarbon development in the U.S. do nothing to change oil and gas demand. They simply displace U.S. production overseas where production practices are less stringent and less ethical. Resulting in increased GHG emissions and other air pollutants, reduced economic opportunities for Americans, and increased geopolitical leverage of Russia and OPEC — see the invasion of Ukraine.
Climate change is a long-term problem best addressed with technologies cost-effective today like natural gas, energy efficiency, and nuclear. The solution requires combining today’s commercial low-carbon energy sources with research and technology development in carbon sequestration, next-generation geothermal, and economical energy storage to make solar and wind more viable.
New York’s policies that prematurely eliminate nuclear and natural gas technologies that have markedly reduced air pollution and environmental impacts for unproven solar, wind, and energy storage technologies is analogous to jumping out of a perfectly good airplane without a parachute hoping that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing.
Today the price mechanism must destroy energy demand to bring it in line with short-term supply. This reduces the quality of living, especially for low-income families. The price mechanism will also incent new supply to the extent possible in the face of growing regulatory hurdles, infrastructure shortages, and capital starvation. A revaluation of all three of these factors is urgently needed. Is the overarching goal “energy transition” at all costs? Or is it humane policies that better human lives and expand opportunities for all? We need to replace the former mindset with the latter.
New York has the lowest per capita energy usage in the US so the low-hanging fruit for energy demand reductions are gone. New York’s ban on hydraulic fracking ensures that we cannot control the price of new supply. The inevitable result will be higher costs for low-income families.
Conclusion
Unfortunately, the belief that climate change is an existential threat has become a matter of religious dogma for many and no rational arguments can dissuade them from that belief. I fear that the unrelenting propaganda that we can ban hydrocarbons and get an energy system that is greener and cheaper is leading to a similar dogmatic position. Those emotional beliefs have brought us to the precipice of the Climate Act where costs will skyrocket and dangerous impacts to reliability are likely. However, all the evidence suggests that the supporters of net-zero transition programs haven’t thought they would have to pay much for it, or alter their own lifestyles. An honest communications rollout would explain that lifestyle changes are needed and that there are affordability and reliability risks. It would also quantify the expected effect of the Climate Act on climate change so that New York’s citizens could have the opportunity to provide comments based on all information.
I am not optimistic that will happen. Stay tuned to this space because I am working on my own overview presentation of the Climate Act’s risks to reliability and affordability. Needless to say it will very likely differ in tone and content from the State’s version.
Pragmatic Environmentalist of New York 