Category: Climate Act Scoping Plan

Climate Act Draft Scoping Plan Transportation Sector Scenarios

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

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until July 1, 2022.

Integration Analysis Reference Case and Scenarios

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

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

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

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

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

Electric Vehicles

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

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

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

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

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

EV Charging

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

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

Light-Duty Vehicle Costs

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

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

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

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

Conclusion

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

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

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

Guest Post Core Error of Climate Movement

This post describes the comments submitted on the Draft Scoping Plan by David L. Dibble. 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.

David L. Dibble is a retired engineer and technical consultant who has read my blog material.  He sent the comment below in this weekend.  He took the approach of directly exposing the core error of the entire climate movement, as he sees it.

Dibble Comment

In Chapter 10, Figure 12, the NPV of assumed GHG benefits ranges from $235 billion to $250 billion in 2020 dollars.  From Chapter 3, the “value of carbon” being used in this analysis is $121 per ton of CO2.  All such claims of GHG benefits are based on an incomplete and therefore misleading concept of what non-condensing GHGs are capable of doing in the atmosphere.  These claims are therefore entirely speculative, and are based on inadequate and unsound attribution of a reported warming trend to emissions of GHGs.  This error is compounded by unsound attribution of storm and flood events to warming from GHGs.  Therefore, the claimed net benefits are not reliable for such an important matter of state policy.

To address this core error, I refer to the publicly available images and animations for the NOAA geostationary satellite “GOES-EAST”.  Please see the link below, which is for Band 16 (the “CO2″ band”) and animates the most recent 8-hour series of visualizations of radiance data for the full disk (i.e. the full view of the planet.)  The resolution is 2 km.  Band 16 is centered at 13.3 microns wavelength in the infrared spectrum, which is the same band of wavelengths from which concerns about the GHG “heat-trapping” effect have arisen for CO2.  To convert radiance values into colors, a brightness temperature scale is used.  The radiance (i.e. the strength of the longwave emission being detected in the imaging sensor) at 50C on the color scale is 13 times the radiance at -90C on the scale. (This was determined from the equations and constants in the user manual.  I can provide details on request.)

So when viewed this way, it becomes clear that the concept of the atmosphere as a passive “trap” in respect to the absorption and emission of infrared energy by CO2 and other GHGs is incomplete.  Rather, the planet is directly observed as a huge array of highly variable emitter elements.  The motion and the resulting variation in time, location, and altitude are readily seen.  The formation and dissipation of clouds as a lot to do with this, and convective weather is especially powerful in the tropics.   The end result is that it is all highly self-regulating as heat energy is transported from the equator to the poles and from the surface to high altitude for longwave radiation to be more easily emitted to space. In concept, it is the performance of the atmosphere as the compressible working fluid of its own heat engine operation that overwhelms the static GHG warming effect arising from the emission and absorption of infrared energy experienced at the surface, looking toward space.  Put the working fluid into motion, and one grasps that heat energy cannot reasonably be expected to accumulate at the surface to harmful effect by what GHGs do in the atmosphere.  Rather, the incrementally stronger radiative coupling of the lower atmosphere to the surface simply makes it easier for energy to be transferred to the working fluid of the heat engine to be circulated in three dimensions.

The IPCC attributes recent warming to GHGs based on large-grid, discrete-layer, step-iterated, parameter-tuned computer simulations of atmospheric motion which inherently cannot produce a realistic output – not even close!  The crude modeling of clouds is one reason for this, and the inability to directly compute the physics of convective weather is another.  Therefore, these models have no diagnostic or predictive authority at all concerning GHGs.  But we can “watch” the real outputs of the planet’s emitter array from space using the most up-to-date imaging and data processing capabilities.  And we can trust that the atmosphere is the perfectly authentic model of its own performance as a heat engine to produce the motion.

I would be glad to discuss this with NYSERDA or anyone reading this comment.  I realize perfectly well that this goes against the climate beliefs held firmly by many in government and academic roles.  Those beliefs are based on a misconception.  So please watch the animation and think through the implications.

My Observations

I agree with Dibble that clouds are a primary reason why the projected climate change estimates cannot be correct.  In his book “Unsettled: What Climate Science Tells Us, What It Doesn’t, and Why It Matters” Dr. Steven Koonin explains this issue as follows:

The ultimate problem with the climate modeling is that it cannot simulate clouds.  In order to solve the physical equations in a global climate the world has to be divided up into a three-dimensional grid.  The equations are calculated for each grid cell and repeated to generate a forecast.  My particular problem is that the grid cell size needed in order to do these calculations are on the order of 100 km horizontally, the vertical height is often 1 km and they do the calculations every 30 minutes or so.  As a result, the models cannot simulate clouds.  Instead the climate modelers develop parameters to project the effect of global warming on clouds.  That single parametrization is a big enough driver of climate that this model component alone could dominate the GCM projections.  This uncertainty is well understood in climate science by those who have worked with these models.  However, the problems with parameterization is not well understood and its ramifications on the policy decisions is poorly understood by most of those who advocate eliminating fossil fuel use.

Unfortunately, New York State only invokes “science” when it is consistent with their pre-conceived notions.  As a result, the points made by Dibble and Koonin will likely be ignored.

Climate Act Draft Scoping Plan Building Sector Scenarios

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

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.

Integration Analysis Reference Case and Scenarios

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates in December 2021.  The primary reference for the scenario descriptions is Appendix G Section I: Techno-Economic Analysis (Section I).  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)” (Section I p.11). The initial analysis found that the Advisory Panel recommendations in Scenario 1 did not meet the Act emissions limits (Figure 1).

The consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   The three mitigation scenarios are described in Section I on page 14.  This article describes the building sector actions.

The Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions table lists specific programs in the Reference Case.  The entire description of the contents of this information in Appendix G text is: “Scenario assumptions and level of transformation by sector and action for mitigation scenarios 2, 3, and 4 are summarized in the tables below.”  The lack of documentation makes it difficult to provide meaningful comments.

Table 1 extracts assumption data from that spreadsheet so that the Reference Case and four scenarios can be compared.  The table lists data for four categories of energy efficiency and electrification.  Note that I have added some numbers from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet Space Heating-Res tables.  There are some slight differences between those tables and the Scenario Definitions table which could be because the table lists data for all buildings and I am only using the data for residences because that is my primary interest.

New Sales of Heat Pumps

The primary difference for new heat pump sales for the scenarios is the ramp rate.  Note that according to this modeling that the rate of heat pump sales for the Reference Case stays at 4% through 2030 in the table and until 2050 in the Reference Case Space Heating-Res table.  If heat pumps are all that they are cracked up to be then shouldn’t the rate of adoption be higher in the business-as- usual case?  As it is it seems to confirm that heat pump adoption cannot stand on its own. 

Scenarios 3 and 4 accelerate the deployment of heat pumps in 2030 by mandating early retirement of existing furnaces instead of waiting until their end of useful life.  It is easy to include this in a framework but there are at least a couple of implementation issues.  What criteria would be used to determine who would get stuck with the added expense for premature retirements?   Shouldn’t the affected owners get an additional subsidy to cover their costs?

The final condition in this category combines multi-family/commercial sales.  These numbers are not listed together anywhere in the Space Heating-Res tables.  Moreover, in 2030 none of the commercial or multi-family residential building sub-sectors are 100% so there is an inconsistency between the Space Heating-Res tables and Scenario Definitions table.

Mix of Heat Pump Technologies

I believe that this category represents the mix of heat pump technologies sold.  Another problem with the residential heating documentation is that the types of heating technology are not the same across all the different tables.  For example, the table that lists device costs provides values for four kinds of heat pumps (air source, hybrid oil electric heat pump, hybrid gas electric heat pump, and ground source heat pump).  The Space Heating-Res tables add ductless air source heat pump.  Unfortunately, for Scenarios 2-4 the ductless air source heat pump is the most common type of heat pump sold in the modeling results.  It was not my understanding that the ductless air source heat pumps were the primary choice for air source heat pumps.  Instead, I thought that the plan was to replace an existing furnace with an air source heat pump furnace.  The lack of documentation makes it impossible to determine the intent of the Integration Analysis modeling.

The biggest difference between mitigation Scenario 2 and Scenarios 3 and 4 is that Scenario 2 includes an option to use air source heat pumps with fuel backup.  This option is included to address the following statement in the Draft Scoping Plan:

In the State’s coldest regions, where heating systems are designed for temperatures of zero (0F) or lower, some homes that install cold climate ASHPs may therefore use supplemental heat (wood, home heating oil, propane, or gas) for peak cold conditions to avoid unnecessary oversizing of heat pumps and to mitigate electric grid impacts.

I agree that this is necessary but I think that there are issues with this option.  In the first place I presume that in Scenarios 3 and 4 these homes will have to rely on electric resistance heating for the supplemental backup needed.  What are the impacts of oversizing heat pumps and the electric grid impacts on affordability?  Oversizing the heat pump adds direct costs which are not reflected in device cost table.  If too many people have to rely on electric resistance heating, then there will be a spike in energy demand during the coldest periods.  That could mean the electric distribution system will have to be over built for those conditions.

In order for heat pumps to work they have to transfer energy.  At some extreme of cold weather air source heat pumps won’t have enough energy to provide heat.  This issue is an example of a clean energy technology that doesn’t work all of the time and the time when it does not work it is needed the most.  Advocates for the net-zero transition often ignore the significant costs needed to provide a reliable system for these worst-case conditions.  In this instance homeowners can address the problem by installing a ground source heat pump ($34K instead of $15K), installing a deep shell insulation and infiltration envelope instead of a basic shell ($45K instead of $6K), or adding electric resistance heat ($1K).  The problem with just adding electric resistance heat is that electric service to the home and neighborhood will have to be upgraded and that adds between ($4K and $9K) and who knows how much more for the added generation needed.  The alleged lower costs of Scenarios 3 and 4 suggest that this issue has not been included in the costs.

The other issue with this option is that the alternative to use home heating oil, propane, or gas may not be viable when most homes have converted to electricity.  Fuel oil and propane dealers probably won’t have enough customers to remain in business.  Delivering natural gas to an ever-decreasing number of homes will also likely have similar viability issues.

Share of Electrified Buildings

In 2050 the percentage of electrified buildings is 92% for all three mitigation scenarios.  Scenario 2 projects that 631,351 housing units will still use combustion heating sources and in Scenarios 3 and 4 634,66 housing units will use combustion sources. First point is that it is not clear that the two scenarios that are supposed to get away from combustion are projected to have more residences on combustion sources.  The same viability issues with oil, propane and gas suppliers are also a concern.

Share of Buildings with Efficient Shell

The Draft Scoping Plan approach depends upon “making energy efficiency improvements in all buildings, with the emphasis on improvements to building envelopes (air sealing, insulation, and replacing poorly performing windows) to reduce energy demand by 30% to 50%.”  The Plan documentation describes building shell improvement characteristics but does not describe the rationale for applying basic vs. deep shell packages.  There is an enormous difference ($45K instead of $6K) between the costs of the two types of building shells and there is insufficient documentation to determine how the Integration Analysis apportioned the technology across buildings in the state.  I submitted comments earlier that addressed the types of building shells.  I concluded that the Draft Scoping Plan underestimates the number of buildings that need deep shell upgrades.  That affects the cost projections significantly.

There is no difference in the percentage of building shell types for all three mitigation scenarios.  Importantly, note that 8% of the buildings are projected to not receive shell upgrades.  I guess that the same 8% of buildings that are not electrified don’t get building shell upgrades.

Conclusion

The Climate Action Council is obligated to provide a Draft Scoping Plan to fully account for costs.  I believe that means that all the control measures should be listed, the assumptions used referenced, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  That information is not available.

Because this information is not available it is not possible to comment on the glaring inconsistency that Scenario 3: Accelerated Transition Away from Combustion and Scenario 4: Beyond 85% Reductions are projected to cost less than Scenario 2: Strategic Use of Low-Carbon Fuels.  As shown here if combustion is prohibited in more homes, then residential heating costs will have to go up significantly to address the problem of performance of air source heat pumps in extreme cold.

In my opinion, it is necessay to do a feasibility analysis for all three mitigation scenarios.  I think a properly done analysis will show that Scenario 2 has tremendous reliability and affordability risks.  I cannot believe that Scenarios 3 and 4 would not increase those risks.  The only rational scenario choice is number 2.

Climate Act Draft Scoping Plan Scenario Components

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The comment period for the Draft Scoping Plan is open until June 10, 2022.  The Council requested feedback on the components of three mitigation scenarios.  This is an overview summary of the components.  I plan to describe the components by sector in more detail in future posts.

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 Climate Act 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.

Integration Analysis Reference Case and Scenario 1

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates.  The primary reference for the scenario descriptions is Appendix G Section I: Techno-Economic Analysis (Section I).  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)” (Section I p.11). The initial analysis found that the Advisory Panel recommendations in Scenario 1 did not meet the Act emissions limits (Figure 1).

There is another aspect to Figure 1.  In order to understand the true impact of these scenarios it is important to know what is included and what is not included.  In particular the Reference Case has “a business-as-usual forecast plus “implemented policies”.  The inclusion of implemented policies in the Reference Case means that many New York State policies that exist only to meet climate goals are not included in the expected costs for the Climate Act itself. 

Figure 1: Screen capture of Figure 4 and its foornote on Section I – page 12.  Note that there is no caption for the figure but there is a footnote.  The footnote is the primary reference for the definition of the Reference Case

The footnote for the preceding figure states that the Reference Case includes a business as usual forecast plus implemented policies, including but not limited to federal appliance standards, energy efficiency achieved by funded programs (Housing and Community Renewal, New York Power Authority, Department of Public Service, Long Island Power Authority, NYSERDA Clean Energy Fund), funded building electrification, national Corporate Average Fuel Economy standards, a statewide Zero-emission vehicle mandate, and a statewide Clean Energy Standard including technology carveouts.  The following table from Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions lists specific programs in the Reference Case.  In order to provide a full accounting of the control measures the Scoping Plan documentation should include a description, the emissions reductions expected, and the costs expected for each of the scenarios.  That information is not provided so the Draft Scoping Plan is fatally flawed.

Figure 2: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Integration Analysis Mitigation Scenarios

The consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   Figure 3 lists the control measures used. The three mitigation scenarios are described in Section I on page 14:

Transformative levels of effort are required across all sectors, and all three scenarios include high levels of electrification, including Scenario 2, which also incorporates the strategic use of low-carbon fuels. Scenario 3 pushes harder on accelerated electrification to meet the emission limits using a very low bioenergy and low-combustion mix of strategies. Scenario 4 pushes beyond 85% direct reductions in 2050 by layering some low-carbon fuels back in, examining very high VMT reduction, and assuming high (but also highly uncertain) levels of innovation in the waste and agriculture sectors. Scenario 4 is the only evaluated scenario that achieves carbon neutrality without the use of negative emissions technologies like direct air capture of CO2, which is also subject to high uncertainty, but is required in Scenarios 2 and 3 to address the gap between remaining gross emissions in 2050 and the ambitious assumed projections of natural sequestration.

Figure 3: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Chapter 9 of the Draft Scoping Plan includes four figures (starting at page 72) that list projected emission reductions and the strategies employed to achieve them for all four scenarios.  The following text reproduces the figures and extracts the sector strategies for multiple dates in the timeline in order to show how the strategies differ between the scenarios.

Scenario 1: Advisory Panel Recommendations

Representation of the Advisory Panel recommendations, which provide a foundation for all scenarios; however, scenario modeling shows that further effort is needed to meet Climate Act emission limits.

Figure 4: Draft Scoping Plan Page 72

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
    • Bioheat blends in NYC buildings
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 0.9 million homes electrified with heat pumps
    • 13% of all homes have efficient shell upgrades
    • 15% renewable natural gas in pipeline
  • Transportation
    • 1.8 million zero-emission light-duty vehicles
    • 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3.6 GW battery storage
  • Hydrofluorocarbon (HFC)
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
  • Industry
    • 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
  • Forestry
    • Forest sequestration returnes to 1990 levels (-35 MMT)

Scenario 2: Strategic Use of Low-Carbon Fuels

Advisory Panel recommendations adjusted for strategic use of bioenergy derived from biogenic waste, agriculture and forest residues, and limited purpose grown biomass, as well as a critical role for green hydrogen for difficult-to electrify applications. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 5: Draft Scoping Plan Page 72

Italicized items are changes from Scenario 1

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
    • Bioheat blends in NYC buildings Scenario 2 eliminates bioheat blends
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps.
    • 1.5 instead of 0.9 million homes electrified with heat pumps
    • 25% instead of 13% of all homes have efficient shell upgrades
    • 9% instead of 15% renewable natural gas in pipeline
    • There is no figure that provides similar information for the Reference Case so it is not clear, for example, how many homes are electrified with heat pumps in the Reference Case
  • Transportation
    • 2.7 instead of 1.8 million zero-emission light-duty vehicles (90% new sales)
    • 100% zero-emission bus sales
    • 75% renewable distillate instead of 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3 GW instead of 3.6 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
  • Forestry
    • Forest sequestration returnes to 1990 levels (-35 MMT)
  • Negative Emission Technology, for example, direct air capture
    • -26 MMT

Scenario 3: Accelerated Transition Away from Combustion

Advisory Panel recommendations adjusted to include a very limited role for bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 6: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 2

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 1.8 instead of 1.5 million homes electrified with heat pumps
    • 25% of all homes have efficient shell upgrades
    • Early retirement of old heating systems
    • 4% instead of 9% renewable natural gas in pipeline
  • Transportation
    • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
    • Early retirement of old vehicles
    • 100% zero-emission bus sales
    • 75% renewable distillate instead of 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission
    • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 83% instead of 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
    • Limited reuse of captured methane
  • Forestry
    • Additional afforestration and forest management -40 MMT instead of -35 MMT
  • Negative Emission Technology, for example, direct air capture
    • -20 MMT instead of -26 MMT

Scenario 4: Beyond 85% Reduction Advisory Panel recommendations adjusted to reflect accelerated electrification and targeted use of low-carbon fuels. This scenario includes additional reductions in VMT and innovation in methane abatement. This scenario reduces gross GHG emissions beyond the 2050 limit and avoids the need for negative emission technologies.

Figure 7: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 3

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 1.8 instead of 1.5 million homes electrified with heat pumps
    • 25% of all homes have efficient shell upgrades
    • Early retirement of old heating systems
    • 7% instead of 4% renewable natural gas in pipeline
  • Transportation
    • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
    • Early retirement of old vehicles
    • 100% zero-emission bus sales
    • 7% renewable distillate
  • Generation
    • 70% clean energy standard
    • 3 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission
    • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 83% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation?
    • 100% renewable natural gas and renewable distillate
    • 71% renewable jet fuel
    • Limited reuse of captured methane
  • Forestry
    • Additional afforestration and forest management -40 MMT instead of -35 MMT
  • Negative Emission Technology, for example, direct air capture
    • -20 MMT instead of -26 MMT
  • Additional innovation in methane mitigation and natural sequestration

Conclusion

There are only a couple of things to mention.  I have noticed that anyone who has addressed the Council request for feedback on the components of the three mitigation scenarios has advocated for Scenario 3, Beyond 85% reductions.  Given the paucity of information available I can only assume that they supported it because it sounded more stringent. 

The list of control measures that are included in the Reference Case, and thus don’t show up as direct costs for the Climate Act, includes multiple measures that only exist as part of the State’s initiatives to address climate change.  I think that is a semantic trick that disguises the real costs of the transition to net-zero because it is clear that the costs associated with at least some of those measures are not included in the cost-benefit analysis.  Because the control measure descriptions, emission reductions and costs are not provided in detail, it is impossible to determine how many are misleadingly categorized to be able to claim that the Climate Act benefits are greater than the costs.  It is also impossible to determine if the Draft Scoping Plan excluded the emission reduction benefits associated with those measure.  If their costs were not included then it is wildly inappropriate to not exclude the benefits from the cost-benefit analysis.  There is no indication that those emission benefits were excluded.

In future posts I will address specifics associated found in specific sectors.  From what I have seen so far there are plenty of concerns.

Failure of the Climate Change Scoping Plan to Meet the Requirements of the Climate Act

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.