Category: Climate Act

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda” and voted to release the Draft Scoping Plan late last year.  After a two-month hiatus the Council finally got around to having a meeting to discuss the plan for 2022 on March 3, 2022 (recording here).  This post describes my thoughts about the meeting and plan.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.  The integration analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. At that time, the Climate Action Council stated that the public comment period would extend through at least the end of April 2022 and would include a minimum of six public hearings. This meeting outlined their plans for 2022.

March 3, 2022 Meeting

The meeting followed the usual routine of all previous meetings.  After the formal welcome, roll call, and consideration of the previous meeting minutes, the co-chairs take the floor to blame any recent unusual weather on climate change (slow couple of months because there were no examples this time), to brag about what a great job they are doing with the implementation process, highlight anything the Governor proposed related to the climate recently (in this case the State of the State annual address), and highlight any related project awards.

My primary interest was the overall goals and objectives discussion starting at 23:50 of the video.  There was a discussion of the proposed 2022 activities & schedule, a debate about the outstanding topics that required further deliberation, an agreement about the decision-making process and a conversation regarding public engagement.

2022 Schedule 

The activity and schedule overview discussion starting at 25:41 in the recording was disappointing.  The proposed plan is for three phases.  From the start of the year through the end of April they proposed to gather information.  From May to August the information there will be a discussion and deliberation phase.  Over the rest of the year the final scoping plan will be drafted and finalized.  This is disappointing because there is no iterative component.  There is no chance for stakeholders to ask questions and respond to their answers.

In addition, there is no opportunity for the Council to ask stakeholders about their comments. If, for example, the Council ever gets around to reading the comment I submitted on February 1 where I argue that the claims that the benefits are greater than the costs are wrong, I believe that claim should be addressed and not ignored. There was no indication in the discussions that this situation would ever arise which pretty much suggests to me that this process is just going through the motions and substantive issues raised in comments will simply be ignored.  It that is not the case and they do respond to substantive issues like whether the benefits may not be greater than the costs, then I think I should be given the chance to rebut whatever hand-waving argument they contrive to claim I am wrong. 

The next slide (25:41 in the recording) presented the plan for Council meetings and supporting activities) It is encouraging that the expert topical input includes the opportunity for experts to provide input and feedback on topics of interest and for representatives of key sectors and industries to provide targeted feedback on topics of interest.  However, there is a problem because throughout the implementation process to date, only one side of the transition challenge has been heard. The Council members who spoke at the meeting are missing this point.  I will discuss this concern more later.

Climate Justice Working Group feedback was the subject of the next slide (30:12 in the recording). In my opinion the Climate Action Council has placed an inappropriate level of focus on this feedback.  There is a Public Service Commission mandate that should be the first priority.  Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

I interpret that to mean that the Climate Act has to meet the following obligations:

• It cannot impede the provision of safe and adequate electric service (i.e., reliability)
• It cannot impair existing obligations and agreements and I assume they mean existing contracts
• It cannot cause a significant increase in arrears or service disconnections that the commission determines is related to the program (i.e., affordability)

The Council’s focus on meeting the targets and placating the Climate Justice Working Group ignores these obligations.  With all due respect to the Working Group, they have no affordability and reliability responsibilities so their priorities differ and could easily result in a Scoping Plan that does not address those obligations adequately.  More importantly, reliability and affordability issues impact disadvantaged communities more than other communities so they should be their priority too.

The next slide addressed public input (33:27 in the recording).  The Climate Action Council is required to hold six in-person hearings across the state but they proposed to add one more public hearing and two virtual public hearings.  However, I am very disappointed with the proposed hearings approach because I think that substantive issues raised won’t get recognized.  They apparently plan to follow the same approach to public input as was used for the advisory panels input.  In particular, they plan on three-hour hearings and to limit speakers to two minutes which is insufficient time for anything meaningful.  Instead it is about enough time for a speaker to say that they are in favor or not in favor of the plan.  Ultimately this approach means the Council is simply going through the motions for the public input requirement of the Climate Act.

The concept that the Council would hold meetings to solicit expert input was a feature in the presentation.  However, there was no recognition that the Council might want to invite speakers to participate in a Council meeting if their comments raised issues not addressed in the Draft Scoping Plan.   

Another issue related to the public comments is how they will be handled.  It was mentioned that there already have been over 1,000 comments submitted to the portal.  The following slide says that “Council to consider the full set of public comments after the comment period closes” (discussed at 34:20 in the recording) but it is silly to wait to start to evaluate the comments until the end of the comment period.  Clearly staff has to be organizing the comments and there was mention that the Council will have access to the NYSERDA web system to see the comments.  I think that the comments should be publicly available after they are reviewed for acceptability and not held from the public until the end of the public comment period.  The comments should be sorted regarding relevance to specific chapters, issues, or form submittals expressing generic support or lack of support.

The proposed schedule and meeting locations for the public hearings was discussed starting at 35:30 in the recording.  Staff pointed out that adding other meeting locations beyond the six mandated in the Climate Act means that the comment period is going to be extended 30 days until the end of May.  Nonetheless Council members suggested additional public hearings in Nassau/Queens, Yonkers/Westchester, Southern Tier and Mid-Hudson areas.

There was a long discussion about the timing, content, and format of the in-person and virtual meetings. 

The next slide (1:12:55) discusses the Integration Analysis plans for 2022.  The authors not that “priority topics can be addressed by focused sensitivity analysis”, but also mentions that there isn’t much time to able to do additional research based on feedback. 

This reinforces my argument that the feedback from already submitted public comments and others submitted before the end of the public comment period should be evaluated and considered on an on-going basis.  The slide says that the analyses needed will “need to be finalized within the second quarter of 2022”.  Three potential areas of inquiry are mentioned in the slide:

• Continued assessment of impacts of electrification, heating system configuration, and magnitude of building shell efficiency investment on key output metrics (e.g., system peak, cost)
• Impacts of expanded uncertainty range of electric distribution system cost
• Further alignment of benefit cost framework with net GHG emissions accounting in Statewide GHG Emissions Report

While I don’t disagree with these areas of inquiry, I am disappointed that the words feasibility, reliability, and affordability are not mentioned.  In my opinion the Draft Scoping Plan does not address those concepts adequately. The fact that they are not menti0ned suggests that the authors of the Draft Scoping Plan think they are covered.

The next slide (1:14:50) describing 2022 activities discusses the finalization of the Scoping Plan.  It just fits the finalization into the schedule.  After this slide was presented, there was an opportunity for comments and discussion (starting at 1:17:00).  Carolyn Ryan pointed out the time to discuss public comments is going to be limited so it will be difficult to incorporate public comment.  Sarah Osgood pointed out that there have been 1100 to 1200 comments submitted already.  She said that they would be summarizing them as quickly as possible as they come in and consider how to present them to the Council for consideration.  At 1:20:50 Gavin Donohue made the first mention of reliability.  He said that he hoped that expert engagement would include this topic. 

Topics and Process

According to the next slide (1:24:30), equity and climate justice “are overarching lenses to apply consistently to all topic areas”.  That sums up the framework of Climate Act implementation as it stands.  In any rational take on implementation, reliability and affordability should be the overarching lenses applied to all topic areas.  Isn’t it obvious that this is the cornerstone to equity and climate justice because an unaffordable and unreliable energy system will impact those least able to pay the most?  Incorporating those social justice issues as part of the need for an affordable and reliable system is the appropriate approach but I fear it is not on the agenda.

Three topics were discussed that “require more deliberation” starting at 1:27:02.  All of these issues were raised by members of the Climate Action Council.  In order to meet the Climate Act mandates the natural gas system has to be replaced and this is the first topic.  Some Council members have interpreted the law to preclude the use of combustion entirely so the “potential applications of advanced fuels” topic addresses this issue.  If it is not necessary to consider technological feasibility then adding another layer of untried technology at the scale necessary may be appropriate but someday, someone has to point out that eliminating combustions has risks.  Chapter 17, Economy-Wide Strategies of the Draft Scoping Plan addresses comprehensive policies that price GHG emissions. 

In the process for supporting council decision-making slide (starting at 1:30:33) several suggestions were made.  Given that there are unresolved issues even before the public comment period started a process is an obvious need.  There is no question that additional input and support to the Council are needed.  During the meeting they talked about subgroups developing recommendations for particular topics.  My concern is that the topics chosen will be based on the biases of Council members rather than on the feasibility of the proposed transition without adverse impacts on reliability and affordability.

Starting at 1:47:00 the three identified topics were discussed in detail.  This particular discussion was so relevant that I am going to make it the subject of another post.

The last substantive slide (2:46:20 in the recording) addressed the decision-making process itself and particularly how they will address “consensus”.  I think the statement “Consensus requires that there has been a good faith effort to find a package of recommendations that meets the most important interests of Council members” sums up my over-arching concern about the Council.  In particular the interests of some of the more vocal Council members are ideological rather than logical.  I keep mentioning affordability and reliability feasibility concerns because those ideologues are ignoring those critical concerns.  Given that every other jurisdiction that has tried to implement some similar transition to emissions-free energy systems has run into problems with affordability and reliability ignoring them in this instance is a recipe for disaster.  Of course, when that happens it will be somebody else’s fault.

Discussion

There are some over-arching points to be made regarding the 2022 Climate Action Council plans for this year.  The first issue is logistical.  The outlined plan does not place enough emphasis on starting to address comments received as soon as possible.  I believe the process of summarizing, categorizing, and disseminating comments should start immediately so that the Council can determine if there are substantive issues that need to be addressed.  If the Council makes it clear that the sooner a substantive issue is raised, the more time they will have to address it, then I think stakeholders will realize it is in their best interests to get comments in as soon as possible rather than waiting until the comment period closes.

I was disappointed that reliability and affordability were not at the top of the list of issues that need to be addressed in 2022.  It appears that climate justice and disadvantaged communities are higher priorities despite the massive impacts of higher costs and unreliable power on those least able to afford higher costs and blackouts.  That point of emphasis reinforced my concern that for many on the Council the green energy transition is more about political pandering to specific voting blocs than addressing climate change in a rational way.

Finally, the Council appears to be tone deaf to the need to hear both sides of substantive issues.  For example, Dennis Elsenbeck at 1:44:58 bias notes that we “use the word bias all the time”.  He goes on to argue that there is bias in this entire process but then claims that “You deal with bias by having an unbiased facilitator”.  In the discussion of combustion avoidance his suggestion is that the Council should hear from experts like Plug Power on the topic of fuel cells.  According to their website, Plug Power is the “leading provider of clean hydrogen and zero-emission fuel cell solutions that are both cost-effective and reliable”.  There is zero chance that any presentation they give to the Council is going to suggest in any way, shape, or form that fuel cells are not the answer with no downsides.  If all the presentations to the Council are from subject matter experts that have a bias towards their technology, then an unbiased facilitator will not be needed because there is only one side presented.  It is time to open up the discussion and make sure that the pros and cons of all implementation topics are heard.  For example, at 29:40, Sarah Osgood mentioned having a presentation on district heating systems.  If this is done then they should not invite just the advocates for those systems but people who can describe potential issues with this approach.

Conclusion

The scope and schedule of the Climate Act transition to a “zero-emissions” energy system is so daunting that a full accounting of the risks to reliability and affordability cannot hope to be adequately addressed in the time frame available.  Nonetheless, I had hoped that the Council would consider the inconvenient issues as well as the convenient issues.  The plan for the electric system transition relies on technology that does not exist.  Any responsible implementation plan would incorporate specific technological and cost conditions in the schedule for this massive transition to ensure that the technology needed is available before the existing system is dismantled.  The Integration Analysis has not confronted this reality and the Council appears blissfully unaware of this risk  The public comment period is supposed to afford stakeholders the opportunity to raise concerns about the viability of the proposed plan relative to issues like this.  However, the plans outlined at this meeting suggest that the public comment requirement will be treated as a formality rather than an opportunity for meaningful issues to be raised and considered.  I do not see how this will end well.

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Climate Action Council has released for public comment the Draft Scoping Plan that outlines the implementation plan for the Climate Act. The document is huge as it covers all aspects of New York’s energy system.  This post looks at one minor component of the Scoping Plan’s mitigation scenarios to determine if the numbers presented are reasonable.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.  The Integration Analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

The Integration Analysis developed four scenarios to compare with a reference case that describes the New York energy system without the Climate Act.  The first scenario is based on Advisory Panel inputs but did not meet the Climate Act targets.  According to Appendix G, Integration Analysis Technical Supplement, Section I, page 13:

Transformative levels of effort are required across all sectors, and scenarios include high levels of electrification including Scenario 2, which also incorporates 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 including use of some low-carbon fuels, examining very high VMT reductions, and assuming high (but also highly uncertain) levels of innovation in the waste and agriculture sectors. The Council expressly seeks feedback on the components of these scenarios of which detailed information can be found in the sector strategies portions of the sectoral chapters in this draft Plan.

This article describes only one component of the strategies.  Make no mistake there is so much information presented and the documentation is so marginal that it is impossible to evaluate all the components in any detail.  For this article I am going to address one aspect of the transportation sector plan. The addendum to this article consolidates relevant information in Appendix G, Integration Analysis Technical Supplement, Transportation in Section I starting on page 35 where the components of the transportation sector scenarios are described.

Transportation Component Comment

The mitigation scenarios reduce transportation emission by reducing the miles traveled by vehicles, adoption of zero-emission vehicles, electrification of non-road sectors, and targeted low-carbon fuel use. Reducing energy consumption means that GHG emissions are reduced within the transportation sector.

When I evaluate a regulatory proposal my first step is to try to reproduce the proposal’s numbers so that I can verify that the assumptions used are reasonable.  Even though I limited myself to just the transportation sector there still are far too many aspects to consider them all.  The scenarios proposed to reduce vehicle miles traveled using smart growth, expanded public transit, telework and demand management programs but all of those strategies are broader than I want to deal with at this time.  I considered discussing the suggestion that there could be a “small role for electric aviation in decarbonizing short distance flights by 2050, and hydrogen aviation to decarbonize medium distance flights”.   The claim that “hydrogen and electric aviation displace 47% of remaining aviation fuel demand in Scenario 4” sets off my BS detector but I chose instead to use a different claim in this article to see if the numbers can be trusted.

In this example I will address the enhanced transit & mobility claims related to the Scenario 4 alternative “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS”.  In particular, I am only going to address the rail improvements measure shown in Table 11 of Appendix G: 200 million light duty vehicle miles can be reduced relative to Scenarios 2 and 3 at a per unit cost of $6 per mile.

⁵⁷ Moving Cooler: http://www.reconnectingamerica.org/assets/Uploads/2009movingcoolerexecsumandappend.pdf, accessed November 2021

Empire Corridor Draft 1 Tier EIS: https://railroads.dot.gov/environment/environmental-reviews/empire-corridor, accessed November 2021

EU Hydrogen Aviation Study:

https://www.fch.europa.eu/sites/default/files/FCH%20Docs/20200720_Hydrogen%20Powered%20Aviation%20report_FINAL%20web.pdf, accessed November 2021

⁵⁸ Scenario 2 and Scenario 3 include 9 billion LDV miles reduced in 2050 relative to Reference scenario, from enhanced transit and mobility; telework and travel demand management; smart growth and mode shifting to biking/walking; No $/mile cost was assessed for tranche of VMT reduction achieved in Scenarios 2-3. Table above shows incremental investment relative to Scenarios 2-3

Table 11 documents transportation-related incremental costs associated with Scenario 4.  It claims that the per-unit cost is $6 per mile and that 200 million light duty vehicle miles will be reduced relative to Scenarios 2 and 3 in 2050.  The plain reading of this is that the 200 hundred million light duty vehicles miles reduced will cost $6 per mile or $1.2 billion.  The basis of the claim is the “Empire Corridor Draft 1 Tier EIS” which is an analysis of improvements that could be made to railroad passenger service in New York.

Empire Corridor Rail Passenger Improvements

The Federal Railroad Administration (FRA), in cooperation with the New York State Department of Transportation (NYSDOT) completed the Empire Corridor Environmental Impact Statement (EIS) in 2014 to “evaluate proposed system improvements to intercity passenger rail services along the 463-mile Empire Corridor, connecting Pennsylvania (Penn) Station in New York City with Niagara Falls Station in Niagara Falls, New York.”  The components of the EIS include the following:

• Empire Corridor Tier 1 DEIS – Volume 1
• Appendix A – Volume 2
• Appendices B-H – Volume 3
• Appendices I-J – Volume 4

Completing an EIS always takes a long time but the fact that the FRA anticipates publishing the final report in 2022, eight years after it was completed suggests that there were issues.  For this evaluation the point is that there were four alternatives considered to upgrade railroad service from New York City to Niagara Falls.  There were two alternatives to raise passenger train speeds to 90 mph between Albany and Buffalo and one to raise passenger train speeds to 110 mph that all use the existing right-of-way.  The fourth alternative would raise the passenger train speeds to 125 mph but that would require the development of a “new electrified (with overhead catenary), two-track, grade-separated high-speed rail corridor of 283 miles between Albany/Rensselaer Station and a new Buffalo station”.  The following table highlights the differences between the alternatives. 

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”.  As this document is the sum total of the documentation a certain degree of guessing is required to deduce what that means.  Although never mentioned it seems likely that Scenarios 2 and 3 use Alternative 110 from the Empire Corridor EIS to project reductions in vehicle miles traveled and using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” appears to provide incremental improvements.

It is possible to check the projected numbers.  Table 11 claims that “200 million light duty vehicle miles will be reduced relative to Scenarios 2 and 3 in 2050” at a per unit cost of $6 per mile.  Recall, however, that I previously interpreted this to mean that the 200 hundred million light duty vehicles miles reduced will cost $6 per mile or $1.2 billion.  The capital cost difference between Alternative 110 ($6.3 billion) and Alternative 125 ($14.7 billion) is $8.4 billion, far more than that per unit cost. 

There is another possible check.  Exhibit 6-7 in the Empire Corridor EIS estimates the annual reductions in auto trips in 2035 for the different alternatives.  Assuming that using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” means that the proposed improvement is the difference between the 110 and 125 alternatives, then that means that 307,475 autos are diverted from highways. 

In order to estimate the vehicle miles traveled reduction from the estimate of 307,475 autos diverted from highways, the distribution of where the passenger boarded and exited is needed.  Exhibit 2-21 provides that information for 2009.  I have an issue with these data.  In particular, while the total appears consistent with the numbers in the rest of the document it is worrisome that the origin and destination numbers match exactly.  I interpret this table to state that 320,155 people boarded trains in New York to go to Albany reading down the first column to New York City then across to the third column under the heading Albany.  For the people going from Albany to New York City read down the trip origins column to Albany and then over to the second column for New York City.  I believe it is highly unlikely that exact number of people going from Albany to New York City and vice-versa would be identical.  Furthermore, the fact that the station pairs in all instances are the same means that there is an issue with the numbers.  Because I don’t expect that there would be a big difference between the numbers and the total is consistent, I have ignored this issue.

Unfortunately, there is no similar breakdown of boardings for the alternatives.  Exhibit 6-6 does break down total ridership by alternative in 2035.

My spreadsheet Empire Corridor Data uses the information from these three tables and the distances between the stations listed along the Empire Corridor (Markets tab) to estimate the vehicle mile traveled reduction expected in 2035 if the 125-mph alternative is implemented rather than the 110-mph alternative.  I assume that the relative ridership between stations remains the same as that shown in Exhibit 2-21 and that the diversion from highways estimates are proportional to the passenger boardings.  The difference in auto trips diverted from highways between the 110-mph alternative (177,603) and the 125-mph alternative (485,078) is 307,475.  The number of diverted auto trips for each station is proportional to the station boardings per station in 2009 multiplied by 307,475 divided by the total number of boardings in 2009 (932,801).  The vehicle mile traveled reduction is the number of trips per station pair times the distance per station pair.  The sum of the distances for all these diverted trips is 64.7 million miles in 2035.  The Table 11 projected number of light-duty vehicle miles traveled is 200 million miles in 2050.  Even though the dates are different I think it is clear that the numbers, and therefore the methodology, are incompatible.

There are a couple of ways to interpret these discrepancies.  It could simply be that my interpretation of the Scoping Plan total costs and mileage reductions for this strategy are incorrect.  On the other hand, I think it is more likely due to a methodology difference.  Due to the lack of documentation, it is impossible to determine how the Integration Analysis estimated the costs and mileages.  I suspect, but cannot prove, that the Integration Analysis assumed some sort of a relationship between railroad passenger investments and vehicle mile reductions based on the results of the Empire Corridor EIS.  Unfortunately, the existence of a relationship does not mean that you can estimate benefits for anything other than the total costs of the alternative.  The cost difference between the 110-mph alternative and the 125-mph alternative is $6.3 billion and diverts 307,475 auto trips away from the roads to the trains.  It is not appropriate, for example, to assume that an investment of $3 billion would divert half as many trips but I think that something along those lines was done.

Conclusion

Without herculean effort by many people over a long period it is impossible to evaluate all the cost-benefit claims in the Draft Scoping Plan.  It is not only that there are many components to the New York energy system but the lack of documentation means that a large part of the analysis is trying to guess how the numbers were generated.  The only alternative is to evaluate a few discrete components and to see if the estimates are reasonable.

This analysis evaluated 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.

Every time I have dug into the numbers, for example residential heating retrofit electrification, the Draft Scoping Plans numbers are not a reasonable estimate compared to my work. I have consistently found that the Scoping Plan costs estimates are biased high and the benefits proposed are biased low.  I conclude that there is little reason to trust the cost estimates in the Draft Scoping Plan because of the issues I have found.

All indications at the March 3, 2022 Climate Action Council meeting were that the plan for public involvement will simply going through the motions.  For example, there is no provision for the kind of discrepancy documented here to be reconciled as a result of public comments.  This example is trivial and has no major bearing on Climate Act implementation.  The terrifying prospect is that the issues associated with reliability raised at last summer’s Reliability Planning Speaker Session could possibly be treated the same, that is to say ignored.  Those issues must be addressed or the result could lead to people freezing to death in the dark.

The Draft Scoping Plan outlines the implementation strategy for New York’s Climate Leadership and Community Protection Act (Climate Act) has been released for public comment by the Climate Action Council. The NY Business Council recently published a summary of the Draft Scoping Plan that I think is an excellent overview of the Plan. 

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target 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”.  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. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”.  Once complete an updated Energy Plan will guide New York’s energy policy going forward.

The NY Business Council is the “voice of business and employers in New York State Representing 3,500 business of all sizes, in all sectors Including nearly 100 local chambers and business groups”.  At a recent webinar Ken Pokalsky referenced a summary of the Draft Scoping Plan that he prepared.  I asked for permission to publicize his summary and this post is the result. 

The summary of thescoping plan points out that the document and supporting documents “amount to more than 1,000 pages and provide significant details on the Climate Action Council’s analysis and recommendations. It explains that “Some sections, i.e., transportation and buildings, provide specific recommendations and timelines for action” and that “Others, including sections on the electric power and natural gas sectors, and on industry, provide far less in the way of a detailed implementation plan.”

The distinction between the sections is an important point.  In order to be a credible basis for the Energy Plan’s roadmap for “providing clean, reliable, and lower-cost energy to all New Yorkers” the State has to prove that it is feasible.  While the transportation and building sector sections provide more detail it is barely sufficient for a feasibility analysis. There clearly isn’t anything approaching a feasibility analysis for the electric power and natural gas sectors.  I believe that this is partially due to the complexities of the electric and gas sectors.  Unfortunately, a main driver of policy is the political calculus to incorporate social and environmental justice concerns.  As a result, appeasing those interests is over-riding technological feasibility concerns.

Benefits and Costs

The following lists the benefits and costs presented with my indented and italicized comments.

• The plan discusses the range of adverse impact caused by climate change and asserts that climate change will be affected by the actions proposed in the scoping plan.

Pokalsky recently gave a presentation at the Real Cost of New York’s Climate Leadership and Community Protection Act webinar.  My post on the webinar made the point that technical feasibility of wind, solar, and energy storage should be a primary concern but only one of six presenters raised that point because it is politically incorrect to argue the point.  Pointing out that the Intergovernmental Panel on Climate Change technical reports don’t agree with the range of adverse impacts listed in the Draft Scoping plan and that the state has never quantified the effect of any New York GHG emission reduction program on global warming itself is even more of a politically incorrect argument.

 In addition to reducing the impacts of climate change, it recognizes that the state will need to adapt to risks that cannot be avoid.

I agree.

 While the report provides few specifics on the cost of implementation measures, it reports on macro-level models of the cost and benefits of multiple compliance scenarios, each of which projects that benefits will significantly outweigh implementation costs, with benefits including public health benefits from improved air quality Improvements in air quality, increased active transportation, and “energy efficiency interventions” in homes generating health benefits ranging from approximately $165 billion to $170 billion. However, this analysis compares the costs of implementing this state specific scoping plan with benefits, including estimates of avoided economic damage from climate change at up to $250 billion, benefits that would require actions beyond those proposed in this scoping plan to achieve.

I have shown that the health benefits claimed exaggerate the projected values, that the estimates of avoided economic damages from climate changes are manipulated to be 5.4 times higher than other jurisdictions, and, despite all the biased calculations, the benefits are not greater than the macro-level cost estimates unless the benefits of reductions are counted multiple times.  If only that error is corrected the total benefits range from negative $74.5 to negative $49.5 billion instead of positive net benefits ranging from $90 billion to $120 billion.

 The scoping plan applies an analytic framework that projects approximately $140 billion in annual New York State energy system expenditures, including capital expenditures and fuel costs, representing 8.9 percent of gross state product. A significant share of that amount, including $30 billion of $50 billion in fuel costs, leaves the state. In part, the economic impact study discusses the effect of redistributing these annual expenditures to achieve the state’s renewable energy and energy efficiency objectives.

In the absence of detailed cost numbers, it is difficult to comment on the analytic framework for costs.  This is a good description of what is available.

 Public health benefits from reduced GHG emissions will include those related to heat, flooding and food, water, and vector-based diseases, and will result in indirect benefits from the reduction of emissions of GHG co-pollutants including particulates and various toxic emissions.

The heat, flooding, food, water and vector-based disease benefits are associated with the social cost of carbon calculations.  I have prepared a white paper on these alleged benefits for anyone who wants to get into the technical details.

• The scoping plan focuses significantly on historic disparate impacts on disadvantaged communities. Throughout the document, the scoping plan references recommendations of the Climate Justice Work Group (CJWC) and the extent to which they were not adopted by the Climate Action Council.

This is an important point that I have not addressed in my work yet.

• The plan asserts that it establishes “the country’s – and perhaps even the planent’s – strongest GHG emission reduction and clean energy requirements,” and it will serve as a model for other jurisdictions.

At the end of the day, I believe that this is the only benefit of the plan.  New York’s politicians will have bragging rights.  Of course, the owners of the Titanic had bragging rights on their maiden voyage too.

 The scoping plan will result in a cleaner environment and a more competitive economy, and will support new jobs, new businesses, and new economic opportunities. (The CAC also issued a report on projected job creation resulting from CLCPA implementation.) It contains several recommendations for retraining workers displaced by CLCPA mandates, and for offsetting any adverse economic consequences on communities impacted by the loss of facilities. It recognizes that CLCPA implementation will require an expanded, trained workforce, and supports measures such as project labor and community workforce agreements on CLCPA-related projects.

This is a primary concern for the Business Council.  I have not addressed this in my work yet and given the amount of material will more than likely defer to the Business Council’s opinion.

• It recognizes the potential impact of emission leakage due to actions that increase the cost of energy, reduces the reliability of energy, or increase the cost of GHG emissions, and recommends some approaches, including credits for early action and targeted incentives.

This is another topic I have not addressed.  Based on my work with Regional Greenhouse Gas Initiative emissions leakage I am pretty sure that leakage is inevitable but that the numbers can be manipulated to make it look like less of an issue.

Conclusion

The Business Council memo is intended to provide an overview of the most significant energy-related proposals impacting major sectors of the New York State’s economy. It does an excellent job in that regard.  The memo points out that “Most businesses will be impacted by the recommendations of multiple sector-specific proposals”. The Business Council urges its members to review the scoping plan and get involved with their internal comment development process.  I recommend that all New Yorkers review the plan and comment too.

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. This post describes comments on residential heating electrification retrofits that I submitted on 2/15/22.  I found that the documentation is insufficient and that the cost estimates are low.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target 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”.  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. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023.

The Integration Analysis estimates that the buildings sector is the largest source of existing GHG emissions.  In all the future scenarios building emissions reductions are driven by “rapid electrification, increased energy efficiency, and improved building shells”.  For home heating electrification that means conversion to heat pumps and improvements to building shells to minimize the energy needed to heat homes.  Late last year I published an article that provided background for this sector.  It also included a table that was updated last month that used the Integration Analysis documentation that could estimate the costs to replace existing home heating systems with all electric systems.  More recently, I documented my fruitless search for the cost numbers presented as graphs in the Draft Scoping Plan.  My comment was based in large part on the material in those posts.

Summary of the Comments

The comment submittal is available along with the calculation spreadsheet.  In my opinion, home electrification is a primary concern for New Yorkers given the importance of affordability and the widespread impact to every household.  Accordingly, I spent a lot of time trying to replicate the costs to retrofit existing furnaces with heat pumps so that I could provide substantive comments explaining whether I thought they were doing it right.  Unfortunately, the documentation was not of sufficient quality to enable me to match their numbers.

One of the points of my comments is that this level of documentation is not acceptable. 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 (my emphasis added).  The fact that the only description of net direct costs is a bar chart without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in the Draft Scoping Plan.

I also pointed out that there is a Public Service Commission mandate that needs to be considered.  Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

I maintain that the only way to ensure that there won’t be a significant increase in arrears or service disconnections is to provide fully documented cost numbers.

In addition to the comment document, I attached a spreadsheet that replicated relevant tables from the Integration Analysis spreadsheets, explained how I thought the cost to retrofit residences with heat pumps should be calculated and compared that to what was available.  The comments describe the missing documentation that is needed to replicate their projections.

My analysis found that a primary driver of home heating electrification is the building shell cost.  I argued that a more refined climatology of cold weather was appropriate.  The Draft Scoping Plan claims only 26% of residences need deep shell upgrades.  I estimate that more than half actually will need to have deep shell upgrades using a more refined climatology.  As far as I can tell from the graphs, I estimate that the entire building sector component cost is $230 billion relative to the reference case in the Draft Scoping Plan.  I calculated that just the residential retrofit heat electrification costs range between $259 billion and $370 billion using one methodology and between $295 billion and $370 billion using a different methodology.  The primary driver of costs is the number of residences that need deep building shell upgrades.   

In order to support my contention that there was insufficient documentation I documented my calculations to show where the documentation is inadequate.  While some aspects of the cost projections are documented in the Integration Analysis spreadsheets, there are critically important numbers missing.  Moreover, the calculation flow is not documented well enough to reproduce the cost projections.  It is unacceptable that the component costs shown in the figures of the Draft Scoping Plan are not provided.

The residential home heating retrofit component of building costs discussed in my comments are a good example of what should be provided for a publicly available evaluation.  The spreadsheets should provide all the data used in the calculations and describe the flow of data between table calculations should also be provided.

Other additional information is needed. I provided examples from my evaluation of the residential heating retrofit spreadsheet.  I suspect that the device costs vary over time but there is no documentation.  Any other values that change with time should also be documented. Building shell assumptions and values used are particularly important given their out-sized impact on the final costs.  What was the rationale for the values used?  Was there an uncertainty analysis of the effect of these assumptions?  How were the building shell assumptions used to estimate air and ground source heat pump distributions?  How were mobile homes addressed?  How many residences were deemed inappropriate for heat pumps?  What is the technology expected for those residences in the future?

Finally, I recommend that the Climate Action Council have a technical workshop that focuses on home electrification.  It is important that this workshop explain how the Integration Analysis calculated all the numbers presented.  An opportunity for stakeholders to provide questions beforehand to be addressed at the workshop would be appropriate as well as the chance for stakeholders to ask clarifying questions during the workshop itself.  The emphasis should be on the exchange of technical information without any opportunity for personal comments.  Throughout the implementation process to date, only one side of the transition challenge has been heard.  It is time to open up the discussion.

Conclusion

My comments on the Draft Scoping Plan addressed several issues related to the lack of documentation and provided suggestions for going forward.  The Climate Act requires the Climate Action Council to make evaluation of the total potential costs and potential economic and non-economic benefits “publicly available”. The fact that the only description of the net direct costs in the Draft Scoping Plan are bar charts without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in Plan.  I outlined what is needed to provide satisfactory information in the supporting spreadsheets and suggested that a technical workshop focused on electrification of residential heating given that impacts to most citizens.

My analysis highlighted the importance of building shell technology on heating electrification.  Because the documentation is so limited it is difficult to determine the assumptions used to project the requirements.  However, I believe that the Draft Scoping Plan underestimates the number of buildings that need deep shell upgrades.  That affects the cost projections significantly.

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050. The Draft Scoping Plan defines how to “achieve the State’s bold clean energy and climate agenda”.  However, there is increasing evidence that this dream is unrealistic.  This post describes an article by Gail Tverberg at Our Finite World that explains that “It is becoming clear that modelers who encouraged the view that a smooth transition to wind, solar, and hydroelectric is possible have missed some important points”.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  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. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

The Climate Act authors presumed that implementing the net-zero target was simply a matter of political will.  The Draft Scoping Plan does not incorporate a feasibility analysis to determine if this transition can occur without impacting reliability and affordability.  This post describes an independent analysis of the feasibility of any similar transition.

Gail Tverberg is an actuary interested in finite world issues – oil depletion, natural gas depletion, water shortages, and climate change. She argues that oil limits look very different from what most expect, with high prices leading to recession, and low prices leading to financial problems for oil producers and for oil exporting countries. We are really dealing with a physics problem that affects many parts of the economy at once, including wages and the financial system. She tries to look at the overall problem.  I have found her work to be insightful and compelling.  However, I think she downplays the potential for human ingenuity to resolve energy depletion problems.

Discussion

Tverberg describes six different reasons why she thinks the net-zero transition is not going as advocates claimed that it would.  I summarize her points below but encourage readers to go to her article for a more complete description.  Where appropriate I comment on the applicability to New York’s Climate Act.

Her first point is that variability is a major problem. She explains that the belief was that with the use of enough intermittent renewables or by using long transmission lines it would enable enough transfer of electricity between locations to largely offset variability. However, in the third quarter of 2021, weak winds were a significant contributor to a European power crunch. Europe’s largest wind producers (Britain, Germany and France) produced only 14% of installed capacity during this period, compared with an average of 20% to 26% in previous years. Because no one had planned for this kind of three-month shortfall prices skyrocketed.

Secondly, she states:

Adequate storage for electricity is not feasible in any reasonable timeframe. This means that if cold countries are not to “freeze in the dark” during winter, fossil fuel backup is likely to be needed for many years in the future.

One workaround for electricity variability is storage. A recent Reuters’ article is titled, Weak winds worsened Europe’s power crunch; utilities need better storage. The article quotes Matthew Jones, lead analyst for EU Power, as saying that low or zero-emissions backup-capacity is “still more than a decade away from being available at scale.” Thus, having huge batteries or hydrogen storage at the scale needed for months of storage is not something that can reasonably be created now or in the next several years.

This is of particular concern for New York’s implementation of the Climate Act.  In particular, the fossil fuel phaseout on a date-certain schedule is going to run up against the timing of the “still more than a decade away from being available at scale” outlook.  In my opinion, the outlook she quoted is optimistic for the availability of the technology.  Permitting, acquisition and construction for new technology is almost certain to take longer than proposed by the New York Draft Scoping Plan.

She goes on to point out that capacity for multiple months of electricity storage is needed. “Such storage would require an amazingly large quantity of materials to produce.”  She goes on to point out that: “Needless to say, if such storage were included, the cost of the overall electrical system would be substantially higher than we have been led to believe.”  I have found no indication whatsoever that these costs are adequately addressed in the Draft Scoping Plan.

Her third point is that despite many years of subsidies and mandates, today’s green electricity is only a tiny fraction of what is needed to keep our current economy operating.  Advocates have simply underestimated how difficult it would be to ramp up green electricity.  While New York may be ahead of many jurisdictions in its proportion of renewable energy that is primarily due to the hydro power resources at Niagara Falls and the Saint Lawrence River.  Any addition renewable development is going to be much more difficult to ramp up.

Tverberg s fourth point is renewables comprised a relatively small share of percentage of electricity in 2020.  She explains why this is important:

Wind and solar don’t replace “dispatchable” generation; they provide some temporary electricity supply, but they tend to make the overall electrical system more difficult to operate because of the variability introduced. Renewables are available only part of the time, so other types of electricity suppliers are still needed when supply temporarily isn’t available. In a sense, all they are replacing is part of the fuel required to make electricity. The fixed costs of backup electricity providers are not adequately compensated, nor are the costs of the added complexity introduced into the system.

If analysts give wind and solar full credit for replacing electricity, as BP does, then, on a world basis, wind electricity replaced 6% of total electricity consumed in 2020. Solar electricity replaced 3% of total electricity provided, and hydro replaced 16% of world electricity. On a combined basis, wind and solar provided 9% of world electricity. With hydro included as well, these renewables amounted to 25% of world electricity supply in 2020.

Her final two points paint a very pessimistic view of the future of the world economy.  Both are based on the idea that resource availability will eventually lead to shortages because there is no way the system can ramp up needed production in a huge number of areas at once so supply lines will break. She argues that this means “Recession is likely to set in.”  This is based on the following:

The way in which the economy would run short of investment materials was simulated in the 1972 book, The Limits to Growth, by Donella Meadows and others. The book gave the results of a number of simulations regarding how the world economy would behave in the future. Virtually all of the simulations indicated that eventually the economy would reach limits to growth. A major problem was that too large a share of the output of the economy was needed for reinvestment, leaving too little for other uses. In the base model, such limits to growth came about now, in the middle of the first half of the 21st century. The economy would stop growing and gradually start to collapse.

She goes on to argue that there are signs that this is happening now.

I don’t want to debate this worldview so I will just point out that The Limits to Growth states: “If all the policies instituted in 1975 in the previous figure are delayed until the year 2000, the equilibrium state is no longer sustainable. Population and industrial capital reach levels high enough to create food and resource shortages before the year 2000.”  This did not happen and I am uncomfortable accepting this belief completely.  If Chicken Little said “the sky is falling – this time for sure” I don’t think I would have more confidence in the projection. As a result, I am more inclined to support the analysis of Robert Bradley who disagrees with the Limits to Growth outlook.

One of the arguments for switching to renewable energy is that fossil fuels will eventually run out and we need to have a sustainable source of energy in place.  However, Tverberg’ s analysis explains that the same resource availability concerns are relevant for the materials needed to produce electricity from wind and solar facilities.  In particular, production of the rare earth elements needed for the magnets and batteries that are critical to wind and solar deployment may be less sustainable than continued development of fossil fuels.  Although these elements aren’t all that rare, they are assigned that descriptor because economically feasible deposits are difficult to come by – when the elements are discovered in high enough concentrations to be mined, they are found together in complex mixtures that require substantial effort to further purify. For instance, to manufacture each electric auto battery 25,000 pounds of brine for the lithium, 30,000 pounds of ore for the cobalt, 5,000 pounds of ore for the nickel, and 25,000 pounds of ore for copper must be processed. All told, you dig up 500,000 pounds of the earth’s crust for just – one – electric vehicle battery.  In my opinion, the combination of few locations where the elements are in high enough concentrations to economically process, the mass of ore needed to extract the elements and the environmental effects of the purification process combine to make their resource availability concern larger than fossil fuel availability.

Conclusion

I think that the points she makes about renewable variability, energy storage, and the lack of substantial progress implementing renewable energy despite many years of subsidies are important.  I don not believe that the Draft Scoping Plan adequately addresses those issues.

Although I disagree with some of the issues raised by Tverberg, I find her conclusion that “Modelers and leaders everywhere have had a basic misunderstanding of how the economy operates and what limits we are up against” compelling. This is especially important in the context that these modelers and leaders want to completely change the current energy system.  She argues that:

The real problem is that diminishing returns leads to huge investment needs in many areas simultaneously. One or two of these investment needs could perhaps be handled, but not all of them, all at once.

Despite the lack of historical evidence that resource availability problems cannot be resolved by human ingenuity, I think it is still appropriate to consider those problems.  In the context of a green energy transition, the question becomes which is the more feasible approach for the huge investments needed for global energy? In my opinion, I think that investments in fossil fuel infrastructure are the better choice because of the rare earth element sustainability issues described here.  That is an ironic conclusion given that one of the reasons that Climate Act proponents want to transition away from fossil fuels is because of their belief that fossil fuels will run out soon.

Note: the last paragraph in the conclusions was updated on 2/9/2022

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050 and the Draft Scoping Plan defines how to “achieve the State’s bold clean energy and climate agenda”.   However, there hasn’t been a feasibility plan that fully addresses the cost and technology necessary to provide reliable energy in the future all-electric net-zero New York energy system.  This is the fourth post in a series of posts describing the problem and the Scoping Plan’s failure to provide a proposal that adequately addresses the problem.  This post shows why extremely high prices are a feature and not a bug for any electric system that relies on intermittent wind and solar generation for the majority of its power.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  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. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. This draft includes results from the integration analysis on the benefits and costs to achieve the Climate Act goals. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023.

The Climate Action Council claims that the integration analysis was developed to estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act greenhouse gas emission limits and carbon neutrality goal. It incorporates and builds from Advisory Panel and Working Group recommendations, as well as inputs and insights from complementary analyses, to model and assess multiple mitigation scenarios. In addition, there is historical/archived information is available through the Support Studies section of the Climate Resources webpage, and can found as part of the Pathways to Deep Decarbonization in New York State – Final Report.

This is one of a series of posts describing the reliability problem and the Scoping Plan’s failure to provide a plan that adequately addresses the problem.  In the first post I described how the Texas blackouts of February 2021 are the inevitable outcome if the Scoping Plan does not address renewable variability correctly.  The second post explained why renewable variability requires massive amounts of over-building to replace existing firm capacity.  The New York Independent System Operator’s Comprehensive Reliability Plan documents reliability issues that one of the state’s organizations responsible for reliability is worried about relative to the transition to an emissions-free generating system.  This post shows why extremely high prices are an inevitable feature and not a bug for any electric system that relies on intermittent wind and solar generation for the majority of its power.

Renewable Variability and High Electricity Prices

A recent article at Timera Energy, Wind intermittency driving requirement for UK flexibility, includes the following figure.   The graph plots the daily wind generation in the United Kingdom and the electricity market day ahead (DA) price.  According to the article:

The UK requires significant wind capacity growth in order to reach challenging 2030 & 2035 decarbonisation targets. This renewable rollout comes with challenges however, with the grid already required to cope with periods of wind generation above 14 GW, and below 1 GW. Low wind events (which are often synchronised across NW Europe) have been driving prices upwards in an already high price environment, with only 3 GW of average wind generation coinciding with a National Grid electricity capacity market notice called on 24th Jan (the shaded grey area on the chart) and a £110/MWh day on day increase in DA prices.

The graph highlights why intermittent wind and solar will always lead to high prices.  First point is that there is tremendous variation in the wind energy resource.  Adding significant solar to the mix changes things a bit but the point is that there will always be times when renewable energy resources are very low.  When those resources are low, the price of electricity goes up a lot because the replacement resources are so expensive.  Importantly, also note that when the renewable resources are high, the price of electricity goes down a lot.  The remainder of this article will consider each of these issues in more detail.

Renewable Variability

As a meteorologist I am particularly concerned about the variability of wind and solar resources.  My over-riding concern is the need to develop a robust estimate of the minimum amount available.  If we don’t know that, then it is impossible to develop adequate resources that can provide electricity when it is needed most.  Unfortunately, it turns out that the highest loads (very cold and very hot weather) correlate very well to the lowest wind energy resources. 

I plan to eventually write an article about this issue in the context of New York.  For this post I will describe the issue by referring to a recent article:  Storage requirements in a 100% renewable electricity system: Extreme events and inter-annual variability reference that uses a German example.  The authors found that this issue is getting increased academic and political attention. Their analysis “explores how such scarcity periods relate to energy storage requirements”. The authors hypothesized a German 100% renewable electricity system and estimated how large the wind, solar, and energy storage components would have to be to provide reliable electricity at all times.  Their analysis used 35 years of hourly time series data. Interestingly, “While our time series analysis supports previous findings that periods with persistently scarce supply last no longer than two weeks, we find that the maximum energy deficit occurs over a much longer period of nine weeks”. This occurred because they found that multiple scarce periods can closely follow each other. This means that the energy storage systems have problems re-charging between energy deficit periods.  They conclude that focusing on short-duration extreme events or single years can lead to an underestimation of storage requirements and costs of a 100 % renewable system.

Low Renewable Resource Availability Impacts

The ultimate problem with low renewable resource periods is that backup resources are needed to maintain reliability.  The German example highlights a couple of points: an extensive time period is needed to find the worst case and the worst case is rare.  In my opinion, the Integration Analysis that supports the Draft Scoping Plan document did not evaluate a long enough time period to determine the worst case and I am sure that it did not address the re-charging problem identified in the German example.  In the current New York State electric system there are generating units that only operate to provide power during the several times a year when the load peaks.  In the future this kind of resource will be needed not only for peak load periods but also low renewable resource availability periods.

In an emissions-free electric system there are two possible solutions.  Most straight-forward is to use energy storage during low wind and solar resources periods because the storage could be built in New York such that it is integrated into the existing network.  Renewable advocates often argue that if there was a more extensive transmission system that power from locations where the wind and solar resources aren’t low could be used.

I believe that energy storage is the more likely solution for New York.  New York has unique reliability constraints because New York City and Long Island are essentially a load pocket.  Experience based on historical blackouts has led to the nation’s strictest set of reliability standards designed to promote reliability for New York consumers, including specific reliability rules for the New York City metropolitan area.  I believe that those rules will ultimately mean that energy storage resources will have to be used.

Unfortunately, there are issues with energy storage.  In the first place, long-duration energy storage batteries that would be a solution for wind and solar deficits are not commercially available. It is difficult to size currently available batteries properly and they are expensive.  One alternative is to overbuild wind and solar resources using the rationale that if the resources only can produce half as much expected then build twice as much to avoid energy storage costs.  However, as the German example shows the worst case is essentially no wind and solar so over-building is not a complete solution.  This is the first inevitable reason that an electric system dependent upon renewable resources is going to be expensive.

The advocates who claim that the wind is always blowing someplace overlook the logistics of such a solution.  The worst-case meteorological situation is a large high-pressure system that causes light winds over large areas.  Weather patterns are governed by atmospheric longwaves (Rossby waves) that affect the jet stream and pressure systems.  The point for this discussion is that “The length of longwaves vary from around 3,700 mi (6,000 km) to 5,000 mi (8,000 km) or more”.  In the worst case it is possible that a high-pressure system could cover a significant fraction of the longwave.  In other words, to get energy from where the wind is blowing for a wind lull on the East Coast you would have to go to the Rocky Mountains.  Imagine all the wind turbines and transmission lines needed to provide all the power needed for the eastern seaboard and all points in between for the worst case.  Worse, understand that these resources have to be there but won’t be used except for the, for example, one in ten-year wind lull.  A US graph similar to the UK graph example above would show prices much, much higher.

High Renewable Resource Availability Impacts

There is another aspect of over-building as a solution.  Current electric pricing schemes pay generators for their cost to operate.  Fuel costs are a main driver of their fees and wind has no fuel cost.  Consequently, wind generators can offer their power generated at little to no cost.  The UK graph shows that effect when the prices are low during periods of high wind generation availability.

This affects overall costs in multiple ways.  Because wind and solar displace dispatchable generation sources like nuclear and hydro, it affects their cost recovery.  Those resources are needed for reliability so subsidies are needed to keep them solvent. Those subsidies increase overall costs.

Donn Dears explained that there are other hidden costs.  For example, the latest natural gas combined cycle (NGCC) power plants can have efficiencies as high as 63%, but with wind and solar on the grid these plants would have to operate in following mode where they respond to wind and solar output ups and downs and adjust output to match intermittent variability.  This decreases their efficiency.  At some point this inefficiency will lead to higher consumer costs.

Conclusion

In my opinion, the biggest electricity planning problem is ensuring that resources are available for the worst case.  In the past this planning has focused on the annual peak load.  Decades of experience has led to a resilient system based on dispatchable resources that can meet load during these periods in New York but the experience in Texas in February 2021 indicates that problems can still arise. 

In the future, this planning will become more difficult because many of the generating resources are not dispatchable.  The Draft Scoping Plan does not adequately address the feasibility of meeting this challenge. The New York Independent System Operator 2021-2030 Comprehensive Reliability Plan notes: “While there are hundreds of projects in the NYISO interconnection queue, there are none that would be capable of providing dispatchable emission-free resources that could perform on a multi-day period to maintain bulk power system reliability. Such resources are not yet widely commercially available.”  This concern is basically ignored.

The United Kingdom graph of electricity prices and wind generation output illustrates the inevitable problem with renewable resource prices.  There are further examples that costs are increasing markedly there (here and here) and no sign that the Climate Action Council is aware of the problem.

I conclude that maintaining current reliability standards with an electric system that relies heavily on renewable energy sources must increase prices significantly.  This is because providing power during peak loads relies on a small set of resources that are rarely used.  In the current system when new resources are needed for this application combustion turbines were used because they are the cheapest dispatchable generating technology.  In any future zero-emissions system, the required resources will probably be energy storage which is much more expensive and has not been deployed for this application at scale.  Proponents that claim that because the wind is always blowing somewhere that all we need to do is develop more transmission underestimate the scale of the resources needed or the distances to locations where the wind is “always” blowing.  As a result, this “solution” would be even more expensive..