Climate Act – Page 53 – Pragmatic Environmentalist of New York

New York Climate Act: Is Anyone Listening to the Experts?

This article was published at Watts Up with That on February 6, 2022: New York Climate Act: Is Anyone Listening to the Experts?

A couple of recent posts here have highlighted the difficulties of a transition to an electric grid powered primarily by wind and solar using New York’s Climate Leadership and Community Protection Act (Climate Act) as an example. This post describes the New York Independent System Operator’s latest relevant report on this topic. The difficulties raised are so large that the question becomes is any leader in New York listening to this expert opinion.

Background

The Climate Act was passed in 2019 and became effective on 1/1/2020. The Climate Action Council has been working since then to develop plans to implement the Act. Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”. Three Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021. The focus of the recent posts has been the Climate Act target for a carbon free electric generating system by 2040.

The two recent posts showed that the benefits are over-stated and the costs under-estimated in the Draft Scoping Plan. My last post here explained that there is a new Draft Scoping Plan Overview available and showed that their claim that the “cost of inaction exceeds the cost of action by more than $90 billion is bogus. More recently the Manhattan Contrarian post More Focus on The Impossible Costs of a Fully Wind/Solar/Battery Energy System looked at the feasibility and costs of such a system using just solar resources as an example. The costs projected are far in excess of the Draft Scoping Plan estimates.

At the same time that the State has been developing its implementation plans for the Climate Act, the New York Independent System Operator (NYISO) has augmented their regular reliability planning process with supplementary analyses addressing the Climate Act challenge. The 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late year includes an excellent overview chapter “Beyond the Comprehensive Reliability Plan – Road to 2040” on this topic that is the focus of this post.

NYISO Reliability Planning

Appendix G of the CRP report describes the NYISO reliability planning process. The reliability planning component of the process consists of two analyses: the Reliability Needs Assessment (RNA) and Comprehensive Reliability Plan (CRP). The RNA evaluates the adequacy and security of the bulk power transmission facilities over a ten-year planning period, the resources in megawatts (MW), and the locations where required to meet projected needs. If necessary, the NYISO will request solutions for identified needs. The CRP determines if the proposed solutions are viable and sufficient then documents the solutions meet the identified reliability needs.

The CRP report itself provides an exhaustive description of all the reliability planning aspects considered in the existing process. The report describes reliability risk factors: “The Reliability Planning Process findings reflect the base case assumptions, which were set in accordance with applicable reliability rules and procedures. There are, however, numerous risk factors that could adversely affect the implementation of the plan and hence system reliability over the planning horizon. These risk factors may arise for several reasons including climate, economic, regulatory, and policy drivers.”

The report highlights some of the risk factors and provides the first instance where it is not clear whether New York State is listening to these experts. The CRP states “A growing amount of New York’s gas-turbine and fossil fuel-fired steam-turbine capacity is reaching an age at which, nationally, a vast majority of similar capacity has been deactivated and then concludes that “While transmission security within New York City (Zone J) is maintained through the ten-year period in accordance with design criteria, the margin would be very tight starting in 2025 and would be deficient beginning in 2028 if forced outages are experienced at the historical rate”. At the same time the New York State Department of Environmental Conservation (DEC) has rejected permits for new replacement generating facilities that addresses this risk factor. For example, the Danskhammer Energy Center proposed a replacement gas-fired combustion turbine but DEC denied the permit “The proposed project would be inconsistent with or would interfere with the statewide greenhouse gas emissions limits established in the Climate Act.”

Draft Scoping Plan

The Scoping Plan is supposed to provide the Climate Action Council with the information necessary to make decisions. The CRP describes several critical issues that must be addressed if the Climate Act transition to emissions-free generation is to succeed without creating a reliability crisis. The first is how to handle renewable resource intermittency. The second is whether battery storage devices will work as needed. It also raises issues with asynchronous wind and solar power and concludes with a discussion of the zero-emissions dispatchable resource needed to keep the system working. These are described in more detail in the addendum to this post. For the most part the Draft Scoping Plan ignores or glosses over all these issues.

The CRP defines renewable resource intermittency well. It notes that “the variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand. Solar resources will have little to no output during the evening and nighttime hours and reduced output due to cloud cover, while wind resources can experience significant and sustained wind lulls.” Additionally, it notes that “With high penetration of renewable intermittent resources, the system will need dispatchable, long-duration resources to balance intermittent supply with demand especially during extended periods where the intermittent resources are not available. These types of resources will need to be significant in capacity and have attributes such as the ability to come on-line quickly, stay on-line for as long as needed, maintain the system’s balance and stability, and adapt to meet rapid, steep ramping needs.” I don’t think the Draft Scoping Plan does an acceptable job describing the magnitude of this problem.

There is a section devoted to storage resources. It explains that seasonal power capability is the main consideration when evaluating most generation resources for their ability to serve load and provide for reliability. It goes on to explain that with energy storage resources, there are two other critical aspects that need to be considered. The first is the duration needed from the storage device and the second involves charging the storage device. Energy storage has been touted as the preferred alternative to peaking power plants but the CRP notes that “Since the ‘fuel’ for storage is electricity from local resources and the grid, the surplus energy in the ‘load pocket’ where storage is located needs to be more than the energy that is needed from the storage device including losses.” Furthermore, the CRP highlights the point that “battery storage resources help to fill in voids created by reduced output from renewable resources, but periods of reduced renewable generation rapidly deplete battery storage resource capabilities resulting in the need for longer running dispatchable emission-free resources”. Lastly, the CRP notes that Pathways to Carbon-Neutral NYC found “a stringent regulatory and siting regime for storage in New York City, including site-based limitations and fire codes regarding siting of battery storage”. I don’t think any of the people touting battery storage as a solution to intermittency understand the implications of these statements. For its part the Draft Scoping Plan ignores all the issues associated with energy storage.

The CRP section on Inverter Resources covers an aspect of the renewable transition that is very rarely considered. In short, existing generation is synchronized with the electric grid but wind and solar provide asynchronous power. This difference must be considered in order to maintain a reliable system. The Eastern Interconnection Planning Collaborative (EIPC) recently described a decline in grid performance when inverter-based resources displace conventional synchronous machines. The degradation in performance is due to a number of factors, including the loss of, or change in, location of reactive power resources, the lack of transmission facilities to transmit the energy to load, and/or the reduction in primary frequency response due to the loss of system inertia from the retirement of legacy synchronous generation. The Draft Scoping Plan does not address the implication of the following statement; “The ability of inverter-based resources to function properly often depends on the strength of the grid at or near the interconnection of the resources”. That means that if inverter-based resources are connected to a “weak” portion of the grid they “may be subject to instability, adverse control interactions, and other issues”. I think that it would be appropriate for the Draft Scoping Plan to discuss a situation where limitations of the transmission grid could cause wind and solar generation to not provide power to the grid but it does not.

The final relevant section of the CRP discusses the need for dispatchable, emissions-free resources. The CRP notes that the amount of dispatchable emission-free resources needed in their scenarios is over 32,000 MW in 2040, approximately 6,000 MW more than the total fossil-fueled generation fleet on the grid in 2021. The CRP states that providing this resource will “require an unprecedented level of investment in newand replacement infrastructure, and/or the emergence of a zero-carbon fuel source for thermal generating resources”. Furthermore, the CRP notes that the one-hour ramp requirements could be over 10,000 MW and a six-hour ramp of over 25,000 MW. Finally, they conclude that “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.” The Draft Scoping Plan response to this is claim that this resource could use green hydrogen as a place holder. Aside from the fact that it is not commercially available, the Scoping Plan does not address whether it can meet the technical criteria specified in the CRP.

Conclusion

There were many good comments to the post More Focus on The Impossible Costs of a Fully Wind/Solar/Battery Energy System replying to some comments that suggested the transition to zero emissions electricity is easily achievable. Subsequently I found the NYISO Comprehensive Reliability Plan document. It supports those who argued that such a transition will be difficult and included some additional arguments that I thought would be of interest to readers here. I encourage interested readers to download that document.

Ultimately, the question in this post is whether any of these concerns are being considered by the Hochul Administration and New York’s Climate Action Council. These political appointees are supposed to be guided by the Scoping Plan but based on my evaluation to date of the Draft Scoping Plan most of the key issues are over-looked. I showed a specific example where current DEC policy and actions directly contradict the concerns expressed in the CRP. I can only conclude that no one in power is listening to the reliability experts in New York. I cannot imagine how this can possibly end well.

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Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. More details on the Climate Leadership & Community Protection Act are available here. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

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Addendum: Highlights from NYISO Climate Act Planning Analyses

The biggest risk to future electric system reliability is the Climate Act. In order to respond, NYISO commissioned a couple of studies. The 2019 Climate Change Study – Phase I examined the impacts that climate change will have on temperature and the resultant impact on load as well as expected changes due to new policies. The most recent winter peak load was 22,542 MW and summer load was 31,723 MW. The study projects that load will increase in the winter to over 56,000 MW and in the summer to over 47,000 MW when the Climate Act is implemented. In 2020, the NYISO commissioned phase II of the Climate Change Study (“Climate Change Impact and Resilience Study”) that examined the resources needed to meet load in a 2040 scenario. That report concluded: “that the variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand. Solar resources will have little to no output during the evening and nighttime hours and reduced output due to cloud cover, while wind resources can experience significant and sustained wind lulls.”

The CRP did additional work looking at the wind lull problem during development. These analyses considered an arbitrary wind lull of week-long loss of wind energy of either projected NY on-shore or off-shore wind energy. Not surprisingly, they found that this type of event could exceed the loss of load expectation reliability criterion. The CRP concludes:

With high penetration of renewable intermittent resources, the system will need dispatchable, long-duration resources to balance intermittent supply with demand especially during extended periods where the intermittent resources are not available. These types of resources will need to be significant in capacity and have attributes such as the ability to come on-line quickly, stay on-line for as long as needed, maintain the system’s balance and stability, and adapt to meet rapid, steep ramping needs.

NYISO Executive Summary Road to 2040 – Storage Resources (Verbatim)

Solar and wind resources are dependent on variable meteorological conditions, and thus their generating output does not always coincide with demand. Energy storage allows for time shifting of generation to meet the timing of demand. Storage resources charge during times of surplus and then discharge at other times when the power is needed.
The seasonal power capability of suppliers would typically be the main consideration when evaluating most generation resources for their ability to serve load and provide for reliability. With energy storage resources, there are two other critical aspects that need to be considered. The first is the duration needed from the storage device. Load duration curves can provide the context for how long a storage device may be needed for reliability. The duration of need can be a significant amount of time during a given day. The second critical aspect involves charging the storage device. Since the “fuel” for storage is electricity from local resources and the grid, the surplus energy in the “load pocket” where storage is located needs to be more than the energy that is needed from the storage device including losses. The NYISO Climate Change Study noted that battery storage resources help to fill in voids created by reduced output from renewable resources, but periods of reduced renewable generation rapidly deplete battery storage resource capabilities resulting in the need for longer running dispatchable emission-free resources. Additionally, the “Pathways to Carbon-Neutral NYC,” which was commissioned by the New York City Mayor’s Office of Sustainability, Con Edison, and National Grid, noted a stringent regulatory and siting regime for storage in New York City, including site-based limitations and fire codes regarding siting of battery storage.

NYISO Executive Summary Road to 2040 – Inverter-Based Resources

There is so much detail in this section that I chose not to reproduce it verbatim. The first two paragraphs state:

With the planned increased to renewable energy resources on the system, there are several important considerations to evaluate in addition to traditional steady state and dynamics analysis. It is expected that many renewable generators will be connected to the grid asynchronously through power electronic devices (i.e., inverter-based resources). The Eastern Interconnection Planning Collaborative (EIPC) recently issued the “Planning the Grid for a Renewable Future” whitepaper indicating a decline in grid performance when inverter-based resources displace conventional synchronous machines. The paper finds that degradation in performance is due to a number of factors, including the loss of, or change in, location of reactive power resources, the lack of transmission facilities to transmit the energy to load, and/or the reduction in primary frequency response due to the loss of system inertia from the retirement of legacy synchronous generation.
The ability of inverter-based resources to function properly often depends on the strength of the grid at or near the interconnection of the resources. Grid strength is a commonly used term to describe how the system responds to system changes (e.g., changes in load, and equipment switching). In a “strong” system, the voltage and frequency are relatively insensitive to changes in current injection from the inverter-based resource. Inverter-based resources connecting to a portion of the system rich in synchronous generation that is electrically close or relatively large is likely connecting to a strong part of the system. Inverter-based resources connected to a “weak” portion of the grid may be subject to instability, adverse control interactions, and other issues.

This section goes on to describe measures related to this issue and where they are problems in New York. “The prevailing measure of system strength is the short-circuit ratio calculation. Short-circuit ratio is defined as the ratio of short-circuit apparent power (SCMVA) at the point of interconnection (POI) from a three-phase fault at the POI to the power rating of the resource.” “Another measure of system strength is voltage flicker caused by the connection of large reactive devices (such as a shunt reactive device or a large motor). Flicker not only affects lighting but has the potential to disrupt industrial processes and consumer electronics.” The document shows that there are some locations in New York where these problems will have to be addressed.

NYISO Executive Summary Road to 2040 – Dispatchable Resources

The final portion of this section discusses the need for significant amounts of dispatchable resources to address the intermittency of wind and solar. Results from several studies are mentioned.

The Climate Change Study looked at 100 x 40 (emission-free electric grid by 2040). It noted the significant amount of dispatchable resources that would be needed to meet that goal but did not describe the technology that would be able to provide a dispatchable resource, instead choosing to refer to generic dispatchable, emission-free resources. Not surprisingly, the Climate Change report found that a similar amount of dispatchable resources as the RNA case would be needed to maintain reliability under baseline assumptions. However, under CLCPA assumptions, the amount of dispatchable emission-free resources needed increases to over 32,000 MW in 2040, approximately 6,000 MW more than the total fossil-fueled generation fleet on the grid in 2021. The Climate Change Study noted that the current system is heavily dependent on existing fossil-fueled resources to maintain reliability and eliminating these resources from the mix “will require an unprecedented level of investment in new and replacement infrastructure, and/or the emergence of a zero-carbon fuel source for thermal generating resources” (emphasis added). The Climate Change Study did note that while the amount of installed capacity (MW) of dispatchable resources is significant, the amount of energy generated (MWh) required from such resources would likely not be significant, with the percent of total energy being in the range of 10% ― 20% range depending on the penetration level of intermittent resources.
The report “Pathways to Carbon-Neutral NYC,” issued April 2021 stated “Both low carbon gas and battery storage can supply dispatchable electricity to the grid. However, both technologies are untested at the scale required to deeply decarbonize the city. Batteries are limited by the amount of energy that they can store and how fast that energy can be discharged. Batteries also require capital to build and space to occupy. At the same time, low carbon gas availability is uncertain, and there is no policy framework to develop these resources at scale. While maintaining gas-fired electricity generation assets can avoid new capital expenditures, sources of renewable natural gas (RNG) would need to be connected to the existing pipeline gas transmission and distribution system, requiring investments. Additionally, RNG combustion still generates air pollutant emissions, which must be considered (emphasis added).”
The NYISO Grid in Transition study noted that it is generally recognized today that meeting New York load with high levels of intermittent renewable resource output, particularly solar and wind generation, will require the NYISO to have sufficient flexible, dispatchable and potentially fast ramping supply to balance variations in intermittent resource output. These variations will include not only short-term variations in output during the operating day as a result of changes in wind speed and cloud cover but also a sustained ramp up of solar output at the beginning of the day as the sun rises and a sustained ramp down of solar output at the end of the day as the sun sets. The Climate Change Study noted in the winter under the CLCPA scenario that the one hour ramp rate requirements could be over 10,000 MW and a six-hour ramp of over 25,000 MW.

This section of text concludes with the following text:

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.

Climate Act Draft Scoping Plan Overview – Next Steps

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”. The Climate Action Council has released a Draft Scoping Plan Overview that summarizes the plan. This article addresses Slide 17 of the Overview document that describes the next steps. I suspect that what I think should be done is different than what the State thinks should be done.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology. 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

According to the Climate Action Council Draft Scoping Plan page:

The Climate Leadership and Community Protection Act (Climate Act) was signed into law in 2019 as one of the most ambitious climate laws in the world. The law created the Climate Action Council (the Council), which is tasked with developing a draft scoping plan that serves as an initial framework for how the State will reduce greenhouse gas emissions and achieve net-zero emissions, increase renewable energy usage, and ensure climate justice. On December 20, the Council voted to release the draft scoping plan for public comment. January 1, 2022 marks the beginning of a 120-day public comment period to receive feedback from the public as the Council works to develop and release a final scoping plan by the end of 2022.

If you have reservations about the impact of the Climate Act on reliability, affordability, impacts on lifestyles, environmental impacts of alternate energy sources and understand that New York’s emission reductions cannot measurably affect global warming when implemented then you should submit comments. The Draft Scoping Plan Overview (Overview) summarizes the plan. If you agree with this discussion and conclusions, please consider submitting a comment making the same points.

Next Steps

Slide 17 of the Draft Scoping Plan Overview presentation is titled “Nest Steps” and states that the public comment period is open through end of April 2022. Three bullet points are included that describe what they expect for the comment period:

To identify areas where additional clarity is needed in the scoping plan
To further understand relevant needs and priorities of members of the public and how they connect to existing (or additional) climate strategies
Highlight where New York residents and businesses can participate in achieving the State’s climate goals

I don’t understand how the public comment period is supposed to work. I have submitted five comments since the comment period opened. My first comment submitted as soon as the comment period opened was to ask for a longer time to comment. The next three comments pointed out logistical problems: the latest integration analysis spreadsheets were not available, it would be nice if the scoping plan chapters were available separately, and an error in the PM2.5 spreadsheet. Most recently, I submitted a more substantive comment that included questions and pointed out an error in the Integration Analysis methodology.

It is not clear to me how my comments will be handled. The submittal form notes that “Please consider that all comments or any additional documents submitted will be made public and posted to the New York State Climate Act website.” As far as I can tell that capability is not available yet. More importantly, then what? In New York Department of Environmental Conservation regulatory proceedings, the comments are categorized and summarized. When the final rule is promulgated responses to the comments are published as part of the regulatory package of documentation. What will the Scoping Plan process do?

I believe my comments identified areas where more clarity is needed, but it is not clear how those issues will be resolved. I think the Draft Scoping Plan comments process has to be different than the regulatory process because there are missing pieces and parts in the evolving plan. The amount of material and complexity of the components is so large that the Draft Scoping Plan Overview (Overview) states that outreach will include information sessions and a speaker series. It seems obvious that something needs to be included to address important questions during the comment period so that the public, stakeholders, and Climate Action Council all have a complete understanding of issues related to the implementation plan.

As an example, consider the comments I submitted on February 1, 2022. My comments address two issues with the Draft Scoping Plan Social Cost of Carbon benefit calculations. In my first comment I noted that I cannot reproduce the values claimed for avoided societal costs from GHG emission reductions in the Scoping Plan. While the integration analysis spreadsheet documentation provides numerical backup for many of the graphics in the Draft Scoping Plan, similar documentation for numbers I consider critically important, such as anything related to costs and the societal benefits calculations, are not included. My comment specifically asked questions about the methodology and requested the backup numbers for the claim that these societal benefits were between $235 and $250 billion.

It seems obvious to me that an iterative process is necessary. I identified a data gap, they have to respond to the data gap in some way, and then I need time to develop a comment using the new information. In the DEC regulatory process there are no responses to comments during the comment period itself. If the Council follows that template, then it would prevent development of refined comments. That is unacceptable. Instead, it has to be an on-going process.

Once comments have identified areas where more clarity is needed, the Council has to provide explanations to the public. The overview notes that “Public and stakeholder input will occur in parallel to complementary continued analysis, speaker series input, and CAC discussion”. I see a timing issue here. Unless there is a cutoff for issues raised where more clarity is needed, how does the “complementary continued analysis, speaker series input, and CAC discussion” respond to those issues in sufficient time for stakeholders to comment. The Council may respond with something but they may not respond such that further commentary is not required. I think this supports my belief that the comment period has to be extended.

Consider for example, the second point of my comments. All the presentations and documents claim that the “Cost of inaction exceeds the cost of action by more than $90 billion”. The avoided economic impacts of damages caused by climate change provide the largest societal benefits for GHG emission reductions in the Scoping Plan. However, as I summarized in a blog post, that claim relies on an incorrect interpretation of the calculation methodology for this benefit. In order to increase the societal benefits, the Scoping Plan artificially increases the social cost benefits by counting them multiple times. The correct way to calculate the benefit is to multiply some estimate of NY GHG emission reductions by the DEC value of carbon values. For example, if all NY GHG emissions were eliminated in 2021 the benefits range from $46.7 and $56.4 billion depending on the emissions total used (1990, maximum annual between 1990 and 2019, or the most recent). Using the flawed lifetime approach in the Scoping Plan is analogous to someone who lost 10 pounds five years ago, kept it off and now claims that they lost 50 pounds. When just this over-counting error is corrected, the total societal benefits are negative not positive. The details supporting my argument are in my comments and in a white paper, Scoping Plan Costs and Benefits.

I think that the Council and the Draft Scoping Plan has to address this issue. Unless there is some kind of mechanism in the Scoping Plan comment process that mandates responses, then this result could be buried and ignored. As it stands now it is not clear that this issue will be discussed much less addressed as part of the process.

Discussion

The Overview presentation requests comments that identify areas where additional clarity is needed in the Draft Scoping Plan. It is supposed to lay out a path to meet the aspirational targets of the Climate Act. The overarching clarification needed is a feasibility analysis that demonstrates current levels of reliability and affordability can be maintained.

The Overview presentation also notes that public and stakeholder input will occur in parallel to complementary continued analysis, speaker series input, and Council discussion. It isn’t clear what that means. The public needs more information to provide meaningful comments. Speaker overview presentations should be designed to give them that information. Those presentations should specify the expected programs needed to meet the targets. For example, home heating electrification is a strategy that needs to be described along with the proscriptive measures necessary.

There also is a need to provide more detailed information for technical stakeholders. For example, last summer the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council. There never was any follow up for the Scoping Plan authors to explain how they addressed the concerns raised at that meeting. While many of the graphics in the Draft Scoping Plan are supported by Integration Analysis spreadsheets that document the numbers, none of the cost numbers are similarly supported. My comment about the social cost of carbon calculation is a third example of detailed information that is not currently available. These issues and others are so important and so complicated that structured and focused workshops are appropriate to fully understand what is proposed for the Scoping Plan for these and other issues raised.

Clearly, an iterative process needs to be incorporated into the comment process. The opportunity to ask questions and get answers is a necessary prerequisite to develop meaningful comments. If the process does not develop a robust Scoping Plan the resulting Energy Plan may not get it right. In February 2021 Texas blackouts spread across almost the entire state, left an unprecedented 11 million Texans freezing in the dark for as long as three days, and resulted in as many as seven hundred deaths. If New York’s unprecedented transition to a system that relies primarily on wind and solar resources gets its reliability planning wrong then the potential for a similar debacle is likely.

According to a Gothamist summary of the Climate Act: “Seggos, the DEC commissioner, said the draft plan is meant to generate a framework and solicit input on how the state can meet its climate goals, not provide a policy-by-policy cost estimate.” With all due respect to the commissioner, I believe it is inappropriate to rely on a “framework” to claim that renewable energy resources can provide adequate and reliable electric service affordably. Furthermore, a critically important criterion for the public is cost and this response suggests that they don’t plan to provide ratepayer cost impacts.

Conclusion

The Overview lists some talking points to describe the Draft Scoping Plan comment process. However, there is no substance so it is not clear how the process will proceed. It has been a month since the start of the comment period and the only information provided is the Overview.

I submitted a comment that addressed the main points of this post. The points in my comment included the following. A feasibility analysis accepted by all the organizations responsible for New York electric system reliability is the most important clarification item that needs to be addressed. The Council should prepare overview presentations of various aspects of the strategies needed to meet the Climate Act. The comment process also has to address technical issues related to reliability, affordability and benefits such that questions raised are answered is sufficient time that comments can be prepared based on the responses. Those technical issues are so important that it would be appropriate to schedule workshops that can focus on them.

If you agree with this discussion and conclusions, please consider submitting your own comment. The more people that comment the better and I am sure that the environmental advocacy organizations are asking their members to comment. I deliberately did not suggest specific comments for others because comments reflecting your personal take on the issue are more persuasive than copying someone else’s text.

Climate Leadership & Community Protection Act Residential Heating Cost Assumptions Update

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. Late last year before the Draft Scoping Plan was released I published an article that included a table that could be used to estimate the costs to replace existing home heating systems with all electric systems using their assumptions This post updates that information using the latest version of the integration analysis used in the Draft Scoping Plan and highlights another analysis of home heating electrification costs.

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. I refer readers to the previous article for additional background information.

Home Heating Electrification Cost Update

This estimate of electrification conversion costs for an individual home is based on data in the 2021-12-29-IA-Tech-Supplement-Annex I-Inputs-Assumptions spreadsheet, Tab: Bldg_Res Device Cost. The data are consolidated and the calculated values are available in a spreadsheet. The Scoping Plan Electrified Home Heating Integration Analysis Device Cost Assumptions table lists device costs for three categories of residential households: large multi-family, small multi-family and single family. Costs are listed for the three types of building shell upgrades and for air source heat pumps, electric resistance backup heat, and ground source heat pumps. The only data that changed in this table from the mid-November spreadsheet were the basic and deep shell device costs for large and small multi-family homes. The Scoping Plan Inputs Assumptions Workbook Residential Home Heating Electrification Costs table looks at the resulting combination of costs per household, building shell type, and type of existing heating system. I assumed in the table that ground source heat pumps would not require backup heat but if you disagree simply add that cost.

There is a lot of information on this table so I will explain how to I determined potential costs for my situation below. I live in a single-family residence heated with an efficient natural gas furnace. In my opinion one of the disadvantages of heat pump technology is that the output heat is relatively low compared to a combustion sourced furnace. The temperature at the register for a heat pump system is around 90^oF whereas in my house the temperature is around 120^oF. However there some cold rooms in my house even when the furnace if providing hot air despite my best attempts to adequately insulate and reduce air infiltration. I believe that in order to maintain safety and comfort throughout the entire winter my house would need improved thermal insulation, spots where there are thermal bridges would have to be fixed, airtightness improved, my double-glazed windows replaced with triple glazed windows, a heat recovery exchange system would have to be installed and that means a deep shell installation. I live in a suburb where I don’t believe that a ground source heat pump has enough yard space for installation so the Climate Act option is an air source heat pump.

According to the Integration Analysis used in Draft Scoping Plan the cost per device to replace my existing efficient gas-fired furnace is $3,085 more than another gas-fired furnace. In order to provide backup heat, the cost of electric resistance heat also has to be added to the cost of the air source heat pump. The cost differential is in the deep shell, single family, ASHP column on the efficient gas furnace row. The expected cost to replace my natural gas furnace with an air source heat pump would be $57,869. Note that for a “basic shell” upgrade the cost is “only” $19,142, or $38,727 less. These numbers did not change from the previous article.

My previous article went on to estimate total costs for electrification and determined that the total cost for residential electrification was on the order of $155 billion. Using the same methodology with the 2021-12-29-IA-Tech-Supplement-Annex I-Input-Assumptions spreadsheet data, the total cost for residential electrification drops down to $135 billion because of the basic and deep shell device costs for large and small multi-family homes. Note that this highlights the importance of the building shell upgrades as a main driver of cost.

The previous article noted issues with the documentation that were not addressed in the more recent Scoping Plan documentation. I noted that there wasn’t enough descriptive information to be able to determine the rationale for basic and deep shell upgrades necessary for a typical homeowner. I also noted that there wasn’t a spreadsheet table available that lists the net present value of net direct costs. I explained that while the graphics in many of the presentation figures and charts are backed up with spreadsheet tables this, arguably one of the most important set of numbers, has no spreadsheet table for documentation. This problem still exists.

Smarter NY Energy Residential Electrification Costs

There is an assessment of costs to convert to electric heating at the Smarter NY Energy website that was completed in September 2021. According to the assessment description:

It is still unclear whether CLCPA implementation will force you to pay big surcharges for putting in a new natural gas, propane gas or heating oil furnace, or actually force you to convert to a heat pump. Either way, the cost is likely to be huge.

Pragmatic Environmentalist Update: In Governor Hochul’s 2022 State of the State book released in January 2022, Part VI-B: Decarbonize New York’s Buildings, explains that the strategy to cut emissions from buildings will be “anchored by a robust legislative and policy agenda”. This includes changes to building codes to “commit to zero on-site greenhouse gas emissions for new construction no later than 2027 and enact nation-leading building codes legislation”. I interpret this to mean that in the 2022 legislative session we will see laws proposed to force New Yorkers to convert to electric heating first for new construction and eventually for all homes.

Proponents of heat pumps like to say that it only costs $7,000 to install a new heat pump. But that’s incredibly misleading. A single head heat pump might heat/cool a room or two. But an entire house? Get ready to shell out upwards of $20,000+ for a complete conversion. It is no simple thing.

Results reported from three different heat pump conversion programs run by the New York State Energy Research Development Agency (NYSERDA) and the Massachusetts Clean Energy Center (MCEC) confirm that typical homeowners would need to pay $20,00-$25,000 for a whole house conversion to heat pumps. A high efficiency gas furnace might cost ⅓ to ½ of this. Now consider that NY already has the 9th highest electric rates in the country source.

And cost doesn’t even address how uncomfortable many people feel using a heat pump in cold temperatures. Perhaps that’s why the Boston Globe reported that despite significant incentives, less than 500 homes had been converted to Heat Pump in MA in 2020, despite a goal of 100,000 per year.

The analysis of results from three different heat pump conversion programs is especially interesting in this context. Joe Uglietto from Diversified Energy Specialists, Inc. authored the report. He found that the MassCEC Whole-Home Air-Source Heat Pump Pilot Program included 53 existing building projects, the average conditioned square footage of home was 1,590 sq. ft., and the average project cost was $21,479. In the MassCEC Residential Air-Source Heat Pump Rebate Program 2014-2019 He estimated that 622 homes were given rebates that could provide 80% or more of the residences annual heat load. and the average conditioned square footage of home was 1,502 sq. ft. with an average project cost of $20,428. In the NYSERDA Residential Air-Source Heat Pump Rebate Program 2017-2019, 386 whole house installations were completed with an average conditioned square footage of home was 1,663 sq. ft. with an average project cost of $16,272.

There are several considerations for comparison with the Scoping Plan estimated costs. An air source heat pump in the Scoping Plan is estimated to cost $14,678 which is less than the cost than in these programs. However, I believe that all three programs included the cost of installation and because of the lack of documentation I don’t know if the Scoping Plan includes that cost. The author notes that in all three programs the existing systems were retained because “The existing heating system is typically retained as a supplementary heat source to compensate for the inadequacy of air-source heat pumps on cold days.” In the Scoping Plan the existing systems are removed and replaced with a supplemental electric heating system but this analysis notes that there is a cost for removal of the existing system. Again, I do not know if that cost is included in the Scoping Plan. Finally, note that the average conditioned space in these studies is 10 to 20% smaller than the median size of homes in Massachusetts and New York. That suggests that these estimates are smaller than could be expected for the New York for most homes.

Conclusion

This article updates my previous estimates for electrifying an existing residence using the integration analysis data. The table and spreadsheet can be used to estimate the costs to convert residences to electric heating consistent with the Climate Act mandates.

Because of changes in just basic and deep shell device costs for large and small multi-family homes the total estimated costs dropped from $155 billion to $135 billion. Due to a lack of understandable documentation, it is not clear how these numbers relate to the total net direct costs of on the order of $300 billion. Understanding that is important because these costs are over one third the total costs and just cover residential single, small multi-family and large multi-family electrification costs. It does not seem likely that this category would account for one third of the total costs.

The Smarter NY Energy assessment of costs to convert to electric heating analysis suggests the Scoping Plan estimates are low. In order to be credible the Climate Action Council needs to address the inconsistencies noted in this analysis.

Climate Leadership & Community Protectin Act Wood Burning Ban?

Late last year there was a story going around that New York State was planning to ban firewood in 2022. This post describes the reporting of that rumor and my interpretation of the effect of the Climate Leadership and Community Protection Act (Climate Act) on wood burning.

Climate Act Background

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. This integration analysis 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 that could be used to implement programs to achieve the emission reduction targets of the Climate Act.

Wood Burning Ban News Reports

A quick internet search for New York wood burning ban found four television station reports in response to viewer questions about a possible ban on wood burning in 2022. Syracuse WSYR, Utica WKTV and Watertown WWNY all ran segments that talked to DEC or other state officials and concluded that nothing was imminent. In this post I will use the Rochester News10 article as the illustrative example of the other news reports.

In the article: “Does the new law called the Climate Leadership and Community Protection Act (or “Climate Act“), outlaw woodstoves and fireplaces or just outdoor furnaces?” on 1/5/22, News10NBC’s Nikki Rudd looked into the question:

New York’s Climate Action Council has what’s called a Draft Scoping Plan. Click here to read it.
In scenarios analyzed wood consumption decreases by about 40%. That has led to headlines like this making the rounds online: “No More Heating with Firewood in New York?”
However, Haley Viccaro, a DEC spokesperson, says that 40% decrease in wood consumption is driven by building and device efficiency and increases in electrification of primary heating across all fuel types over time.
“Additionally, the analysis remains consistent across scenarios as to the contribution of remaining high-efficiency, low-emissions wood burning (for example, wood use for primary and secondary heating or industrial use) as well as some recreational wood combustion,” Viccaro said.
In layman’s terms, the plan right now does not include any recommendations specifically about wood burning. Viccaro wants to make it clear, the state is not considering legislation that would ban heating your home with firewood.
So if you read or heard that claim, it’s false.

Frankly, the response from DEC to this and the other reports might be true as presented but in the bigger picture they lack context. In the remainder of this post, I will provide background information for context so readers can judge for themselves whether or not a wood burning ban is inevitable.

Climate Act and Wood Burning

The Draft Scoping Plan document is huge. The document is 861 pages long and the body of the Scoping Plan report itself is 330 pages. There are eight appendices:

Appendix A: Advisory Panel Recommendations
Appendix B: CJWG Feedback on Advisory Panel Recommendations
Appendix C: JTWG Recommendations to the Council on Measures to Minimize the Carbon Leakage Risk and Minimize Anti-Competitiveness Impacts of Potential Carbon Policies and Energy Sector Mandates
Appendix D: Power Generation Sites Identified by the JTWG
Appendix E: JTWG Recommendations to the Council on Issues and Opportunities Related to the EITE Entities
Appendix F: Environmental and Health Data for Quantifying Health Benefits of Climate Policy
Appendix G: Integration Analysis Technical Supplement
Appendix H: Adaptation & Resilience Recommendation Components

In order to determine how the Scoping Plan treats the future it is necessary to delve into Appendix G that contains two sections with extensive documentation. Section I Techno-Economic Analysis has five chapters, 76 figures, and 22 tables in its 122 pages. Appendix G Section II Health Co-Benefits Analysis two chapters, 3 tables and 14 figures in its 39 pages. The Inputs Workbook spreadsheet has 49 tabs with data and the Key Drivers spreadsheet has 68 tabs with data. I am 100% sure that DEC spokesperson Haley Viccaro does not know exactly what the Scoping Plan has to say about wood burning. Instead, she is just responding from the public narrative script. I am also sure that most readers have no desire to sift through the document to figure out what the document says about wood burning. In this section I will provide that information.

I believe the primary consideration for those people who asked the question whether the Climate Act would ban wood burning as an energy source were worried about home heating. Home heating is addressed in Chapter 12, Buildings. It (page 129 of 861 in the document) states that:

Decarbonizing building operations describes the elimination of GHG emissions from building end uses through improving the building envelope and switching from equipment and systems powered by burning gas, oil, or other fossil fuels to highly efficient equipment and systems powered by emissions-free energy sources. In addition, embodied carbon associated with building construction can be reduced through building reuse and through using lower carbon materials or carbon-sequestering products.

In this context the question of the wood heating ban comes down to interpretation of the phrase “elimination of GHG emissions from building end uses”. If wood burning emissions are considered GHG emissions then they will be banned someday, somehow.

The Buildings Chapter in the Scoping Plan goes on to describe the vision for 2050, the target date for the net-zero target. The Scoping Plan is all in for heat pump technology:

The Integration Analysis indicates that by 2050, the large majority of buildings statewide will need to use electric heat pumps for heating and cooling to meet the Climate Act requirements. This approach depends upon 100% zero-emissions electricity by 2040 and 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 Integration Analysis finds that widespread building electrification is needed even with the strategic utilization of low carbon fuels that are projected to be available, notably the use of renewable natural gas to meet back-up heating demands in a small proportion (less than 10%) of electrified buildings and the utilization of green hydrogen to power a smaller Con Ed district system by 2050. To manage the impacts of widespread electrification on the State’s electric grid, it will be important for buildings to adopt smart controls, energy storage, and other load flexibility measures. Policymakers also should assess the differential grid impact, costs, and benefits of cold climate air source, ground source, and community thermal heat pump systems; at this writing, related analysis in underway.

In this context the reference to “large majority of buildings” leaves the possibility that a minority of buildings could use wood burning for space heating but the strategic utilization clause does not mention wood burning as an option.

Because it provides context to the emission reduction strategies, let me unpack what they are saying in the rest of this section in layman’s terms. The Scoping Plan presumes that converting the majority of homes to electric heat pumps and upgrading building envelopes will be affordable and safe. Note, however, that the Scoping Plan does not include any cost estimates for consumers which I believe is major criterion for affordability. The safety question boils down to one over-riding concern. What are we supposed to do when there is an extended electricity outage if, for example, there is an ice storm or their plans for 100% zero-emissions that rely on intermittent wind and solar don’t work? When they say “To manage the impacts of widespread electrification on the State’s electric grid, it will be important for buildings to adopt smart controls, energy storage, and other load flexibility measures” what they mean is they want to be able to control your electric appliances to the point that when there are electric system issues, they will decide how much energy you get. When they mention “Policymakers also should assess the differential grid impact, costs, and benefits” of the electric heating options, what they mean is we are not sure this will work but we are crossing our fingers and hoping that it will. In February 2021, there were extended, widespread, expensive, and deadly electric outages in Texas because energy planners there did not develop a resilient energy system. If New York’s plan gets any one of many novel aspects of the Scoping Plan wrong the same thing will happen here.

In Section 12.2 of the Buildings Chapter, strategies are listed for the relevant theme for wood burning in Table 9. The theme is titled “adopt zero emission codes and standards”. The first strategy is to adopt new building codes for new construction that are “all-electric”. The second strategy specifies

“zero emissions equipment” for existing buildings. In my opinion this strategy explicitly prohibits wood burning because it is neither “all-electric” or “zero emissions”.

One final point with respect to the buildings sector strategies is relevant. In Governor Hochul’s 2022 State of the State book, Part VI-B: Decarbonize New York’s Buildings, explains that the strategy to cut emissions from buildings will be “anchored by a robust legislative and policy agenda”. This includes changes to building codes to “commit to zero on-site greenhouse gas emissions for new construction no later than 2027 and enact nation-leading building codes legislation”. I interpret this to mean that in the 2022 legislative session we will see laws proposed to enact whatever they mean by this language. Also note that the interpretation of wood burning as a greenhouse gas affects a possible ban.

Health Benefits

There is another aspect that indirectly bears on the possibility of a potential ban on wood burning. The Scoping Plan claims health benefits totaling $165 to $170 billion across the three mitigation scenarios due to improvements in air quality. According to Appendix G Integration Analysis Technical Supplement Section II page 30: “The health benefits are driven by reductions in all air pollutant emissions, but reductions of primary PM2.5 are the strongest driver of the benefits.” It goes on to say that “Of the one quarter of the PM2.5 emissions that is from combustion sources, nearly all of it is due to residential or industrial wood combustion.” Importantly: “When all fuels are considered, the residential and commercial sector accounts for the majority of the PM2.5 emission reductions, due mostly to reductions in residential wood combustion.” These impacts are illustrated in Figure 11 from the supplement document.

On page 29 in Section II of Appendix G the Scoping Plan states: “approximately 40% of the projected benefits are associated with reduced wood combustion in industrial, commercial, and residential uses.”. It is not clear to me and I have been unable to find an explicit statement describing how the Plan intends to get that 40% reduction. On one hand the authors could be so enamored with the purported benefits of electric heat pumps for heating that they think everyone will willingly convert. I think that it is naïve to believe that many people using firewood for heating will voluntarily convert because heating reliability and affordability is valued so highly by them that they won’t be convinced to switch.

With respect to the wood burning ban, the health results could be used to justify it. There also has been a push to develop “benefits” from the Climate Act so that could also mean they will decide that a ban is appropriate. This is certainly an unresolved issue.

Council and Advisory Panel Membership

The final driver for a wood burning ban comes from some of the more vocal members of the Climate Action Council. The Council has 22 voting members: 12 political appointees who head various state agencies and the rest non-agency experts: two appointed by the governor, three each appointed by majority leaders of the Assembly and Senate and one each appointed by the minority leaders of the Assembly and Senate. All the governor appointments were made by former governor Andrew Cuomo. The ten at large members shall “include at all times individuals with expertise in issues relating to climate change mitigation and/or adaptation, such as environmental justice, labor, public health and regulated industries”. The two minority appointments are from regulated industries. All the other appointees allegedly have expertise in issues related environmental justice, labor, public health or renewable energy. The bottom line is that the recommendations and comments from these people were clearly biased against combustion energy sources.

There is another aspect of the membership of the Council and the Advisory Panels that is relevant for a potential wood burning ban. I have previously described how the precautionary principle is driving the CLCPA based on the work of David Zaruk, an EU risk and science communications specialist, and author of the Risk Monger blog. In a recent post, part of a series on the Western leadership’s response to the COVID-19 crisis, he described the current state of policy leadership that is apropos to this discussion:

“The world of governance has evolved in the last two decades, redefining its tools and responsibilities to focus more on administration and being functionary (and less on leadership and being visionary). I have written on how this evolution towards policy-making based on more public engagement, participation and consultation has actually led to a decline in dialogue and empowerment. What is even more disturbing is how this nanny state approach, where our authorities promise a population they will be kept 100% safe in a zero-risk biosphere, has created a docilian population completely unable and unprepared to protect themselves.”

His explanation that managing policy has become more about managing public expectations with consultations and citizen panels driving decisions describes the membership of the Advisory Panels and Climate Action Council. He says now we have “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”. That is exactly what has happened during the development of the Scoping Plan. Facts, strategic vision, and risk trade-offs were not core competences for the panel members. The elimination of combustion emissions and social justice concerns of many, including the most vocal, were more important than affordable and reliable energy. For example, some of these people argue that the Climate Act bans combustion and when reliability issues are raised, the response is basically tough – it’s the law. At its core people who rely on wood burning for home heating are doing so because they want reliable energy that they can afford. In my opinion, many of the council and advisory panel members just do not relate to the reasons why people rely on wood burning for heat.

Conclusion

Based on my research and review of the Climate Act and the Scoping Plan I agree with the strict interpretation that there will not be a ban on wood burning in 2022. However, the real question is whether a wood burning ban is inevitable someday as part of the Climate Act implementation process. This post lists enough conflicting information to make the point that the answer is not clearly obvious.

There are multiple reasons to believe a wood burning ban is inevitable. If wood burning emissions are considered GHG emissions, then interpretation of the phrase “elimination of GHG emissions from building end uses” means a ban is likely. I believe this is more likely than not. In the Scoping Plan Buildings Chapter, strategies to adopt new building codes for new construction explicitly say “all-electric” and the second strategy specifies “zero emissions equipment” for existing buildings. In my opinion this strategy explicitly prohibits wood burning because it is neither “all-electric” or “zero emissions”. I suspect that the health benefit claims with respect to eliminating wood burning ban will be used to justify it, but this is certainly an unresolved issue. Motivated members of the Climate Action Council clearly advocate for banning all combustion and that includes wood burning.

On the other hand, there is nothing specific that clearly indicates that wood burning bans are necessary. There is clear language noting that wood consumption decreases by about 40% for all the scenarios but I could not figure out how that is supposed to occur. In the description of building description there is a reference suggesting that decarbonization applies to a “large majority of buildings” and that leaves the possibility that a minority of buildings could use wood burning for space heating.

In conclusion, I admit that this is an unresolved issue but I believe the preponderance of information suggests that a wood firing ban is inevitable at some point. The uproar at the end of last year indicates that this is a hot button issue with many people. The official story for the Scoping Plan that there will be no immediate ban on wood burning is consistent with the Scoping Plan. However, if the implementation plan eventually bans the sale of wood stoves wood boilers, or fireplace inserts that is consistent with the Scoping Plan and not a direct ban on wood burning either. Of course it also means that someday you will no longer be able to burn wood because your wood burning appliance is worn out and cannot be replaced.

If you are concerned about a potential ban on wood burning for heating, I recommend that you do the following. Get educated about the Climate Act so that you understand exactly what is involved for New Yorkers to meet the Climate Act targets. Submit comments saying that banning wood burning is a safety risk when there is an electrical outage and will be more expensive so there should be no ban. Contact your legislators to let them know that you are concerned. Of special interest in 2022 is the commitment to zero on-site greenhouse gas emissions for new construction no later than 2027 and to “enact nation-leading building codes legislation” proposed by Governor Hochul. If you aren’t ready for all-electric home mandates then comment. I suggest you also make the point that the Climate Act targets and schedule need to be reassessed with respect to wood burning and many other issues.

Scoping Plan Reliability Feasibility – Renewable Variability

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 second post of a series of posts describing the problem and the Scoping Plan’s failure to provide a proposal 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. This post shows that solar variability markedly increases the resources needed.

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. This integration analysis 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.

Renewable Variability

I have called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020. On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council. All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed. A recent article by David Wojick at PA Pundits International titled Unreliability Makes Solar Power Impossibly Expensive does a great job describing how renewable resource availability affects reliability.

Wojick explains that meteorological variability strongly affects renewable resource availability. In order to reliably provide electricity from an electric grid that depends on wind and solar planners have to determine the worst case. In his article he illustrates the problem using an example for solar energy of five days of cloudy weather that reduces the energy available to essentially zero. In the following I excerpt his description, highlight key points and provide indented and italicized comments.

Unreliability Makes Solar Power Impossibly Expensive

How many successive days of dark cloudiness to design for is a complex question of local and regional meteorology. Here we simply use 5 days but it easily could be more. Five dark days certainly happens from time to time in most states. In Virginia’s case it can happen over the whole Mid-Atlantic region, so no one has significant solar power. This rules out buying solar power from the neighbors.

The Scoping Plan projects 2050 solar capacity between 60,604 and 65,210 MW for three mitigation scenarios. Given the latitude of New York which translates into short days in the winter, the effect of the Great Lakes on Upstate cloudiness in the winter, and potential for significant snowfall over the entire state, it is reasonable to expect that none of this capacity will be available for at least five days.

Reliability requires designing for these relatively extreme events. With conventional generation you design for maximum need for power but with wind and solar you also have to design for minimum supply. That minimum case is what I am looking at here.

The required battery capacity is simple. Five days at 24 hours a day is 120 hours. To supply a steady 1,000 MW that is a whopping 120,000 MWh of storage. We already have the overnight storage capacity for 16 hours so we now need an additional 104 hours, which means 104,000 MWh of additional storage.

Keep in mind that today the available Li ion batteries only provide 4 hours of energy.

However, the required additional generating capacity to charge these dark days batteries is far from simple. It all depends on how long we have to do the charging. The more time we have the smaller the required generating capacity.

It is vital to get the dark days batteries charged before the next dark days arrive, which in some cases might be very soon. This too is a matter of meteorology. To be conservative we here first assume that we have two bright sunny days to do the job.

Two days gives us 16 hours of charging time for the needed 120,000 MWh, which requires a large 7,500 MW of generating capacity. We already have 3,000 MW of generating capacity but that is in use providing round the clock sunny day power. It is not available to help recharge the dark days batteries. Turns out we need a whopping 10,500 MW of solar generating capacity.

This 10,500 MW is a lot considering we only want to reliably generate 1,000 MW around the clock. Moreover, some of this additional generating capacity will seldom be used. But reliability is like that due to the great variability of weather. In conventional fossil fueled generation the extreme event that drives design is peak need (also called peak demand). Special generators called “peakers” are used for this case. In the solar case the special equipment is batteries or other forms of storage.

This is an important point. In order to provide electricity when it is needed a significant fraction of generating capacity will seldom be used. If it is not used much it will be difficult to pay for it. Inevitably, it will mean very high electricity prices during those peak periods.

Note that if we have 5 days to recharge the dark days batteries then the amount of required generation is a lot less. Five days gives us 40 hours to charge the 120,000 MWh so one only needs 3,000 MW of additional generating capacity, added to the 3,000 MW we need to produce daily power on sunny days.

I cannot over emphasize the importance to determine the frequency, duration, and intensity of low wind and solar resource availability. If it is found that New York can only expect 2 full days will be available to recharge the batteries, then the Scoping Plan projected 2050 solar capacity between 60,604 and 65,210 MW only produces between 5,772 and 6,211 MW of reliable solar energy. On the other hand, if New York can expect 5 full days will be available to recharge the batteries that same capacity produces between 10,101 and 10,868 MW of reliable solar energy.

At this point we need 120,000 MWh of battery storage and from 6,000 to 10,500 MW of generating capacity, in order to reliable supply 1,000 MW of round the clock power.

If it is found that New York can only expect 2 full days will be available to recharge the batteries, then the Scoping Plan projected 2050 solar capacity between 60,604 and 65,210 MW will require between 692,619 MWh and 745,260 MWh of energy storage to produce the 5,772 and 6,211 MW of reliable solar energy.

These large numbers occur because following a period of dark cloudy days we are doing three things simultaneously during the daylight generating hours. We are (1) generating 1,000 MW of immediately used electricity, while recharging both the (2) nighttime batteries and the (3) dark days batteries.

Note too that the numbers should actually be bigger. Batteries are not charged 100% and then drained to zero. The standard practice is to operate between 80% and 20%. In that case the available storage is just 60% of the nameplate capacity. This turns the dark days 120,000 MWh into a requirement for 200,000 MWh.

If it is found that New York can only expect 2 full days will be available to recharge the batteries, then with this constraint the Scoping Plan projected 2050 solar capacity between 60,604 and 65,210 MW will require between 1,154,364 MWh and 1,242,100 MWh of energy storage to produce the 5,772 and 6,211 MW of reliable solar energy.

The cost of the dark days case

Wojick also calculates costs in his article.

A standard figure from EIA for the cost of grid scale battery arrays is $250 per kWh, which gives $250,000 per MWh. At this cost the required 200,000 MWh of storage for around the clock 1,000 MW is $50 billion.

In order to provide adequate energy storage for the Scoping Plan solar capacity costs range between $288.6 billion and $310.5 billion for the three mitigation scenarios.

A standard EIA figure for PV solar capacity is $1300 per kW or $1,300,000 per MW. This makes the 6,000 to 10,500 MW cost $7.8 to 13.7 billion.

The Scoping Plan solar capacity costs range between $78.8 billion and $84.8 billion.

This makes $60 billion for just 1,000 MW a good rough estimate for stand-alone solar capacity to meet the 5 dark cloudy days case. (Adding wind power does not reduce this number because the 5 dark days may also see zero wind output.)

The total Scoping Plan solar capacity costs range $367.4 billion and $395.3 billion!

There is a major disconnect between Wojick’s cost estimate and the values presented in the Scoping Plan. According to Figure 51 from Appendix G, Section I, the Scenario 2, “Strategic use of low-carbon fuels” net present value of costs relative to the reference case (2020-2050) are $310 billion; Scenario 3, “Accelerated transition away from combustion”, costs are $290 billion; and Scenario 5, “Beyond 85%” costs are $305 billion. If just the cost for the solar resources necessary are over $367 billion, then something has to be reconciled.

Scoping Plan Appendix G, Section I states that “The integration analysis includes calculations for three different cost metrics: Net Present Value (NPV) of net direct costs, annual net direct costs, and system expenditure” and notes that “the NPV of levelized costs in each scenario incremental to the Reference Case from 2020-2050”. Depending on the Reference Case costs that could account for some of the difference. However, the Scoping Plan does not include any tables that list costs for the Reference Case and Scenarios. The only data available are in figures. At the time of this writing, January 23, 2022, the spreadsheet resources that provide numbers used in most figures are not available for any of the figures with cost numbers. As a result, I cannot reconcile the cost numbers shown here and the Scoping Plan costs.

Conclusion

Wojick’s analysis provides a simple, easily replicated description of the effect of day length on solar resource availability. He demonstrates that accurately determining the expected solar resource availability is critically important for reliability planning. It is also obvious from his work that someone says solar generation is cheaper than fossil-fired generation, that person is not considering all the reliability requirements.

There are implications to the Scoping Plan. Scenario 2, “Strategic use of low-carbon fuels” projects 2050 solar capacity of 64,621 MW; Scenario 3, “Accelerated transition away from combustion”, projects 60,604 MW; and Scenario 5, “Beyond 85%” projects 65,210 MW. Wojick shows that if it is found that New York can only expect 2 full days will be available to recharge the batteries needed to provide power when the sun isn’t shining, then the Scoping Plan projected 2050 solar capacity range of 60,604 to 65,210 MW only produces between 5,772 and 6,211 MW of reliable solar energy. On the other hand, if New York can expect 5 full days will be available to recharge the batteries the Scoping Plan capacity produces between 10,101 and 10,868 MW of reliable solar energy.

I have been unable to determine how the Scoping Plan addresses the issues raised. I don’t think the integration analysis that forms the basis of the Scoping Plan adequately determined the worst-case meteorological conditions for wind and solar availability. I don’t know how the integration analysis addressed the reliability issues associated with wind and solar resource availability but I am sure that the New York Independent System Operator and New York State Reliability Council have not reconciled their reliability responsibilities with the Scoping Plan. Clearly the Climate Action Council must address this problem.

Scoping Plan Reliability Feasibility – Scope of the Problem

Background

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. The integration analysis 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.

February 2021 Texas Electricity Debacle

A recent article in Texas Monthly describes the deadly blackout that hit Texas in February 2021. Russell Gold’s article “One year after the deadly blackout, officials have done little to prevent the next one—which could be far worse” does an excellent job describing what happened. He explains that as the frigid air behind the winter storm blanketed the state and the electric gird operators started dealing with resulting problems:

Nobody yet knew just how widespread the blackouts would become—that they would spread across almost the entire state, leave an unprecedented 11 million Texans freezing in the dark for as long as three days, and result in as many as seven hundred deaths. But neither could the governor, legislators, and regulators who are supposed to oversee the state’s electric grid claim to be surprised. They had been warned repeatedly, by experts and by previous calamities—including a major blackout in 2011—that the grid was uniquely vulnerable to cold weather.

The integration analysis recognizes that the future New York electric grid will be more vulnerable to cold weather. When electricity is universally used for heating, cooking, hot water, and transportation the peak loads will occur in winter. The analysis also recognizes that solar energy resources will be reduced in the winter if for no other reason the days are shorter and that multi-day wind lulls mean that non-fossil fuel energy resources availability will be an issue. However, the reality is that the integration analysis does not provide enough detail to be considered a cost and technology feasibility study, particularly with regards to how the cold weather wind lull problem will be handled.

I highly recommend reading Gold’s article for its description of how the blackouts unfolded. There is a gripping description of how the blackout disaster unfolded for the grid operators and a very good explanation of the issues they faced.

Two days before Mecke was awakened in his office, ERCOT had held an emergency conference call to warn the state’s utilities and rural electric cooperatives that blackouts were likely. ERCOT officials said the grid might have to shed as much as 7,500 megawatts—effectively darkening roughly one of every eight homes in the state. That’s nearly twice as much as the last controlled load shed, in 2011, when rolling blackouts had lasted as long as eight hours, which in turn was four times longer than the previous large-scale blackout, in 2006.
The worst-case scenario ERCOT had gamed out, what it called “extreme winter,” contemplated a record-setting demand of 67.2 gigawatts. Electricity consumption blew past that mark at 7 p.m. on February 14. Meanwhile, electricity supply continued to dwindle as underinsulated power plants went down, one after another.
For the grid to function properly, the supply of electricity must always match demand; this equilibrium is reflected in the grid’s frequency, which usually remains steady at 60 hertz. Power plants across the state are tuned in to the frequency, and they automatically increase or decrease generation to maintain equilibrium. The grid is like a giant synchronized machine, its components linked across hundreds of miles, from Midland to Houston, from Amarillo to Brownsville. On this night, as demand drastically outpaced supply, the frequency dropped and the vast machine began churning faster. But eventually it couldn’t compensate on its own.
By 1:23 a.m., ERCOT could no longer delay action. An operator in its control room picked up the hotline phone, which was wired to sixteen of the state’s utility companies, and ordered a thousand-megawatt load shed statewide. “You practice for this for years,” Mecke said. “You hope it never happens.”
In fact, a few hours earlier, he’d run his coworkers through a simulation of a nearly identical load shed. When the time came to carry out the operation for real, there were no hiccups. “It was surprisingly calm,” he said. “It was smooth.” Within seconds, electricity in parts of San Antonio began to blink off. Mecke, hopeful that the grid would stabilize, breathed a sigh of relief. The calm was short-lived.
The frequency should have risen after the load shed, but instead it kept falling. It was “nerve-racking,” said Mecke.

At 1:47 a.m., the hotline phone rang again. Everyone in the CPS control center stopped what they were doing. ERCOT needed another thousand megawatts cut. Because of coronavirus precautions, CPS executives weren’t in the control room. Rudy Garza, the chief customer officer, tracked the frequency’s dangerous decline on his phone, texting back and forth with industry friends and former coworkers from across the state. “We were scared,” he said.
CenterPoint Energy, a utility in Houston, runs a control room similar to that of CPS. Eric Easton, CenterPoint’s vice president of real-time operations, was hastening to execute the second round of blackouts when the hotline phone rang for the third time, at 1:51 a.m. ERCOT ordered another three thousand megawatts—more than the first two combined. “Calls started coming in so fast that they were overlapping,” said Easton. “When are we going to stop shedding load?” he wondered.
But the situation was only growing more dire. At the precise time of the third call, the frequency reached a critical threshold: 59.4 hertz. The Texas grid, which has been around in some form since World War II, had only once in its history fallen this low. Automated turbines across the state began spinning even faster to produce more electricity, but when the frequency dips below 59.4 hertz, the turbines reach speeds and pressures that can cause catastrophic damage to them, requiring that they be repaired or replaced. This scenario was unlikely because, to prevent it, the grid automatically triggers a nine-minute countdown when it strikes 59.4 hertz. If the frequency did not rise in time, power plants would shut down and the grid would begin turning itself off completely. This would leave all 26 million Texans who relied on the ERCOT grid without power for weeks or months.
A few more minutes ticked by. The frequency kept falling, touching 59.302 hertz, yet another alarming precipice. At 59.3 hertz, human operators are taken out of the equation: they are too slow to make the urgent adjustments that are needed to stabilize the grid. The system is programmed to automatically start blacking out as many areas as are necessary to balance power supply and demand. But in this scenario, that fail-safe may not have worked because so many areas had already been manually cut off. “We were on the very edge,” said Easton.
In a last-ditch effort to prevent the grid’s collapse, ERCOT placed a fourth hotline call, at 1:55 a.m., and ordered another 3,500 megawatts. All across Texas, grid operators were moving as quickly as they could, blacking out more and more neighborhoods, but they were running out of options. As the countdown approached zero, the frequency suddenly shot back up. The immediate crisis was over—the last-second load shed had worked—but for most of the following day, the grid remained dangerously unstable.
It is hard to fathom the devastation a total shutdown would have wreaked. Bill Magness, then the CEO of ERCOT, would explain as much to the Texas Senate ten days later. Magness is a lawyer with a buzz cut and ramrod-straight posture who spent time in the nineties and aughts as a practicing Buddhist. “What my team and the folks at the utilities in Texas would be doing is an exercise called ‘black start,’ ” he said. A black start would have required carefully rebooting a few power plants at a time and using them to jump-start others, thereby restoring the grid piece by piece. It’s not a matter of flipping switches. The steps required for a black start are numerous, complex, and delicate. No one knows how long that process would take, because no one has ever needed to do it. Magness said it would have been weeks at least.

Discussion

Gold also gives his opinion why it happened and how to fix it. I am not familiar enough with the Texas electric energy system to support or dispute his arguments. In this instance it does not matter. For whatever reason the Texas electric system did not have enough generating resources available to meet the peak load requirements when Texans needed it most. If New York’s implementation plan for net-zero leads to a similar situation where there isn’t enough energy available the result will be the same: massive costs and deaths due to a lack of heat.

I have called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020. On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council. All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed. It is my understanding that the New York Independent System Operator and the New York State Reliability Council have reliability planning responsibilities. How can the Climate Action Council propose a Scoping Plan without reconciliation with those entities?

According to a Gothamist summary of the Climate Act: “Seggos, the DEC commissioner, said the draft plan is meant to generate a framework and solicit input on how the state can meet its climate goals, not provide a policy-by-policy cost estimate.” With all due respect to the commissioner, I believe it is inappropriate to rely on a “framework” to claim that renewable energy resources can provide adequate and reliable electric service affordably.

Conclusion

At the September 13, 2021 meeting of the Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed. The fact is that the situation in Europe this winter is a harbinger of things to come in New York. The Draft Scoping Plan considers control measures in isolation and ignores the ramifications observed elsewhere for the measures. The Draft Scoping Plan’s strategies to decarbonize the economy are a classic example of the ancient political strategy of “winging it”. Sadly, the Climate Action Council is basing the future of New York’s electricity grid on a plan that relies, to a very great extent, on a collective crossing of fingers. If this problem is not resolved then the impacts observed in the Texas blackouts disaster of February 2021 will be the inevitable outcome. In subsequent posts I will explain why this is the case and offer some suggestions for addressing the problem.

Climate Leadership & Community Protection Act Emission Reductions in Context

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” and claims that there are significant direct and indirect benefits if New York’s greenhouse gas emissions (GHG) are reduced to net-zero. I maintain that any claim of benefits is illusory because in the context of global impacts New York’s contribution is miniscule. This post documents how New York GHG relate to global emission increases.

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. 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.

New York Compared to the World

Climate Act advocates frequently argue that New York needs to take action because our economy is large. I analyzed that claim recently and summarized the data here. The 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world. However, when New York’s GHG 2016 emissions are compared to emissions from other countries, New York ranks 35^th. More importantly, a country’s emissions divided by its GDP is a measure of GHG emission efficiency. New York ranks third in this category trailing only Switzerland and Sweden.

There is no question that New York is rich but is not a major player in global GHG emissions. In fact, New York’s share of global GHG emissions is 0.45% in 2016, the last year when state-wide emissions consistent with the methodology used elsewhere are available. In 1990 New York’s share of global GHG emissions was 0.77% so the state’s programs to reduce emissions have been working.

Despite the fact that the ostensible rationale for GHG emission reduction policies is to reduce global warming impacts, the Draft Scoping Plan continues an unbroken string of not reporting the effects of a policy proposal on global warming. The reason is simple. The change to global warming from eliminating New York GHG emissions are simply too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions. I have calculated the expected impact on global warming as only 0.01°C by the year 2100 if New York’s GHG emissions are eliminated.

The purpose of this post is to document how New York GHG relate to global emission increases. I found CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet. The trend results indicate that the year-to-year trend in GHG emissions was positive 21 of 26 years and for CO2 emissions was positive 24 of 30 years. The five-year average of the GHG year-to-year trends was positive every year between 1995 and 2016, the last year GHG emissions were available. The five-year average of the CO2 year-to-year trends was positive every year between 1995 and 2020 except for the 2020 COVID year. In addition, excluding COVID year 2020, the smallest five-year average annual global GHG or CO2 emissions increase was 0.5%. New York’s share of global GHG emissions is 0.45% in 2016 so this means that global annual increases in GHG emissions have always been greater than New York’s total contribution to global emissions.

Conclusion

By any measure New York’s complete elimination of GHG emissions is so small that there will not be any effect on the state’s climate and global climate change impacts to New York. Although New York’s economy would be ranked ninth relative to other countries, New York’s emissions are only 0.45% of global emissions which ranks 35^th. The change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions. Finally, this post documents that global emissions have increased more than New York’s total share of global emissions since 1995. In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year.

The only possible conclusion is that the Climate Act emissions reduction program is nothing more than virtue-signaling. Given the likely significant costs, risks to reliability, and other impacts to New York society, I think that the schedule and ambition of the Climate Act targets needs to be re-assessed for such an empty gesture.

Climate Act Scoping Plan Benefits Summary

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. 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 Scoping Plan that was released for public comment on December 30, 2021.

According to a Gothamist summary of the Climate Act: “Seggos, the DEC commissioner, said the draft plan is meant to generate a framework and solicit input on how the state can meet its climate goals, not provide a policy-by-policy cost estimate.” In my opinion, that is a serious shortcoming for the Scoping Plan cost and benefits assessment because a framework is not a feasibility study. Both the costs and benefits are societal estimates. There are no guesses of the direct costs to consumers or rate-payer impacts. Similarly, the benefit values are to society and do not directly offset the ultimate costs to consumers. Until such time that direct consumer costs and benefits are known New Yorkers cannot decide whether it is appropriate to proceed with the ambition and schedule of the Climate Act.

The Scoping Plan estimates societal health benefits and avoided economic damages caused by climate change as a result of GHG emission reductions. Improvements in air quality, increased active transportation, and energy efficiency interventions in low- and middle-income homes generates health benefits ranging from approximately $165 billion to $170 billion. Reduced GHG emissions avoids the economic impacts of damages caused by climate change equaling approximately $235 to $250 billion. The combined benefits range from approximately $400 billion to $420 billion.

This post summarizes all these benefits claims. I have addressed some of them before but this consolidates all the analyses. Complete documentation for this evaluation is contained in the Scoping Plan Costs and Benefits white paper.

Scoping Plan Benefits Summary

The Scoping Plan claims net benefits range from $90 billion to $120 billion. The Plan describes health benefits totaling $165 to $170 billion due to improvements in air quality, increased active transportation ($39.5 billion), and energy efficiency interventions in Low- and Middle- Income (LMI) homes ($8.7 billion). The benefit claims are not documented well enough to confirm those estimates but they appear to be biased high. The claimed benefits for the avoided cost of GHG emissions range between $235 and $250 billion. However, Climate Act guidance incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times. When the multiple-counting error is corrected, the avoided carbon damage benefits range from negative $74.5 to negative $49.5 billion.

The Scoping Plan air quality improvement benefits range between $100 billion and $103 billion for the low values and the high values range between $165 billion and $172 billion. These benefits are due to an air quality improvement for PM_2.5 of 0.35 µg/m³ that is supposed to “avoid tens of thousands of premature deaths, thousands of non-fatal heart attacks, thousands of other hospitalizations, thousands of asthma-related emergency room visits, and hundreds of thousands of lost workdays”. However, the modeled impacts rely on a linear no-threshold model. The observed reduction in New York City since 2005-2007 is 5.6 µg/m³ and that is 16 times higher than the projected decrease due to the Climate Act. Using the linear no-threshold model that means that we should be able to observe sixteen times tens of thousands of premature deaths, sixteen times thousands of non-fatal heart attacks, sixteen times thousands of other hospitalizations, sixteen times thousands of asthma-related emergency room visits, and sixteen times hundreds of thousands of lost workdays since 2007. When the Scoping Plan verifies that these reductions have been observed I will accept these benefits.

The Scoping Plan admits that the health benefits from increased active transportation “should be considered a first-order approximation of the benefits of increased active transportation”. The active transportation health theory claims that as people are forced out of their personal vehicles some will switch to walking and biking. Those activities are healthier so there is a benefit. However, the analysis was conducted at the state level, rather than modeling changes in walking and biking activity due to changes in vehicle miles traveled within counties or individual communities. Because the actual number of places where this strategy could actually encourage more walking and bicycling to work is small relative to the state level, the $39.5 billion health benefit claim is far too high.

Upon examination the majority of the health benefits from energy efficiency interventions in LMI homes are the result of “non-energy interventions”. The Climate Act intends to transform the energy sector so it is disingenuous to claim health benefits not directly related to energy efficiency programs themselves. Of the $8.7 billion in benefits claimed $3 billion is due to reduction in asthma-related incidents resulting from better ventilation not directly due to energy efficiency. The $2.4 billion in benefits from reduced trip or fall injuries and reduced carbon monoxide poisoning benefits are non-energy interventions and should not be claimed as benefits for GHG emission reduction programs.

The Scoping Plan claims the largest proposed benefits come from avoided GHG emission impacts on climate change due to emission reductions. The Climate Act Scoping Plan manipulates the emissions, the emissions accounting, and calculation of social cost of carbon benefits to inflate these benefits to claim that there are net benefits. In order to maximize the benefits from emission reductions the Scoping Plan uses non-conventional assumptions to contrive increased emission estimates that are 1.9 times higher in 1990 and 2.3 times higher in 2019 than conventional, or UNFCCC, format for emissions accounting used by other jurisdictions. New York’s Value of Carbon guidance chooses a lower discount rate that places lower value on immediate benefits relative to higher delayed benefits received in the future. The combined effect of the higher emissions and lower discount rate means that New York’s societal benefits of GHG emission reductions are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions.

Even with that gamesmanship the Scoping Plan benefits were too low to claim that benefits out weighed the costs. The Value of Carbon guidance incorrectly calculates benefits by applying the value of an emission reduction multiple times. It is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. Dr. Richard Tol confirmed that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”. Using that trick and the other manipulations results in New York societal benefits more than 21 times higher than benefits using everybody else’s methodology. When the over-counting error is corrected, the total societal benefits range between negative $74.5 billion and negative $49.5 billion.

Conclusion

The Scoping Plan Costs and Benefits white paper documents the calculation results presented in this summary. The Plan describes health benefits totaling $165 to $170 billion due to improvements in air quality but observed improvements are 16 times greater than those projected for the Climate Act. If the State can show that the health benefits projected have been observed comparable to those observed then this claim holds water. The increased active transportation benefit of $39.5 billion is based on a first-order approximation based on state-wide numbers but the benefits will likely only occur in certain areas. As a result, the benefit estimate is far too high. Energy efficiency interventions benefits in LMI homes are claimed to total $8.7 billion but $2.4 billion of that is from non-energy interventions and should not be claimed as benefits for Climate Act GHG emission reduction programs. If the claims were documented better, I believe that the further reductions in the benefits would be found.

The claimed benefits for the avoided cost of GHG emissions range between $235 and $250 billion. However, Climate Act guidance incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times. The Climate Act manipulates emissions to increase benefits and uses a lower discount rate than current Federal guidance resulting in societal benefits of GHG emission reductions that are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions. The largest impact of the Climate Act for these benefits is based on an incorrect guidance for calculating benefits. In particular, 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 net benefits ranging from $90 billion to $120 billion.

Bringing Britain’s woes to New York?

Great Britain is further along in its plans to meet a “Net Zero” greenhouse gas (GHG) emissions target by 2050 than New York’s Climate Leadership and Community Protection Act (Climate Act) effort. Paul Driessen recently published an article asking the question whether Biden-AOC energy policies will do to Americans what UK climate obsession is doing to Brits?. This post reproduces his article with my New York relevant comments.

Background

Paul Driessen is senior policy analyst for the Committee For A Constructive Tomorrow (www.CFACT.org) and author of books and articles on energy, environment, climate and human rights issues. My comments are indented and italicized.

Bringing Britain’s woes to America? Virginia enacted a Clean Economy Act; other states have implemented similar laws. AOC demands a national Green New Deal; President Biden is imposing one via executive decree. The United Kingdom is determined to reach Net Zero greenhouse gas emissions; the European Union is pursuing a Green Deal.

The Climate Act Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda” was recently released by New York State.

All these policies send energy prices rocketing upward, eliminating jobs and killing people. Instead of reducing emissions, they simply move them overseas, where they combine with massive air and water pollution, habitat destruction and wildlife decimation – as China and other countries burn more coal, oil and gas every year, to improve their people’s living standards … and to mine and process raw materials for the wind turbines, solar panels and battery modules they manufacture for climate-obsessed nations. The net result: Progress toward global Net Zero is zero – worse than zero – and all the lost jobs, rising poverty, reduced living standards and policy-driven deaths are for nothing.

My Citizen’s Guide to the Climate Act documents New York’s similarly futile quest.

President Biden wants hydrocarbon-free electricity generation by 2035, and elimination of all fossil fuel extraction and use by 2050. That means no gasoline or diesel vehicles; no natural gas to power factories or heat, warm water and cook in homes, hospitals and businesses; no petrochemical feedstocks for fertilizers, plastics, pharmaceuticals and thousands of other essential, everyday products.

The Climate Act target for hydrocarbon-free electricity generation is 2040 but that is no more realistic than Biden’s dream. Even though New York is further along in its planning there still is no feasibility plan to replace fossil fuels.

All US energy will be provided by wind, solar and battery power – millions of wind turbines, billions of solar panels and billions of battery modules, sprawling across continental United States and along its coasts. Petrochemicals will come from crops planted on millions of acres of former wildlife habitat.

New York has not done a cumulative environmental impact analysis for the Scoping Plan’s estimates of wind and solar deployments so residents don’t know these impacts.

To drive this extreme agenda, Team Biden has canceled pipelines, leases and permits; pressured banks to stop lending money for drilling; and issued scores of regulations that delay and drive up costs for fossil fuel projects – while making it easy for industrial-scale wind and solar installations to get permits. Prices for energy, transportation, food, services and used cars predictably shot up. Inflation and consumer prices reached 40-year highs.

New York’s policies are the same and the impacts exacerbate Federal policy effects.

Henry Hub natural gas prices doubled from $2.61 per mcf (thousand cubic feet or million BTUs) in November 2020 to $5.51 in October 2021, before falling to $4.75 in January 2022, as skyrocketing global prices spurred drilling, fracking and production on US state and private lands. Regular gasoline averaged $2.17 a gallon nationwide in 2020 – but hit $3.39/gal ($4.38 in California) in the same timeframe.

New York Heating Fuel prices show similar increases.

As Americans fret and fume over the needlessly high prices – and wonder what the future might hold – they can look to the UK and EU (a) to count their blessings for comparatively low prices today and (b) to ponder how continued climate-centric policies could impact American livelihoods and living standards.

Britain and continental Europe have already embraced a wind-and-solar future, closed coal and nuclear power plants, and banned fracking for the trillions of cubic feet of natural gas beneath their feet, while North Sea production keeps falling. They have reaped the whirlwind from those callously inept policies.

The Scoping Plan mentions that switching to wind and solar will ensure that New York’s resources are used in the future but neglects to point out that natural gas development has been banned in the state.

(It is illuminating and ironic that Russian organizations finance many US, UK and EU anti-fracking disinformation campaigns, funneling funds through a Bermuda law firm, a shell company and the Sea Change Foundation to the Sierra Club, Climate Action Network and other groups.)

There are many New York environmental organizations that seem to have plenty of time and money to lobby. It is not clear where their money is coming from.

Britain and Europe’s vaunted wind turbines have been generating electricity at a dismal 14% of “nameplate capacity” – providing power three hours a day, one day a week, four days a month, in short spurts, at completely unpredictable times. Their wintertime solar power has been equally sporadic and unpredictable. No modern society can function on such energy.

On January 15, 2022 New York State was very cold. Wind and other renewables provided 2% of the electric generation for the day. Over half of the generation was produced by fossil fuels. The Scoping Plan glosses over the magnitude of this problem and has not proposed a feasible plan to provide reliable power on the days when the all-electric New York energy system needs it the most.

The huge gaps have been plugged with gas- and coal-fired generation, with much of the gas coming from Russia and the USA. But Asia also wants the gas, and Russia is playing Ukraine/Nord Stream 2 pipeline politics with its gas, tightening supplies as demand soars. UK and EU home and business gas and electricity prices are in the stratosphere – five to ten times the Biden Era prices Americans are paying.

Presuming that the Climate Action Council can conjure up a feasible way to provide power on the coldest days they face the problem that whatever resource they want to use will only be needed around 3% of the time. The potential resources for this requirement are all very expensive. When these resources are needed electricity prices will be very high during those periods in order to cover operating and capital costs. The Scoping Plan has not addressed this problem.

Luckily for families and businesses, Britain’s Office of Gas & Electric Markets (Ofgem) regulates how much utility companies can charge. But that often means keeping household, hospital, school and business energy prices well below the utilities’ actual costs – with predictable results. Experts say the average annual household bill of £1,277 ($1,755) could surge to £1,865 ($2,530) when the current price cap is raised in April 2022 – for homes and apartments that are much smaller than US counterparts, in a climate with much less extreme summer and winter temperatures than in much of the United States. Annual bills could exceed £2,000 ($2,715) or much more at Ofgem’s August review. National Energy Action says this could put more than 6 million UK households (nearly one-fourth of all households) in “fuel poverty” – unable to afford proper heat, and often having to choose between heating or eating, even when cold indoor temperatures put their health and lives at risk.

The Scoping Plan has not provided estimates of household costs. Moreover, I don’t think the provisions to address energy poverty in New York are adequate to protect those who can least afford the inevitable increased costs.

For families that want budgetary certainty, the average 12-month fixed deal for a typical household now costs almost £2,500 ($3,430). But the UK’s second-biggest energy supplier’s most recent fixed-rate offer is almost £4,200 ($5,750)! That’s because natural gas and electricity generation costs are expected to keep rising – and because utilities must pay wind turbine operators “constraint payments” to turn turbines off whenever they generate more power than the grid needs and can absorb!

This is another inevitable consequence of New York’s policies and is an added aspect of costs not adequately addressed in the Scoping Plan.

The month-ahead natural gas price at the Dutch TTF hub (a European benchmark for trading gas) recently hit €93.3 ($107) per megawatt-hour. That’s $31 an mcf – more than six times the January 2022 Henry Hub price. Just a month earlier, the European day-ahead gas price reached $61 per mcf! No wonder 30 UK energy suppliers went bankrupt by the end of 2021 – leaving families and businesses scrambling to find new suppliers, at skyrocketing prices for heating and cooking. When utilities cannot charge customers anywhere near operating costs, they go belly-up. No wonder two-thirds of UK renters struggle to pay their energy bills, and 400,000 more UK households were in danger of losing their gas and electricity provider before last Christmas. People are “genuinely terrified” about rising energy costs. Excess winter energy-poverty death tolls are likely to set new records.

It is not clear why anyone would think that when New York’s policies are fully implemented that the same effects won’t be seen. The Climate Act mandates that experiences in other jurisdictions should be considered but none of these issues are addressed in the Scoping Plan.

Health and living standards in Britain and Europe will likely get far worse. In addition to insane energy costs, wages and environmental regulation costs are much higher than in Asia. Ceramic, steel, aluminum, automotive and other energy-intensive companies and industries are becoming uncompetitive. Manufacturing, jobs, energy use and greenhouse gas emissions are just moving to Asia.

The Scoping Plan includes a “just transition” component that is supposed to alleviate these issues in New York. However is not clear how that can be done.

Climate and energy politics, combined with fierce global demand, make it unlikely that Europe’s energy prices will go down. And while the EU recently voted to define natural gas and nuclear power as “sustainable,” acquiring affordable gas and building new nuclear plants will take years and be battled every step of the way. Rolling blackouts could become as common as in California.

It is telling that the European Union recently voted to define natural gas and nuclear power as sustainable. The rational explanation is that they have observed problems that can be solved by those fuels. The Climate Action Council and its advisory groups continue to cling to the belief that the same issues will not occur in New York.

British politicians “rail at energy costs” and argue about trimming them at the margins, says journalist Madeline Grant, perhaps by reducing the 5% VAT on energy or the 25% green-social subsidy levies on electricity bills. But they “dare not question the green policies” that cause energy price increases, end up taking no action, and then slap hefty new “pollution taxes” on gas and diesel vehicles.

The Climate and Community Investment Act is New York’s political solution to fund the grandiose plans to go to ”net-zero”. I believe that New Yorkers will rebel when those costs become known.

Britain and Europe need to drill and frack their vast shale deposits. Having shut down their older nuclear plants, they must start building small modular reactors. The rest of the developed world needs to take similar actions – and not only because China, India and the rest of the developing world are not about to give up fossil fuels and rely on unreliable wind and solar power, but to save jobs and lives. Otherwise, Britain’s Christmas just past will be its, Europe’s and America’s Christmas future, forever. Scrooge learned from Marley. Will Boris Johnson, Joe Biden, AOC and their lot learn from reality?

New York has to recognize what is happening in Europe and change its plans. If not then the inevitable result will be extraordinarily high energy prices.

Conclusion

There are lessons to be learned for New York if only they consider what is happening in Great Britain. Unfortunately I have little hope that the state will come to its senses and reconsider the schedule and targets of the Climate Act.

NY Climate Act Scoping Plan Active Transportation Benefit

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” and claims that there are significant direct and indirect benefits, including improved public health. One Scoping Plan policy is active transportation that claims that if physical activity is built into daily routines by forcing people to walk or bicycle rather than drive, then emissions will be reduced and there will be health benefits too. This post looks at the claim that there will be $39.5 billion in health co-benefits for active transportation.

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. 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. An overview of the results of this integration analysis were presented to the Climate Action Council at two October meetings and has since been updated. This analysis forms the basis of the draft Scoping Plan that is supposed to be released to the public at the end of the year.

In the following sections I provide my indented and italicized comments for documentation in Scoping Plan Appendix G: Integration Analysis Technical Supplement.

Appendix G: Section II, Page 24: 1.4 Increased Active Transportation.

The public health benefits of increased active transportation were estimated using the Integrated Transport and Health Impact Model (ITHIM).[1] The analysis drew on modeling conducted for the New York State Clean Transportation Roadmap,[2] which estimated the increase in walking and biking trips resulting from a decrease in VMT.

The documentation consists of a Power Point presentation to the Transportation Advisory Panel. The presentation lacks important information. The scenarios in the presentation are not the scenarios in the Scoping Plan. There is no reference describing which simulated policies are included in the Scoping Plan scenarios. The presentation does not list the expected decrease in vehicle miles traveled (VMT).

ITHIM uses U.S.-level data from the Global Burden of Disease study[1] and other published literature to estimate the change in the relative risk of premature mortality due to increased physical activity. ITHIM also calculates the potential increase in pedestrian mortality from vehicle collisions, and it presents the net change in mortality for a given change in walking and biking activity.

ITHIM calculates the health impacts of walking and bicycling short distances usually traveled by car or driving low-emission automobiles. Without any documentation it is not clear if ITHIM includes pedestrian mortality in the winter.

In this analysis, the ITHIM model was customized with NYS-specific data on population, baseline mortality rates, and VMT, from the same data sources discussed above for the ambient air quality analysis, as well as baseline walking and biking activity taken from the Federal Highway Administration’s National Household Travel Survey.[1]

In another analysis that used ITHIM: “We utilized data from local, state, and federal sources to fulfill the 14 ITHIM calibration items, which include disease burdens, travel habits, physical activity participation, air pollution levels, and traffic injuries and fatalities.” It is not clear how Scoping Plan analysis handled all 14 calibration items.

The analysis valued the change in mortality using the value of a statistical life from COBRA to be consistent with the ambient air quality analysis.

Comprehensive documentation would explain how the numbers differ and offer more of a rationale than “consistency”.

The analysis used NYS-specific data where possible alongside the default equations within ITHIM to estimate the net change in mortality from increased walking and biking. These equations include default parameters based on national-level data to represent the change in relative risk of mortality from change in physical activity.

Again an explanation why national-level data are appropriate to use for New York is needed.

This analysis was conducted at the state level, rather than modeling changes in walking and biking activity due to changes in VMT within counties or individual communities. For this reason, the results of this analysis should be considered a first-order approximation of the benefits of increased active transportation.

This is a huge issue with this analysis. The plain reading of this is that they took the statewide change in VMT, assumed that some portion of this would be replaced by walking and biking, and then took health care credit for the change. However, smart planning changes to walking and biking is a specific community outcome. In my opinion, the actual number of places where this strategy could actually encourage more walking and bicycling to work is very small.

Appendix G: Section II, Page 37: 2.3 Health Benefits of Increased Active Transportation

The potential value of the net reduction in the number of deaths, including the decrease in deaths from increased physical activity and the increase in deaths from traffic collisions, is estimated to be a NPV of $39.5 billion (2020 to 2050). As presented in Figure 22, the values increase over the years as walking and cycling increases with the introduction of infrastructure and other measures to encourage the use of these modes. Note that the projected decrease in premature deaths from physical activity far outweighs the potential increase in deaths from traffic collisions. Active transportation benefits are the same for the Low-Carbon Fuels and Accelerated Transition scenarios.

[1] U.S. Federal Highway Administration. 2021. National Household Travel Survey. https://nhts.ornl.gov/

[1] Institute for Health Metrics and Evaluation (IHME). Global Burden of Disease (GBD). Seattle, WA: Institute for Health Metrics, University of Washington; 2015. http://www.healthdata.org/gbd

[1] Available at: http://cal-ithim.org/ithim/#Home

[2] Cadmus. New York Clean Transportation Roadmap Preliminary Results: GHGs and Energy. Presentation to the Transportation Advisory Panel to the New York State Climate Action Council. April 9, 2021. https://climate.ny.gov/Advisory-Panel/Meetings-and-Materials.

New York Clean Transportation Roadmap Preliminary Results: GHGs and Energy

On April 9, 2021 Cadmus presented preliminary results for the New York Clean Transportation Roadmap. As noted above this represents the documentation for this policy. I have not found the final report and the Scoping Plan offers no other reference. The documentation consists of a slide presentation and lacks important information. For example, the presentation includes the following slide that describes a couple of simulated policies that could represent the mechanism to increase physical activity. For example, in the Smart Growth policy, the baseline states: “2050 Reference Case value for fraction of HH in mixed-use neighborhoods ranges from 4 to 74% across MSAs”. I don’t know what the HH acronym means. On the other hand, the Complete Streets policy appears to directly address increased walking and biking to work.

In order to evaluate the claims, I wondered how many employees are expected to start using active transportation to get to work. Demographics of the Civilian Labor Force for New York State and the New York State Labor Market Regions lists 2015 – 2019 American Community Survey (ACS) five-year estimates of employed people for ten regions. Note that the Complete Streets mitigation scenario states that the “Start value for % walking or biking to work ranges from 0.7% to 12.1% across counties”. I believe that the percentage of people walking or biking to work is highest in New York City which is one of the regions in the ACS employee estimates. This is an example of a problem with the poor documentation. Assuming that the New York City region has 12.1% employees who walk or bike to work and that all the other regions have 0.7% who do so, then we can calculate the state-wide percentage. Using those assumptions, the state-wide percentage is 5.6% which exceeds the 2050 goal for Mitigation Scenario 1. That makes no sense and without adequate documentation it is impossible to reconcile this discrepancy.

There is another issue with these estimates. There is a spreadsheet that lists the data in the health benefit figures. In the following table the benefits column are values in the Scoping Plan documentation. I interpret the Complete Streets policy to increase the percentage of workers who walk, bike or take an electronic bike or scooter to work by either 5% or 10% by 2050. In the table I divide the benefits claimed by the number of commuters. Complete documentation would show how many employees switch per year and then it would be possible to estimate the health benefits per active commuter. Even without that differentiation the numbers per commuter seem high. More importantly, are the health benefits applied for each commuter every year until 2050?

Figure 14 Data Potential Annual Value of Public Health Benefits from Increased Active Transportation for 9,498,320 employees in Demographics of the Civilian Labor Force

		Actively Commuting
		5%	10%
		474,916	949,832
	Benefits	Benefits per Commuter
Year	(millions, 2020$)	5%	10%
2020	$0	$0	$0
2021	$0	$0	$0
2022	$208	$439	$219
2023	$420	$885	$442
2024	$636	$1,338	$669
2025	$855	$1,800	$900
2026	$1,077	$2,269	$1,134
2027	$1,304	$2,746	$1,373
2028	$1,534	$3,230	$1,615
2029	$1,768	$3,723	$1,862
2030	$2,006	$4,224	$2,112
2031	$2,248	$4,734	$2,367
2032	$2,494	$5,251	$2,626
2033	$2,744	$5,778	$2,889
2034	$2,998	$6,312	$3,156
2035	$3,256	$6,856	$3,428
2036	$3,284	$6,914	$3,457
2037	$3,312	$6,973	$3,486
2038	$3,340	$7,032	$3,516
2039	$3,368	$7,092	$3,546
2040	$3,397	$7,153	$3,576
2041	$3,426	$7,213	$3,607
2042	$3,455	$7,275	$3,637
2043	$3,484	$7,337	$3,668
2044	$3,514	$7,399	$3,700
2045	$3,544	$7,462	$3,731
2046	$3,574	$7,526	$3,763
2047	$3,604	$7,590	$3,795
2048	$3,635	$7,654	$3,827
2049	$3,666	$7,720	$3,860
2050	$3,697	$7,785	$3,893

Conclusion

The Scoping Plan claims that “the potential value of the net reduction in the number of deaths, including the decrease in deaths from increased physical activity and the increase in deaths from traffic collisions, is estimated to be a net present value of $39.5 billion (2020 to 2050)”. My first impression of this value was that it was too high. While the lack of documentation makes it difficult to decipher exactly how the number was derived, I see nothing to disprove that impression.

The Scoping Plan admits that “the results of this analysis should be considered a first-order approximation of the benefits of increased active transportation”. In this instance “first-order approximation” means wild guess that they threw up hoping it would stick. While there are undoubtedly some benefits for active transportation, the Scoping Plan claim for $39.5 billion is unsupportable.