Guest Posts – Page 3 – Pragmatic Environmentalist of New York

Climate Act Draft Scoping Plan Comments by a Business Owner

This post describes the comments submitted on the Climate Leadership and Community Protection Act (Climate Act) Draft Scoping Plan by the owner of PKG Equipment, Inc. outside of Rochester in Chili, NY. His concerns highlighted one of the transition issues that is not being considered by the Climate Action Council.

PKG Equipment is a second-generation, family-owned company. It is a manufacturer and service provider of equipment typically used in the finishing, chemical manufacturing, steel manufacturing and glass manufacturing industries. PKG Equipment was founded in 1969 by Sam Pontarelli, the current management team’s father, and two partners who sold their shares to him in the1970s. During the 1970s, the company began fabricating plating equipment using thermoplastics, and it purchased European plastic welding and forming machines in the early 1980s. PKG Equipment began manufacturing turnkey plating systems and also became a distributor for related equipment.

Comments

Stephen Pontarelli is the CEO and with a little bit of help from me prepared the following comments.

I live in the Rochester area and own PKG Equipment, Inc. that employs 25 people. Energy costs are a major consideration for my family and our business. I am submitting these comments because the Climate Action Council has not done a satisfactory job explaining what the Climate Act transition will cost, how it might threaten energy reliability, or how it will affect my business.

I have been unable to find any detailed cost information. What is the expected cost of electricity? I have seen articles that noted that energy costs in Germany have increased markedly as they implement a similar transition. What is New York going to do differently than those other jurisdictions that have seen cost increases?

I understand that the transition plan boils down to electrifying everything. I am particularly concerned about heating our manufacturing facility. It sounds like the preferred electrification approach is to use heat pumps. My understanding is that they only work well during the coldest periods of the winter if the structure is very well insulated, has improved window treatments, and reduces air infiltration. There are a number of considerations that make those improvements problematic. Will there be support available to upgrade our building’s insulation and windows? How am I supposed to minimize air infiltration at the loading dock? Also, our manufacturing process uses natural gas for our curing ovens and heat treating. Replacing that equipment alone would approach $1,000,000. That doesn’t include getting the appropriate amount of electricity to the building. We would need a ridiculous amount of electricity to run this equipment. Our small business can’t afford this transition.

I understand that the future electric grid is supposed to rely on intermittent wind and solar generating resources. I figured out that your scenarios for future implementation call for about 150% of the total existing generating capacity of the state, that land-based wind is supposed to increase by nearly an order of magnitude, and that battery energy storage capacity will be close to today’s fossil generating resources. Surely developing all those resources is going to be incredibly expensive so it seems certain that energy costs for my business and home will increase markedly. I think it is necessary to include a clear explanation of all the control measures proposed, the assumptions used to project the costs, and a description of the emissions reductions expected for the Draft Scoping Plan strategies.

There is another worrisome aspect of future energy resources. The Draft Scoping Plan mentions a zero-carbon firm resource as a necessary component. I think it is incredibly risky to rely on an unproven resource. Finally, I was asked to consider bidding on a component system for an offshore wind turbine project. I cannot imagine, based on my background and expertise, that all the components necessary for those systems will be available to be installed per the proposed schedule. At the same time, I have heard that there is considerable pressure to stop all investments in existing fossil fuel infrastructure. I am concerned that shutting down systems based on an unrealistic implementation schedule for a technology like offshore wind that has not developed the infrastructure to transport and install the turbines is a serious risk to reliability. Therefore, I recommend that implementation is conditional based on determining upfront standards of affordability and reliability once costs for the unproven zero-carbon firm resource are determined and the development issues associated with offshore wind are known so that a realistic schedule can be developed.

I am not willing to accept higher costs, lower standards of energy reliability, or limitations to my business operations unless there is a clear tangible benefit. I have read compelling arguments that the Draft Scoping Plan benefits are over-stated and that in fact the actual costs of the program far exceed the benefits. In that regard, I don’t understand what is meant when the costs and benefits are presented “relative to the Reference Case”. Given the fact that total New York State greenhouse gas emissions are less than the annual increase in global greenhouse gas emissions, the obvious conclusion is that upfront standards of affordability and reliability must be set such that the Climate Act transition does not do more harm than good to New York State.

Conclusion

Frankly when I have thought about the industrial transition from natural gas to electricity that will be mandated by the Climate Act, I thought mostly about big manufacturing companies. I have seen no sign that the Climate Action Council hasn’t been thinking the same thing. The fact is that PKG Equipment represents the smaller companies that do not use natural gas for most of their processes but only for a couple of pieces of equipment. Replacing that equipment will be a major burden for small companies. In addition, those processes will require a lot of power that will very likely require service upgrades for their building and depending on the location distribution system upgrades.

I know the Pontarelli family. They all are from New York, want to stay in New York, and, through their hard work, provide jobs for 25 people. They are representative of many other small companies throughout the state. I despair that the financial impositions of the Climate Act will force them and the other similar companies to leave New York in order to remain competitive with businesses outside of New York.

Guest Post Draft Scoping Plan Comments on Practicality and Others

This post describes the comments submitted on the Climate Leadership and Community Protection Act (Climate Act) Draft Scoping Plan by Gary R. Schoonmaker. If I knew how to do guest posts on this site, I would have made this a guest post. My apologies but I am going to have to wing it.

Gary R. Schoonmaker is a lifetime citizen of New York State; a licensed Landscape Architect with over 18 years experience at an electric and gas utility in New York State; and involvement in many environmental organizations in Central New York. He designed and built an energy efficient home in 1978 which had an air-to-air heat pump and now has solar panels; and has over 40 years experience in real estate development.

Schoonmaker Verbal Comments

On April 26, 2022, Schoonmaker used his two minutes at the public hearing at the College of Environmental Science and Forestry in Syracuse (3:22:15 of the video recording) to present his credentials and raise serious concerns about the practical limitations on implementing the plan as proposed in the draft scoping plan. If you want a good overview of the comments then I recommend his comments in no small part because of his effective presentation.

He described his verbal comments as follows:

In my testimony, I questioned the reasonableness of coercing compliance from state residents instead of offering people a solution similar to previous energy transitions where people chose the change themselves, e.g. kerosene or whale oil to electricity, or horses to automobiles. One could add any number of other transitions: pony express to telegraph, telegraph to radio, radio to television; crank telephone to corded telephone to wireless to cell phones; coal or wood to other fossil fuels for space heating; open windows to air conditioning; the list goes on and on! The commonality for all of these is that people chose to adopt these changes for themselves because they believed the new technologies bettered their lives and were in their own best interests. The government did not dictate or coerce the whole of society to change based on their assumed wisdom. They trusted the people to make the best decisions for themselves.

In the present situation however, the government, in the form of the State Legislature, the Governor, the Climate Action Council, and other agencies (including the Public Service Commission), have now decided they know best and are proposing to use the power of the State to coerce change because they think they know best. No gas connections after 2024; no gas appliances after 2030; no fossil fueled vehicles after 2035……. And on and on with little regard for the desires of the citizens or their freedom to live their lives as they see fit.

I also addressed the impracticality of doubling the capacity of the electrical system: generation; transmission; distribution, in the next eight years as proposed. Ask anyone in the utility industry with experience in constructing new facilities how long it takes to design, get approval for and construct new or even upgraded facilities and they will tell you that doubling capacity in eight years (or less) is not only impractical, but impossible. Even if by fiat the State was to order such a change, there is little recognition in the plan for the social upheaval that would result from constructing hundreds of miles of new transmission lines and digging up every urban area and suburban neighborhood with underground utility services for years in order to implement the upgrades.

Written Comments

I have posted the complete set of comments for your information. Because they are so extensive, I am not going to provide them all here. Instead, I will provide some highlights of the main points presented.

The comments pointed out the practical problems converting the entire energy system to electricity. The schedule is impractical solely due to the number of conversions of homes, businesses, and vehicles. Throw in supply chain, technology development needs, and supporting infrastructure requirements he notes that the level of this transition on the proposed schedule just can’t work as proposed.

He raises philosophical concerns. He asks “how sure are we that climate change is real; that man is the principal driver of climate change; that man’s actions can be modified to effect a meaningful change; and that such change would actually benefit mankind?” I particularly like his discussion of “settled science”:

Man-induced climate change is not “settled science” no matter what we are told. In fact “settled science” is an oxymoron to science itself. Science is the continual process of questioning everything. When someone tells you not to question, they have stopped being scientists and become politicians with an agenda. In fact, there are many highly qualified scientists who question the theory of man-induced climate change and the practicability of man being able to control the climate in meaningful ways. Honestly, the idea that men can control climate is egotistical at best and ridiculous at worst. Man is much more capable of adapting to, rather than controlling climate or weather.

He also raises technical issues with climate modeling. I like this comment:

They are trying to project the climate for the next hundred years. Really!?! There are so many data points and interactions, that such an effort is futile. Considering that the input data is from a couple of hundred of years at best, the period of record seems horrifically short considering that climate has been changing for thousands of years. Then they want us to believe that they understand and have programmed the models to accurately predict the interactions of the millions of variables.

He also raises two legal issues:

When is the New York State Environmental Quality Review Act (SEQRA) triggered and the plan subjected to that review?

The plan appears to violate the “taking” provision of the United States Constitution’s 5^th amendment and the New York State Constitution.

In my opinion the response to the SEQRA question raised will be that they did do an analysis. However, to my knowledge they have not evaluated the current projections for wind, solar, and energy storage development. Also note that there is a generating type called dispatchable, emission-free resource that is projected to have a capacity (MW) approximately equal to the current fossil-fired capacity. They cannot possibly determine environmental impacts without knowing what that resource will be.

The legal question about the taking” provision of the United States Constitution’s 5^th amendment and the New York State Constitution is an interesting point. As he points out “the forced abandonment of natural gas systems, fossil fired generation facilities, natural gas appliances, personal and commercial fossil fueled vehicles, and perhaps other privately held property, would constitute a “taking” and therefore require compensation”. There is no indication in the Draft Scoping Plan that those costs have been considered.

Schoonmaker also raised ethical issues:

At what point does the concept of individual freedom become subservient to the State’s coercive powers? This is something that is questioned in far more than the subject at hand, but in this case, as in earlier energy transitions, people should not be coerced under an arbitrary and unsubstantiated timeline, but allowed to choose for themselves as the change actually benefits them at the proper time. In the meantime, we can all adapt as we see fit.

He concludes:

Instead of the heavy-handed coercion of the present plan (and even legislation), we should slow down and let people choose for themselves as the technology matures and provides the incentives for people to change if it benefits them. I have a friend who just bought a hybrid pick-up truck and he is very happy with it. Perhaps that is a better way to go than pure electric. This draft plan doesn’t allow for that option.

Natural gas is a relatively clean fuel as is nuclear, but both are excluded.

Hydrogen and fuel cell technology also hold significant promise for working towards the goals of the plan, but would be excluded if the plan was to be implemented as scheduled. People at the hearings made strong arguments for winterizing older homes as an initial step towards reaching the goals of the plan, but they were apparently dismissed for not being aggressive enough. Actually, aggression is a good word to describe the proposed plan: aggressive and confrontational and offensive to the American principles of individual freedom, free choice and justice.

My Thoughts

I had not thought of the transition in the way Schoonmaker described it in his comments before I heard him speak. His point that this transition is different is spot on. In the past energy transitions occurred because it was in the best interests of society because of cost and quality of life improvements. In this transition we are expected to swallow more expensive, less convenient energy options because we are told the science says we have to do it. However, when we ask questions about that science, we are told it cannot be questioned and that we are deniers for even considering that maybe the rationale is not as strong as we have been told. Schoonmaker questions the climate science but notes that he is not a climate scientist. Neither am I but at its core the belief that anthropogenic greenhouse gas emissions will cause an inevitable climate crisis is an air pollution meteorology problem. I have 45 years experience in that field and I know the air pollution science does not support the energy transition proposed. The climate science part of this is only a portion of the whole issue and very few climate scientists have the air pollution background necessary to understand the limitations of their approach.

The same tactic is being used for the energy transition. Schoonmaker has enough experience in the electric energy sector to know that transitioning away from the current system to one dependent upon wind and solar generation poses real risks to affordability and reliability. The Climate Action Council’s last meeting included one member claiming that raising that concern is “misinformation”. With all due respect, he simply does not understand if that is what he believes. The Council has not adequately addressed the reliability concerns raised by people who understand the issues. If the Administration does not step in and insist that the Final Scoping Plan reconcile their concerns, then it will lead to unaffordable electricity and catastrophic reliability problems.

Guest Post Core Error of Climate Movement

This post describes the comments submitted on the Draft Scoping Plan by David L. Dibble. If I knew how to do guest posts on this site, I would have made this a guest post. My apologies but I am going to have to wing it.

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

Dibble Comment

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

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

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

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

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

My Observations

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

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

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

Another Example of Gamesmanship in the Climate Act Integration Analysis

I still have not figured out how to do guest posts. Dietmar Detering from Nuclear New York has been digging into the economic assumptions used in the Climate Act Integration Analysis, sent me his latest analysis and asked if I would share widely. We have collaborated on this post describing his analysis of the Draft Scoping Plan gamesmanship with numbers to “prove” value for the net-zero transition.

Detering is a member of Nuclear New York, independent advocates for reliable carbon-free energy. His organization strongly supports nuclear power as a necessary component of any zero-emissions transition because it is the only scalable proven zero-emissions technology available. After growing up on a dairy farm in Germany, Dietmar Detering earned his Ph.D. in political science in 1999 at Münster University. He then moved to New York City and built an online event publishing business (EventMe! Inc.), which he still runs. He has served in volunteer leadership roles with several community organizations while raising two daughters with his wife. Passionate about environmental protection since he was a teenager, Dietmar started focusing on nuclear power advocacy in 2018. Besides his activities in New York, he is also a member of Germany’s Nuklearia group.

Climate Act Background

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050. . The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Draft Scoping Plan Shortcomings

There are many obvious shortcomings of the CAC scoping plan/NYSERDA integration analysis. The projections for renewable energy use exaggerated capacity factors for wind and solar, leading to vast underestimates of needed investments, land requirements and environmental impacts. The future capacity projections also rely imported electricity from both clean sources and dirty sources. It appears the projections are biased to underestimate the needed investments in solar, wind, battery, and hydrogen infrastructure.

Despite its proven capabilities there is no commitment to expand the use of nuclear energy. In fact, there have been comments from working groups that argue that the existing power plants should be shut down sooner rather than later.

Detering and I share the concern that the Draft Scoping Plan does not recognize some practical implementation issues. There is no appreciation of rural resistance to wind and solar build-out at the scale needed. As word gets around about the massive buildout needed there will be more and more resistance. Affordability is a major concern and the Draft Scoping Plan overestimate how much New Yorkers will be willing to pay for higher energy prices for the benefit of future generations in other countries.

The largest benefit claimed is associated with societal benefits of avoid carbon emissions. I have shown that the Draft Scoping Plan manipulates emissions inconsistent with all other jurisdictions to increase benefits and incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times. Detering notes that the Integration Analysis uses a discount rate 3.6% per year for all of its economic projections. However, for social costs of carbon, it is using NY’s official $125/ton which is based on a 2% discount factor. Apples and oranges!

Gross State Product (GSP) Degrowth

The main point of this post is that Detering has uncovered a truly bizarre aspect of the NYSERDA Integration Analysis economic modeling. One of the key drivers of future energy use is how the GSP will change over time in the future. The Key Drivers Outputs spreadsheet lists future annual GSP in the GSP table. He confirmed that the spreadsheet explicitly uses 2020 dollars, for past and future years.

Detering prepared a spreadsheet that incorporates the GSP data from the Key Drivers Outputs spreadsheet. The spreadsheet shows an average 1.9% per capita GSP growth in the years back, but .84% for the future. On the other hand, the text in Appendix G says that the Integration Analysis assumes a 1.9% growth of GSP (not per capita) and a .2% growth of population. It is not clear whether they are using nominal GSP numbers, which would explain the mismatch with the table, which uses 2020 dollars. The point is that 1.9% GSP growth is a good number for real dollars (inflation-adjusted) but not nominal ones. The table shows that their growth assumption (in 2020 dollars) per capita practically drops by half (-55%).

He has checked this math and is confident about the assumed 55% drop in per capita GSP growth. The possible conclusions are all bad:

NYSERDA’s Integration Analysis needs a low growth because GSP is linked to energy usage. Over 30 years, .84% translates to a 29% growth, but 1.9% means a 76% growth. Big difference – much less wind and solar to plan for, again!
NYSERDA’s Integration Analysis assumes with a program like this, there is no way New York can pull off much more growth in incomes and wealth. High energy costs will drive jobs away and New Yorkers will be poorer as a result. Naturally, growth assumptions need to be reduced.
It appears that NYSERDA’s Integration Analysis is yielding to degrowth ideas.
This is a game of low expectations. It allows the state to say 30 years from now: Look, the Climate Act wasn’t so bad for the state after all. We assumed annual per capita GSP growth of only .84% and we’ve gotten over .9% on average!

Conclusion

Jim Shultz recently described the text of the Draft Scoping Plan: “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”. Dietmar Detering and I have found that the Integration Analysis documentation spreadsheets are worse. There are reams of numbers hiding the fact that the numbers really needed to explain the cost implications of the plan are not included. There are only a handful of people who have dug into the complexities of the Draft Scoping Plan enough to understand the deceitful actions being taken to “prove” that the Climate Act transition will have benefits that out-weigh the costs.

Detering’s analysis documents another game with the numbers in NYSERDA’s Integration Analysis. In order to “prove” benefits out-weigh costs for the future net-zero energy system, there have been multiple games played to lower costs. In this example, future load is reduced by using a lower growth rate for the economy. This lowers the cost of the necessary wind and solar resources needed.