Forecast Verification for the New York Climate Action Council Meeting

On September 4, 2021 I predicted that at the next meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council the recent flooding in lower New York State would be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post notes that for the record the Co-Chair “remarks and reflections” included a slide on the recent flooding.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  My forecast was correct because the meeting included the following slide describing the recent New York flood events (At 8:25 in the Meeting Recording).

Discussion

The immediate response after the flooding from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  As noted in the last post the mis-perception between climate and weather is so common that I have developed a page that explains the difference between weather and climate and includes articles debunking similar claims. 

In the previous post I concluded that flooding caused by heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to implement mitigation measures as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits even if the climate change alarm proves to be over rated.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.

The remarks and reflections also noted that the latest report from the Intergovernmental Panel on Climate Change had come out since the last meeting.  The director of the Department of Environmental Conservation, Basil Seggos, described the stark warnings of the report at 7:25 of the video.  Not surprisingly, there was no recognition that the high carbon pathway that gives the catastrophic predictions is based on emissions that are implausibly high because recent International Energy Agency estimates are 30% less than that IPCC scenario.  Furthermore, Dr Judith Curry writes that “The extreme tail risks from global warming, associated with very high emissions and high climate sensitivity, have shrunk and are now regarded as unlikely if not implausible.”  Nonetheless, NY policy makers continue to emphasize projections based on the high emissions and high climate sensitivity scenarios.

Conclusion

The CLCPA implementation process continues to portray any extreme weather event as “proof” of global warming driving climate change.  However, New York agencies ignore the difference between weather and climate.  A climatological average is defined as a 30-year average.  In 1954 three hurricanes and in 1955 two hurricanes hit the Atlantic coast north of South Carolina.  If that were to happen today, the alarmists would be screaming that this is definitive proof of a changing climate.  It happened over 66 years ago and has not happened again through two climatological averaging periods.  That indicates if anything, a tendency for fewer hurricanes.  I conclude that describing the flooding caused by the remnants of hurricane Ida as proof of climate change is an example of not letting a crisis go to waste and not letting the facts get in the way of a good story.

Prediction for the New York Climate Action Council’s Next Meeting

In New York’s Climate Leadership and Community Protection Act (CLCPA) the Climate Action Council is required to prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule of the law.  I predict that at their next meeting the recent flooding in lower New York State will be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post explains why the rationale is wrong and the proposed solution hurts rather than helps the flooding problems.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  Given that history I have no doubt that the next meeting will describe the flooding effects of hurricane Henri and the remnants of hurricane Ida and imply that the CLCPA will reduce if not eliminate those effects in the future.  That claim as well as all the other similar claims in the past is baloney.

New York Flooding

On August 22, 2021 tropical depression Henri made landfall in Rhode Island.  Although it had weakened from a hurricane and skirted New York, it dumped heavy rains from New Jersey to New England.   The region had a wet summer so the ground was already saturated.  As a result, the main impact was flooding.  Hurricane Ida struck the Louisiana coast on August 29, 2021 sixteen years to the day after Hurricane Katrina devastated New Orleans.  Although there was widespread devastation, the levees in New Orleans held and the loss of life was much less in Louisiana.

I followed the forecasts of the remnants of Ida as it slogged north and the east out to sea.  Every forecaster was warning that heavy rains were likely in the New York City area and coupled with already saturated grounds that flooding was likely.  Cliff Mass described the weather as it hit the area and noting that New York’s Central Park had a record of 3.15 inches in an hour.  He explains that hurricane remnants, known as extratropical cyclones, combine strong upward motions with large amounts of tropical moisture.  This combination causes heavy rains and flooding.  Tragically, dozens of people were killed in New York and New Jersey as a result of this flooding.

The immediate response from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  I believe that this will also be the response by the Climate Action Council co-chairs at the next meeting.  This is such a common response that I have developed a page that explains the difference between weather and climate and includes article debunking similar claims.  In this case however, I want to respond differently.  In particular, I want to discuss what the best approach would be to prevent a reoccurrence of the deaths and devastation in New York City.

Discussion

As I mentioned before this was a very well forecasted event with some caveats.  Cliff Mass notes that there were warnings out for heavy precipitation but that there some issues with “intensity and position”. He goes on to argue that a larger number of finer resolution weather prediction ensembles could be used to develop better probabilistic/uncertainty predictions.  I think those models could also be improved by incorporating higher density observations into the models.  All those revisions could improve the forecasts if implemented.

However, the fact is that the forecasts were ignored.  In my opinion, many New York City residents are so divorced from weather impacts (they simply are not outside for long periods that much) that they don’t pay attention to weather forecasts unless it is an extreme event.  Consequently, the idea that a forecast for heavy rain means that they should monitor the weather situation, i.e., check the weather forecast frequently in that situation, is not common practice.  As a result, communication practices have to be changed to ensure that people stay off the roads and get out of low-lying basement apartments when this kind of forecast is made.

The good news vis-à-vis Ida was that the levee resilience measures installed in Louisiana since Katrina worked well enough to prevent a re-occurrence of that disaster.  If there were other levees that failed it is clear that additional strengthening is needed.  The bigger problem there is the extensive damage to the electric system.  Clearly more needs to be done to strengthen the resiliency of the electric transmission and distribution system.

After super storm Sandy In New York City extensive upgrades were made to prevent damage from storm surges.  However, given that the subways still flooded, more still needs to be done to prevent water damage to that system.  Given the extreme amount of rain it probably is not possible to engineer a system to prevent all the many water issues but it certainly is time to update what could be done.  In addition to infrastructure improvements developing an improved warning system would be useful.  For example, during such an event if people knew that the GPS driving direction systems were being updated with flooding information, they could use them to steer clear of problem areas.

All of the aforementioned resiliency measures require investments of time and money.  However, they all can provide benefits to reduce impacts of future storms.  One of the key points to understand about extreme weather and climate change is that climate change impacts are smaller than the effects of natural variability.  As a result, it is ludicrous to expect that extreme weather will stop occurring even if climate change mitigation measures reduce global warming and the alleged effects on extreme weather.  The most likely future scenario for weather is more extreme weather and that means that adapting to the effects of extreme weather is a no regrets approach.

More importantly the fact is that beyond New York and the United States fossil fuel emissions are increasing at a rate that is many times greater than New York’s emissions.  Consequently, even if New York mitigation efforts do reduce emissions there will be no impacts on the world’s weather because of increased emissions elsewhere. 

Conclusion

The next meeting of the Climate Action Council will be on Monday, September 13, 2021 at 2:00 p.m. ET.  The meeting agenda includes a welcome item that I predict will mention the flooding in New York City as a sign that climate change is a reality and we need to fight it. 

In actuality the observed heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to do something about it as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits in any event.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.

Reliability Challenges in Meeting New York’s Climate Act Requirements

This post was published at Watts Up With That on  September 2, 2021

On July 18, 2019 former New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act “Climate Act”), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  Over the last year recommendations have been developed by panels of politically chosen representatives for consideration for a Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session that provides some interesting insights regarding reliability planning for electric systems dominated by renewable energy generation.

Background

Reliability planning in New York is prioritized because there is a long history of blackouts in New York State in general and New York City in particular.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In every case after blackouts in 1959, 1961 1965, 1977, 2003, and 2012 new requirements for infrastructure and operating rules were implemented to prevent future reoccurrences.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.  With all due respect to the professionals who are trying to develop a reliable system that incorporates large amounts of intermittent and diffuse wind and solar generation, the track record for blackouts indicates that historically not all the problems could be anticipated and that retrospective reliability improvements were the norm.

Over the past year the electric system professionals have looked on the Climate Act transition process and recommendations with increasing concern because it is clear that many of the appointed representatives do not understand the particular reliability requirements of New York.  After a year and many comments, the State finally responded with an overview briefing presentation on those requirements to the people who are supposed to guide the transition plan.  The speaker session (recording here) included presentations from six organizations with varying levels of reliability background, experience, and responsibilities:

  • New York State Reliability Council (NYSRC) – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service (DPS) – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

In a post on my blog I did an overview of all the presentations.  The warning in five of the six presentations was similar: it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions.  A “large quantity of installed dispatchable energy resources is needed in a small number of hours” and it “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs”.  That technology does not exist for utility-scale applications.  Unfortunately, in order to cater to the environmental zealots involved in the process a presentation from Vote Solar who claimed “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” was included.  That presentation was based on the report, “Why Local Solar for All Costs Less”, that is fatally flawed because it relies on annual estimates of renewable resource availability and does not address worst case conditions.

NYSRC Presentation

The presentation by the New York State Reliability Council succinctly describes the organization, how the New York electric system is operated to maintain reliability and some of the challenges presented when renewable energy sources are increased significantly.  It was so well done I thought it would be of interest to readers here.

New York’s electric system is de-regulated so reliability planning is provided by the New York Independent System Operator, various state agencies and the NYSRC.  The introduction describes the NYSRC and the Installed Reserve Margin (IRM) parameter.  The IRM is defined as the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   Load shedding occurs when the demand for electricity exceeds supply and grid operators have to turn power off for groups of customers in order to prevent the whole system from collapsing.  Note that one of the lessons learned from previous blackouts was that New York City has to maintain a significant amount of in-city generation availability to prevent blackouts.  The NYSRC has specific rules in this regard.

The next slide described how the system is operated reliably. Note that in addition to the short-term operation of the system that longer term planning is also required.  In order to address the one in ten-year criteria of the IRM, planning has to address new generation and transmission resource development that can take ten years to get built.

The slide titled “Operating the future system reliably” explained that as the mix of generation resources changes, planning and operations will also have to change.  A point of emphasis is that “Limited fuel diversity and over dependence on energy limited resources is a risk to reliability”.  In the past New York boasted a truly diverse fueled electric system with significant coal, residual oil, natural gas, hydro and nuclear resources.  There were significant resources available from sources that could store fuel on-site and could operate with more than one fuel.  However, the state has banned the use of coal and residual oil has become so expensive that its use has dropped precipitously.  The conclusion in the slide that additional dispatchable and sustainable energy resources to manage the substantially different system in order to maintain reliability refers, in part, to the New York City requirements for in-city capacity.  Presently, for example, that means facilities must be able to burn oil when natural gas is unavailable. 

The next slide (not shown here) re-emphasizes the importance of the IRM which turns out to be a future challenge when there are significant increases in renewable resources.  This is illustrated in the slide titled “Solar impact on resource adequacy”.  The slide shows the diurnal variation of load vs solar generation also known as the “duck curve”.  Typical discussions of the duck curve focus on the operational challenge resulting from the loss of solar generation at the same time the load is high.  This slide addresses the changes in the reserve requirements with the addition of 26,000 MW of new solar generation in New York.  Because of the enormous variation in available energy from solar, adding that amount of solar generation would raise the reserve requirement to approximately 22,000 MW as compared to the current reserve requirement of 6,600 MW.  It also means that the state can only retire 4,000 MW of current resources.

The Climate Act has an electric system target of zero emissions in 2040.  The Department of Public Service (DPS) and New York State Energy Research & Development Authority (NYSERDA) have made a preliminary estimate of the resources needed to meet that goal as shown below.  The key numbers from this slide are that they expect to need 88,337 MW in 2040 for an expected load of 38,000 MW.  In order to meet that load and with a loss of load expectation no greater than once in ten years the NYSRC estimates that the total reserves will be approximately 50,000 MW.

The presentation observes that the New York reserve margin will have to increase to over 100% relative to the current reserve margin of about 20%.  The estimates of resources needed to meet the Climate Act targets have not incorporated this issue so they under-estimate the resources needed significantly.  In addition, the new technologies have to be zero emissions and meet the characteristics of fossil fuels (dispatchable, fast-ramping, and long duration storage).  The presentation notes that “these resources rely on technologies that do not currently exist for utility-scale applications”.

Conclusions

I recommend reading the session presentation and listening as it gives a good overview of reliability issues facing New York or any other jurisdiction in the transition to net-zero.  One caveat is to not waste your time reading the Vote Solar presentation because it is based on fatally flawed analysis.

There is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low.  Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous.  Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be added to the total needed to balance anticipated load.  While the focus of the highlighted presentation was New York, I believe that similar problems will become evident at any other jurisdiction that attempts to develop a net zero emissions electricity system. 

The NYSRC conclusion that the state of New York appears to be headed down a transition path which will require reliance on technologies that do currently exist in less than ten years should be a wake-up call.  The ultimate question is whether the proposed transition plan will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the transition program. I fear New York consumers will be lab rats for a politically motivated virtue signaling empty gesture that is going to cost enormous sums of money, and, in the event of a major blackout, cause much more harm than good.

—————————————————————————————————————————————

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  He has  written extensively on implementation of the Climate Act because the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

Climate Leadership & Community Protection Act Reliability Planning Speaker Session Follow-Up

Note: When this was written and posted the recording was not available. The Session recording was posted on August 30, 2021

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Over the last year Advisory Panels to the Climate Action Council have developed and submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   This is one in a series of articles about this process.

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 mantain current reliability standards and that a “yet to be developed technology” will be needed.  This post addresses the study that was the basis for the claim by Vote Solar that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” is fatally flawed.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

This post is a follow up to an earlier description of the presentations made at the NYSERDA Reliability Planning Speaker Session on August 2, 2021.  The first article was a detailed description of the following presentations:

  • New York State Reliability Council (NYSRC) – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service (DPS) – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

The article included background information on the organizations as well as highlights from each presentation.  I also prepared a condensed version that was edited down even further and published at Natural Gas Now.

The advisory panels who are charged with providing recommendations to the Climate Action Council and the Council itself have been working on implementation plans for the last year.  During the development of the advisory panel recommendations, it was obvious that reliability was only receiving token consideration and that many of the panel and council members did not understand the issues and requirements for a reliable energy system.  As a result of many comments, this briefing on the topic of electric system reliability was set up.

In my previous articles I concluded that there was a common warning admonition in most of the presentations: today’s renewable energy technology is insufficient to develop a reliable electric system with net-zero emissions.  The NYSRC notes that “substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced” needs to be developed.  The NYISO explicitly points out that a “large quantity of installed dispatchable energy resources is needed in a small number of hours” that “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs” but only implicitly points out that these are magical resources that do not exist yet for utility-scale needs.  The utility consultation group explains that “technology development and diversity of clean resources are essential for long term success” but provide no details of the enormity of that task.  Even the DPS makes the point that “evaluating and implementing advanced technologies to enhance the capability of the existing and future transmission and distribution system” is necessary for future reliability.  The Utility Intervention Unit does not provide a comparable warning but does stress the importance of planning and the need to address new technologies.  Obviously relying on as yet unproven technology to transition the electric system on the schedule of the CLCPA is a serious threat to reliability.

There was one exception to this message.  Vote Solar claimed that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective”.  In my previous articles I blamed the speaker’s inexperience and lack of background on this flawed argument.   Since then, and thanks to an unnamed colleague, I have found the likely source of his mis-information as described below.

Local Solar Roadmap

Late last year the report, “Why Local Solar for All Costs Less,” described the results of a new distributed energy resources (DER) planning model.  According to a trade press story: the “planning model that includes what most integrated resource plans and solar cost-benefit analyses still leave out — a detailed and long-term view of the distribution system”.  “Developed by industry consultants Vibrant Clean Energy (VCE), the model provides a Local Solar Roadmap rooted in a super-granular and highly mathematical view of grid planning. Power flows and resources on the distribution system are looked at in slices of 5 minutes and 3 square kilometers. The operational variables built into the model are equally detailed, encompassing multiple applications for energy storage, emerging technologies such as hydrogen, and increasing stress on the system due to climate change.”  Given that Vote Solar was one of the sponsoring organizations and the use of common graphics and tables I am sure that this is the basis for the alternative view presented by Vote Solar.

The results are summarized in a slide presentation and there is an overview summary report that provide a general overview of the approach and results.   The executive summary in the report explains that:

The electricity system in the United States (US) is considered to be one of the largest machines ever created.  With the advent of clean and renewable technologies, a widespread evolution is occurring. The renewable technologies are lower cost than fossil thermal generation on a levelized cost basis, but their variability creates new and unique constraints and opportunities for the electricity system of the next several decades.  Superimposed on the changing structure of the electricity system is a damaged climate that will continue to worsen as mankind continues to emit greenhouse gas (GHG) pollution into the atmosphere.

The first problem with the report shows up in the first paragraph of the executive summary: “renewable technologies are lower cost than fossil thermal generation on a levelized cost basis”.  Levelized cost is defined as “a measure of the cost of an energy generation system over the course of its lifetime, which is calculated as the per-unit price at which energy must be generated from a specific energy source in order to break even. The levelized cost of an energy generation system (LCOE) reflects capital and operating and maintenance costs, and it serves as a useful measure for comparing the cost of, say, a solar photovoltaic plant and a natural gas-fired plant.”  The problem is that comparing costs using this measure only incorporates the costs of the facility itself not the cost to provide reliable power when and where it is needed.  Storage, load balancing and grid integration needs to be developed and those costs are necessary to cover for the intermittent and diffuse nature of wind and solar.  Not acknowledging those costs is a common trick of renewable energy advocates when claiming lower costs.

This analysis “proves” that not only are renewable energy sources the best approach but also goes on to claim that it is not necessary to rely on utility-scale wind and solar facilities. Their work supposedly proves that large additions of distributed energy resources (DER) are the best approach for the future.  They describe conventional thinking as follows:

The new, smarter approach is described as follows:

Obviously, renewables are emphasized but their grid of the future has at least ten times more local solar and storage.  The basis of the claim is new and better models.  The summary slide presentation goes on to argue that the new model is needed to because “utility planning models were designed for a century old utility system”. 

The authors claim that “These models play a critical role in developing integrated resources plans and setting electric rates, however current models are missing fundamental data” and that one of the missing pieces is “high resolution climate and weather data”.  It is not clear to me whether they don’t know or choose to ignore that current utility planning relies on multiple models.  The reliability presentations described models used to explicitly address reliability issues that incorporate historical weather data.  In the past it was not necessary to consider short-term (less than one hour) weather variations because the generating facilities did not fluctuate as much as wind and solar.  However, the work that NYSRC and NYISO are doing now does consider those fluctuations and uses shorted term data.

The complaint that transmission and distribution costs are “rarely considered or simply an afterthought” may be true elsewhere but New York’s current reliability planning process does consider them.  I also consider the claim that “they don’t account for total system costs and benefits” disingenuous for anyone that invokes the levelized cost basis to “prove” that wind and solar are cheaper than traditional generating facilities.  The point of all these arguments is that a new and better model is needed.

WIS:dom®-P

The overview summary report describes the new model that “proves” their claims:

The present study demonstrates, quantifies and evaluates the potential value that distributed energy resources (DERs) could provide to the electricity system, while considering as many facets of their inclusion into a sophisticated grid modeling tool. The Weather-Informed energy Systems: for design, operations and markets planning (WIS:dom®-P) optimization software tool is utilized for the present study. A detailed technical document of the WIS:dom®-P software can be found online. The modeling software is a combined capacity expansion and production cost model that allows for simultaneous 3-kilometer, 5-minute dispatch and power flow along with multi-decade resource selection. It includes detailed representations of fossil generation, variable resources, storage, transmission and DERs. It also contains policies, mandates, and localized data, as well as engineering parameters and constraints of the electricity system and its components. Some novel features include highly granular weather inputs over the whole US, climate change-induced changes to energy infrastructure, land use and siting constraints, dynamic transmission line ratings, electrification and novel fuel production endogenously, and detailed storage dispatch algorithms.

WIS:dom®-P is described as a “state of the art, fully combined capacity expansion and production cost model , developed to process vast volumes of data”.  It simultaneously “co-optimizes for: “(1) Capacity expansion requirements (generation, storage, transmission, and demand side resources); and (2) Dispatch requirements (production costs, power flow, reserves, ramping and reliability)”. 

The model documentation is a great example of intimidation by equation and jargon.  In order to run the model, the user defines 25 parameters ranging from “amortized capital and fixed costs for generation technologies” to “the fuel cost per unit of primary energy for generation technologies”.  Each parameter covers a range of options that vary by location.  Considering the fact that the model can cover the contiguous United States parameter definition is a daunting task.  The model optimizes a further 21 internal variables.  These are not variables in the elementary sense representing a single value.  Instead, they are multi-dimensional representations of the, for example, “installed capacity of generation technologies” and “electricity demand” covering an area up to the size of the continuous United States.  Each of the 46 parameters gets its own symbol as exemplified by the internal variable list below:

The mathematical formulation of the objective function is:

Don’t worry I am not going to dissect the formulation.  I just want to make the point that the authors of the program are very likely on a different level of mathematical understanding than the sponsors of the solar advocacy groups who wanted this analysis.  Frankly they are on a different level than me, an old retired guy who might have been able to dissect this 50 years ago but who has long since forgotten much of the mathematics behind this optimization methodology.  However, I understand enough to question whether this approach adequately addresses the issues that the NYSRC, NYISO and DPS have analyzed in their work.

Ultimate Problem

The question for the reader is why the WIS:dom®-P approach provides a different answer than the other organizations that presented at the reliability speaker session.  I believe that the reason is that all the others are addressing resource planning for the worst-case situation when load peaks.  In the past, reliability planning focused on the resources needed for peak summer loads when energy use increases above normal load to provide extra load for air conditioning.  The New York energy planners all recognize that when the CLCPA requires electrification of heating and transportation that the peak load will shift to the winter.  This leads to the bigger problem that the availability of solar and wind resources during the winter peak also has to be considered when it is expected to be much lower than in the summer.   I agree with the conclusion that the future worst-case will be a multi-day wind lull in the winter when solar energy availability is low and wind is also low but I am uncomfortable that analyses done to date adequately consider renewable resource availability during those periods.

I was unable to conclusively determine how worst-case meteorological conditions were addressed in the WIS:dom®-P approach.  The documentation states “The model was initialized and aligned with historical data from 2018 and then the simulations evolved the electricity system across the contiguous United States (CONUS) from 2020 through 2050 in 5-year investment periods”.  Elsewhere it states “Typically, seven calendar years are also simulated after a pathway solution is found. Future simulations will also include 175 years of 50-km, hourly data to determine the robustness of solutions”.   It also notes that the supply and demand balance equation set includes: “the weather-driven (wind, solar, and hydro) resource potential, charge/discharge cycles of storage and demand flexibility, and changes in demand requirements throughout the entire simulation period” among other things that suggests that the model incorporates meteorological effects on resources.  The formulation of the reserve margin (eq. 1.14.3) suggests that the calculations are on an annual basis:

The advantage of Eq. (1.14.3) is that it incorporates numerous years of weather data in a reduced form that is mathematically tractable. Some disadvantages persist. First, the minimum years (time step by time step) can jump around across the dataset. Secondly, the weather and demand are decoupled from each other. Finally, to understand the dynamics of conventional generation, storage and DSM, the original weather year time step data are used, which could underestimate their performance. Overall, however, it does provide a robust evaluation of the VRE contribution to planning reserve margins over a wide range of possible conditions.

This leads me to believe that the fatal flaw in the WIS:dom®-P approach is that the optimization occurs on an annual basis.  In order to ensure that adequate electricity is available when needed the most during the winter wind lull, the optimization balancing has to address the specific requirements of that period.  Unless the renewable resource availability constraints are addressed for the energy storage estimates during the worst-case period, the true magnitude of the resources needed to keep lights on during those conditions remains unknown.  Everyone else recognized this constraint and consequently raised a common concern about current renewable technology.

Conclusion

In the previous posts I wondered if the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel.  This analysis shows that the basis for their dreams of a “smarter” planning solution are dangerous because the supporting analysis does not address the worst case.  If electric planning does not address those worst-case conditions, then the inevitable result will be a Texas style blackout that will have enormous costs and result in people freezing to death.  The severe winter weather in Texas caused at least 151 deaths, property damage of $18 billion, economic damages of $86 billion to $129 billion, and $50 billion for electricity over normal prices during the storm.  This is comparable to the costs of superstorm Sandy.  However, the costs for one are preventable but the costs for a storm like Sandy are not.

Climate Leadership & Community Protection Act Target Status Based on NYSERDA Patterns and Trends Energy Use

The New York State Energy Research and Development Authority (NYSERDA) publishes an annual a comprehensive summary of energy statistics and data on energy consumption, supply sources, and price and expenditure information for New York State called Patterns and TrendsOn July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets of 70 percent of electricity from renewable sources by 2030 and 100 percent carbon-free electricity by 2040. This post evaluates some of the data in the latest edition, Patterns and Trends – New York State Energy Profiles: 2003-2017,  to assess where the state stands now relative to those Climate Leadership and Community Protection Act targets. 

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

For anyone interested in New York energy information the Patterns and Trends documents are a great resource.  One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data.  For space reasons the report does not list all the numbers but the underlying spreadsheet includes everything.  Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind.  In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of the year.  The latest report available, Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) publication date is March 2021 38 months after the end of the year.  I believe that these delays are due to reviews of the data by the Cuomo administration.

New York Historical Energy Sources

Patterns and Trends Section 3: New York State Energy Consumption provides data that can be used to describe the historical trends of electrical energy sources.  This section presents data on primary and net energy consumption in New York State by sector and fuel type from 2003 through 2017 in the document but provides data in many cases back to 1990 the base year for the CLCPA. Primary consumption of energy is shown by fuel type in physical units, such as tons, cubic feet, gigawatt-hours (GWh), barrels, and trillion Btu (TBtu). Total primary energy consumption by sector, including residential, commercial, industrial, transportation, and electric generation but we will only consider the electric generation sector in this analysis.  This Patterns and Trends section also includes information on other fuels, including wood, municipal waste, solar, and geothermal energy. Electricity generation reported does not include generator station use.

Figure 1 lists the historical trend (%) of the sources of electric generation in New York State (NYS) from 1990 to 2017 using data from Table 3-4b in Patterns and Trends.  The data shown combine all the fossil fuel sources into one category, list the data from each of the other categories, and combine the CLCPA renewable sources into a category.  The CLCPA defines renewable energy sources as wind, solar, biomass, geothermal, hydro and nuclear.  In 1990 NYS obtained 59% of its electricity from fossil fuels, 38% from CLCPA renewables and imported 3% from out of state.  Note that nuclear and hydro accounted for 36% of the renewables, municipal waste, biomass and geothermal under the other category provided 1% but there was no wind and solar electricity generation. 

Since 1990 there has been an uneven trend of decreasing fossil fuel use down to 30% in 2017.  Net imports has increased to 16%.  Since 2001 nuclear generation has provided around 30% and in 2017 provided 32%.  Hydro has provided between 15 and 18% since 2001.  Biomass and geothermal has stayed at 2% since 2008.  Solar had yet to show any significant generation and wind provided 3%.  The good news is that fossil is only 70% but the bad news is that imported electricity does not all meet the CLCPA renewable definition so we cannot fully assess the status of energy use relative to the CLCPA targets.

Conclusion

The Patterns and Trends document is a valuable resource for NYS energy analyses.  Unfortunately, there is a significant reporting lag so the latest available data is three years old.  In order to better address feasibility more recent data are necessary.  I will follow this article with a feasibility post with that information.

Climate Leadership & Community Protection Act Electric Vehicle Propaganda

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Since the law was enacted the process of developing strategies to meet those targets has been underway.  My posts describing and commenting on the strategies are all available here. In order to meet the emission reduction targets for the transportation sector, electric vehicles are a necessary component.  This post comments on the New York State Energy Research & Development Authority (NYSERDA) recent email giving four reasons you should consider an electric vehicle. 

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

I recently wrote a post on a similar NYSERDA email about heat pumps and the Energy Efficiency & Housing Advisory Panel scoping plan recommendations to the Climate Action Council. I noted that in the panel presentation the first mitigation strategy is an initiative to modify building codes and standards for new construction, including additions and alterations, to require solar photo-voltaic (PV) panels on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  An all-electric home must use electricity for heating and heat pumps are the proposed solution. My post showed that the NYSERDA email titled “Myth Buster: The Heat Pump Edition” was propaganda.

Propaganda is defined as material disseminated by the advocates of a doctrine or cause.  There are many propaganda techniques including “card stacking”.  This technique is a feature of the CLCPA:

It involves the deliberate omission of certain facts to fool the target audience. The term card stacking originates from gambling and occurs when players try to stack decks in their favor. A similar ideology is used by companies to make their products appear better than they actually are.

On May 10, 2021 the Transportation Advisory Panel presented their strategies to the Climate Action Council.  An outline of their recommendations is also available.  As shown in the following slide from the recommendations the first mitigation strategy initiative is to transition to 100% zero-emission light duty vehicle sales. 

The recommended mitigation strategy overview noted that a potential risk or barrier to success was “Lack of consumer awareness/interest and consumer concerns about technology & charging/fueling”.  The strategy suggests a “Coordinated and cooperative marketing campaign with industry partners” as a possible mitigant.

I think garnering support for this initiative is a major challenge for proponents.  Clearly a marketing campaign is necessary to dupe the public into this ill-advised strategy. As shown below, I believe the rationale for purchasing an electric vehicle in their marketing campaign is pretty weak and certainly not enough to make me consider getting one.

Four Reasons to Consider an Electric Vehicle

The following is the text from a NYSERDA email titled “Considering an electric vehicle (EV)? Here are four reasons you should”.  It also is available in a weblink.

There’s no denying that over the past several years the demand for electric vehicles (EV) has increased. In New York State, driving electric is a great opportunity for vehicle owners to make a positive environmental impact, lowering their carbon footprint while helping the State reach its ambitious clean energy and climate action goals.

Transportation accounts for 42% of New York State’s greenhouse gas emissions, meaning that every EV that replaces a gas-powered vehicle will help make a difference.

Making the switch to an electric vehicle is a big decision. The more knowledge you have, the more informed your choices will be. If you’re still on the fence about making the switch, here are four additional things to consider:

1: Electric vehicles will save you time and money.

Compared to gasoline-powered cars, EVs are more energy efficient and cost about 50 to 70% less to operate per mile. EV motors don’t need oil changes, you’ll be making fewer visits for regular maintenance and repairs. And since your car will run on electricity, not gas, you won’t need to make trips to the gas station. 

2: Electric vehicles are clean, quiet, and fun to drive

There is no loud engine, but electric vehicles deliver fast acceleration and surprising pick up that make them exceptionally fun to drive. EVs also boast a variety of different technological advantages, including the ability to preheat your car without garage emissions, or to turn up the bass on your speakers without engine distortions.

3: There are tax credits and rebates available to help you purchase your EV.

With an electric car charger provided by your vehicle’s manufacturer, you can simply plug into a standard home outlet to charge your car. You can also upgrade your home to a Level 2 charger, which requires an electrician to install but increases the speed of charging up to 10x compared to a standard outlet. And if you need to charge your EV while you’re out and about, rest easy: there are thousands of available charging stations throughout the State that are easy to find through mobile apps and through the NYSERDA website.

4: There are tax credits and rebates that can be put toward purchasing an EV.

Use the Drive Clean Rebate to take up to $2,000 off the price of an electric car at the time of purchase. You can also combine that rebate with the existing federal tax credit for electric cars, which provides up to $7,500 for the purchase of a new electric car.

Discussion

I will address the propaganda in the components of the NYSERDA email below.  My comments will rely heavily on Dr. Jay Lehr’s excellent overview of the many reasons that electric vehicles will never replace the internal combustion engine.

NYSERDA claims that electric vehicles will save you time and money because they are “more energy efficient and cost about 50 to 70% less to operate per mile” than gasoline powered vehicles. This ignores the fact that electric vehicles are significantly more expensive than comparable internal combustion automobiles.  There also are buried assumptions about the costs of electricity relative to gasoline that can be used to game the answers to provide this rationale.  Another claim is that “since your car will run on electricity, not gas, you won’t need to make trips to the gas station”.  What happens when you want to take a trip that exceeds the battery range is ignored.  A gasoline powered car can re-fuel in a matter of minutes whereas an electric vehicle charger takes hours if you can find a charging station that is not being used.  Lehr also points out that the cost of battery replacement and lack of a used car market should also be considered when comparing costs.

Electric vehicle proponents love to claim that they are clean, quiet, and fun to drive.  Although electric vehicles to have lower emissions the life-cycle emissions and supply chain implications of the batteries needed need to considered for this claim.  NYSERDA claims that “electric vehicles deliver fast acceleration and surprising pick up that make them exceptionally fun to drive”. Reality is that most people use their vehicles as a tool and having fun is a low priority.  The email goes on to claim that they “boast a variety of different technological advantages, including the ability to preheat your car without garage emissions, or to turn up the bass on your speakers without engine distortions”.   The first claim about garage emissions suggests this was written by someone who has a garage.  Based on my neighborhood more than half the cars are not stored in a garage in the winter.  The final claim is absurd.  Who in the world decides to buy a car based on being able to turn up their bass speakers? 

One of reasons that electric vehicle ownership is more expensive is the desirability of a charging system that can provide a full charge in a short time.  The third component notes that you can choose between the electric car charger provided by your vehicle’s manufacturer that uses a standard home outlet to or upgrade your home to a Level 2 charger, “which requires an electrician to install but increases the speed of charging up to 10x compared to a standard outlet”. Another notable observation in my neighborhood is the number of vehicles per home.  Most have at least two and anyone with adult children living at home has more. Of course, the concern about where to charge at home in my suburb pales in comparison to any city where car owners have to park on the street.  NYSERDA goes on to claim that “if you need to charge your EV while you’re out and about, rest easy: there are thousands of available charging stations throughout the State that are easy to find through mobile apps and through the NYSERDA website”.  I believe it is fair to say that European electric vehicle implementation is ahead of New York so the “horror trip” of a retired German couple who needed 26 hours to make a 765 Km or 475 mile trip in an electric vehicle makes me leery of this NYSERDA claim.

Finally, NYSERDA notes that you can use the Drive Clean Rebate to take “up to $2,000 off the price of an electric car at the time of purchase” and that you can also combine that rebate with the existing federal tax credit for electric cars, which provides up to $7,500 for the purchase of a new electric car.  There are around 9.4 million standard vehicles registered in New York.  If every one of those vehicles were to be replaced, this subsidyt would cost $18.9 billion so I have to wonder if this money will be available for everyone.

Conclusion

When I explain the CLCPA implementation strategies most people do not grasp that this abstract concept is going to have big impacts on personal choice and affordability.   Moreover, as details on the plans are fleshed out it is becoming increasingly obvious that there are serious environmental consequences that are being ignored in the process.  

In my opinion the majority of New Yorkers will object to electric vehicles primarily because of personal choice.  In my case I rely on my personal vehicles as a tool to my way of life and I expect that my concerns are similar to many others.  I do not choose my vehicles based on whether it is fun to drive.  Several times a year I use my car to take a trip beyond the range of current electric vehicles.  While I try to avoid driving in bad winter weather there are times it cannot be avoided and a car that might lose power quickly if I get marooned is a danger to me and my family.  While I could afford an electric vehicle, I see no reason to pay more for a vehicle that might be an interesting toy but has flaws for my personal use.

The fact is that purchasing a new vehicle, much less a more expensive electric vehicle, is beyond the means of many people.  Worse is that there are other costs involved with widespread electric vehicle use.  Dr. Lehr notes that “On most suburban streets the electrical infrastructure would be unable to carry more than three houses with a single Tesla. For half the homes on your block to have electric vehicles, the system would be wildly overloaded.”  As a result, the suburban electric distribution system will have to be upgraded and everyone will have to pay for those costs.  Experience elsewhere shows that, for example, upgrade costs to the electric system for the United Kingdom are enormous and will increase costs for everyone.  Therefore, electric vehicles are toys for the rich that will be subsidized by the poor.

Among the environmental consequences not included in the CLCPA implementation process are the impacts of exotic materials needed for the transition.  A recent report by the International Energy Agency included a comparison of the minerals needed for electric vehicles as opposed to conventional cars.  Assuming that a million cars are sold per year in New York in 2035 when the mandate to sell only electric vehicles are sold in New York that means that an additional 34,505 tons of copper, 8,904 tons of lithium, 43.409 tons of nickel, 15, 583 tons of manganese, 14,470 tons of cobalt, and 70,122 tons of graphite will be needed each year.  If all other jurisdictions enact similar mandates the amount of rare earth minerals required will be enormous.  The newly released book “Clean Energy Exploitations” by Ron Stein and Todd Royal explains how the development needed to provide these materials will exploit the most vulnerable people while destroying their environment. 

I conclude that NYSERDA’s rationale for purchasing an electric vehicle is out of touch with the public.  I think this strategy is ill-advised due to its hidden environmental impacts and cost shifting from higher-income drivers to lower-income consumers.  I hope that when the public becomes aware of these impacts that there will be sufficient push-back to drop the electric vehicle mandates.

Update 7/27/21: Immediately after publishing this I found another summary of the problems of EV deployment that is worth reading.  “Electrifying parts of our transportation system may result in incremental reductions in greenhouse gas emissions,” Robert Bryce argues. “But a look at history, as well as an analysis of the supply-chain issues involved in manufacturing EVs, the resource intensity of batteries, and the increasingly fragile state of our electric grid – which is being destabilized by bad policy at the state and national levels – shows that a headlong drive to convert our transportation systems to run on ‘green’ electricity could cost taxpayers untold billions of dollars, increase greenhouse gas emissions, be bad for societal resilience, make the U.S. more dependent on commodity markets dominated by China, make us less able to respond to extreme weather events or attacks on our infrastructure, and impose regressive taxes on low and middle-income Americans in the form of higher electricity prices.”

Climate Leadership & Community Protection Act Climate Justice Working Group Presentation 28 June 2021

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have commented on the advisory panel implementation recommendations presented to the Climate Action Council this year.  This post describes the first Climate Justice Working Group presentation to the Climate Action Council.  Their presentation provided an overview of their expectations and specific comments on two of the advisory panel recommendations.  There is a recording available of the meeting here.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Section 75-0111 of the CLCPA mandates that the Department of Environmental Conservation establish a Climate Justice Working Group.  I provided background information on the requirements and the membership in an earlier post.  The post also includes documentation describing the education and affiliation of the members of the working group.

According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here.

I think there is a controversy regarding the scope of this working group’s charge.  The CLCPA states that each advisory panel is required to coordinate with the climate justice working group while developing their enabling strategies.  There also are requirements that the draft and final scoping plan have to be developed in consultation with the climate justice advisory group.  I interpret that to be a consulting role but it is apparent that this working group believes that they have the responsibility to be the final arbiter whether the advisory panel enabling strategy recommendations adequately address climate justice.  As noted in my previous post, there is little technical expertise on this panel to support that role.  More importantly, their vision excludes any consideration of feasibility or competing interests.

Climate Justice Framework

My words cannot fully capture the tenor and content of the presentation by Elizabeth Yeampierre, the Executive Director of UPROSE.  It would be worth your while to listen to her seven-minute lecture to the Climate Action Council starting at 8:00 in the meeting recording.  I say lecture because my impression was that she believes that the climate justice working group has a mission that is not open to compromise, that the solutions have to come from the communities because they are most impacted, and those solutions have to not only address climate change but also co-pollutants.  Unfortunately, the basis for this climate justice framework is technically flawed and does not recognize that there is no zero-risk way to provide reliable, abundant, and affordable energy.

The rationale for the climate justice framework is that climate change is truly an existential threat.  According to Yeampierre, the next Intergovernmental Panel on Climate Change report is going show that there are thresholds for climate breakdown that will doom humanity because humans cannot evolve or develop new ecosystems to handle drastic climate shifts. However, humans have adapted their ecosystem to live across an incredible range of temperatures.  At the cold end of the spectrum the humans in the remote village of Oymyakon in eastern Siberia have adapted to an ecosystem where the record low temperature is -96 OF degrees below zero Fahrenheit and the record high is 94.3 OF.  The average monthly temperature in January is -51.5 OF and in July is 58.8 OF a range of 110 Fahrenheit degrees.  At the hottest extreme, Mecca, Saudi Arabia has had a record high temperature of 121.6 OF and record low of 51.6 OF.  The average monthly temperature in January is 75 OF and in July is 96 OF.  The 2.4 million residents of Mecca have adapted their ecosystem to live in a city whose annual average temperature is 87.3 OF.  I rate this claim as bogus.

Yeampierre goes on to point out that we need to act now because of the recent heat waves in the Pacific Northwest.  I believe that the definitive take down of that claim has been prepared by University of Washington meteorologist Dr. Cliff Mass.  The weather and climate of that region is his particular specialty and he explains that the “specific ingredients that led to the heatwave include a high-amplitude ridge of high pressure and an approaching low-pressure area that “supercharged” the warming” and showed that “global warming only contributed a small about (1-2F) of the 30-40F heatwave and that proposed global warming amplification mechanisms (e.g., droughts, enhanced ridging/high pressure) cannot explain the severe heat event”.  Again, her rationale for drastic action has no basis in fact.

In my opinion, the following justice lens diagram describes the Green New Deal which not only calls for public policy to address climate change but to also achieve other social goals and resource efficiency.  The diagram shows the plan to move from today’s “extractive” economy to a future “living” economy.  While I could certainly do a post just on this diagram, I will only summarize it below for the context of the Climate Justice Working Group.

On the left side of the diagram is today’s extractive economy where work’s purpose is exploitation.  The worldview is consumerism and colonial mindset.  Resources are to be extracted – “dig, burn, dump”.  Governance is militarism. 

The right side of the diagram describes the living economy where work and cooperation produce ecological and social well-being.  According to this, resources have to be regenerated, the worldview is caring and sacredness, and governance is by “deep” democracy.

The center of the diagram describes the plan to convert to the living economy.  Solutions that are “visionary and oppositional” will stop the bad and build the new.  If we “starve and stop” to “divest from their power” we can “feed and grow” to “invest in our power” through a values filter.  This filter moves capital by shifting economic control to communities, democratizing wealth and the workplace, advancing ecological restoration, driving racial justice and social equity, making most production and consumption locally based and retaining and restoring cultures and traditions.  All this occurs when the rules are changed to “draw down money and power”. 

I really don’t think that the majority of the politicians that voted for the CLCPA considered that the law to mitigate greenhouse gases to address climate change was also a mandate to move to a socialist utopia as described in this diagram.  I am certain that the majority of the voters would not endorse this plan.  The real question is how far is the Cuomo Administration going to go down this path to appease the environmental justice demographic but not alienate the rest of society.

In Yeampierre’s naïve view of the energy sector front line communities must defend lands and rivers from mines, power plants, mega-projects and industrial agriculture by expanding agro-ecology and transformative economies while building community-controlled energy and food systems.  This post is only going to address energy systems which she believes should be dominated by renewables like wind and solar.  The reality is that in order to convert to wind and solar the extractive impact on lands and rivers will be enormous because the rare earth metals required for those technologies require extensive mining.  Because wind and solar are diffuse, vast tracts of land will be blanketed with turbines and panels.  When those turbines and panels reach the end of their useful life they will have to be decommissioned and the materials disposed in landfills.  My point is that when looked at holistically the probable impact of renewable energy on communities will be larger but, for the urban environmental justice activists the impacts will be moved from their communities elsewhere out of sight and out of mind.

The urban environmental justice activists most hypocritical position regards health impacts.  Yeampierre advocates for a zero-risk approach to air pollution.  It is not enough to meet (with the exception of ozone in New York) the National Ambient Air Quality Standards (NAAQS) that have protected the health and welfare in the United States for decades.  The fact that the concentrations of all the air pollutants have dropped dramatically since the Clean Air Act is irrelevant because there still are elevated levels in disadvantaged communities relative to elsewhere even if those levels are less than the air quality standards.  The activists argue that, for example, power plants in urban areas have to be replaced by renewable energy and energy storage based on epidemiological statistics that claim excess health impacts from air pollution amongst other confounding factors.  That position is hypocritical because the extraction of the rare earth metals necessary for energy storage and renewable energy is done almost exclusively overseas where the health and environment protections are much weaker and labor protections nearly non-existent.   As a result, there are real health and welfare impacts directly attributable to their solution as opposed to the statistical artifacts that support their supposed problem.

There also is hypocrisy associated with their description of the extractive economy.  The unfortunate fact is that child labor is involved in the African mining industry.  It is sad and telling about their objectives that the Climate Justice Working Group has not called for New York renewable energy and energy storage facilities to require that their mineral suppliers are certified by the Responsible Mineral Initiative or something similar.

Working Group Observations on Enabling Initiatives

The working group summarized their observations and general impressions “mainly on the Transportation Advisory Panel recommendations”.  Abigail McHugh-Grifa, the Executive Director of the Rochester People’s Climate Coalition, presented the overview (starting at 14:45 in the meeting recording).  She holds a Ph.D. in Music Education, but “decided to give up her career in music to dedicate herself to climate work”.  She exemplifies my concern that the members of this working group lack the background and education to provide meaningful comments on technical issues. 

She explained that the working group decided to present comments on the enabling initiative recommendations from two panels, transportation and housing & energy efficiency, because they represent opposite ends of the spectrum in terms of how well the panels incorporated environmental justice priorities.  In other words, transportation did not address the pre-conceived notions of a “climate just” transportation system but the housing and energy efficiency checked all the boxes for their demands.

I annotated the slide used in her presentation with my italicized comments below:

  • Recognize that goals/benchmarks/accountability is essential
    • The recommendations need clear guidance on how benefits/investments will be defined, measured, tracked, and shared over the long term
    • Scoping plan must ensure data is available to accurately measure the success of implementing the CLCPA
      • I agree with this comment.
    • Better scrutinize every action for justice
      • Some of the recommendations presented false market-based solutions
        • The EJ community has historically been opposed to market-based solutions because they believe that they don’t prevent localized areas of high pollution. In the case of greenhouse gas emissions that is not a relevant concern so their problem is associated with co-pollutants.  The EJ community’s air pollution goal is zero risk, i.e., zero emissions. 
      • Provide greater clarity, reasoning, and purpose
        • Some goals such as the doubling of municipal-sponsored public transportation appear arbitrary without an analysis on the basis of the target
          • None of the enabling initiatives included any substantive documentation. As a result, I agree that more detail is needed to justify the enabling initiative recommendations.
        • Policies with significant implications like a feebate deserve more than a ‘handwave’. It sounds like ‘free money’. How does it actually work in practice?
          • I agree with this comment.
        • Provide explanation of how the social cost of carbon was incorporated
          • As far as I can tell the social cost of carbon has not been incorporated yet. It is another one of those pesky details that should be in the as yet unreleased documentation.
        • Edit jargon to plain speak, and remove vague, squishy language and strive to provide key details
          • In my opinion, the presentations by this working group exemplified vague jargon and a lack of details. Moreover, oftentimes understanding a technical topic requires knowledge of the jargon as detailed in a following section.
        • Increase ambition (using transportation panel recommendation examples)
          • Fill in the gap of connectivity between regions of the state that rely on public transportation by prioritizing high speed rail and long-range bus service
            • I don’t think the state can afford high speed rail and I am sure that the effect on travel in the only corridor (New York – Albany – Buffalo) where it might be feasible would not provide any meaningful reduction in GHG emissions.
          • Refine transit-oriented development strategy to elevate its estimated GHG reduction impact by 2050 from medium to high by placing the most emphasis on vehicle mile travel reduction.
            • Transit-oriented development refers to mixed use (residential, commercial and business) development along public transit lines to reduce the need for personal vehicles. Theory is fine but in practical terms I don’t see this as meaningful solution away from New York City.
          • Deemphasize vehicle electrification as the topmost solution as it fails to address single occupancy vehicle associated issues. This hinders our ability to address the root cause of runaway transportation emissions, and its related link to systemic issues such as racism and poverty
            • Apparently, the environmental justice advocates have issues with single occupancy vehicles. In the suburbs and in rural areas single occupancy vehicles are a necessity.  In order to convince those residents that there is a link to systemic racism and poverty issues there has to be a dialogue with the opportunity to challenge some of the presumptions but that approach was explicitly rejected by Yeampierre in her overview of climate justice.

The McHugh-Grifa presentation also used the transportation presentation as examples of some of the points made for the bullet points above.  One of her concerns was that the transportation panel recommendation outline presentation was filled with jargon and vague or squishy language and gave some examples.  For example, in slide 20, component for delivery, “make ready costs for support facilities”, she complained that “I have been doing this work for a while and I just don’t understand what that means”.  Apparently in her background in music education, she never got around to the obvious issue that if you electrify public transit buses, the transit garages aka support facilities have to be set up to recharge the batteries and service entirely different bus components.  In my conversations with an expert in this field he has pointed out many nuances and complications to this challenge that he has said that even the state’s bus electrification alleged experts don’t understand.  While I agree that the outline doesn’t do an adequate job providing documentation for the recommendations, I also have to point out that the presentation was never intended to educate members of the public who have no background in this sector simply because of space limitations. 

It got worse.  She complained of three problematic themes in the transportation recommendations that were not clear enough.  The first theme was that the recommendations only focused on “encouraging and incentivizing” behaviors rather than “concrete and enforceable policy change that would advance the systemic transformation of our transportation system that the climate crisis demands”.  In the context of single occupant vehicle use that translates to a vehicle mile traveled policy limit which I believe will bring out yellow vest protests the instant it is proposed.  The second theme was the need for clear metrics coupled with enforcement mechanisms as exemplified by the apparent failure of the transportation sector recommendations to meet the expected reductions targets.  I suspect that the transportation panel had some concerns that the reality of the changes to the transportation system needed relative to what is politically palatable led to the lack of specific enforcement mechanisms.  The last theme concerned public engagement.  Recall that a key premise of the climate justice framework is that decisions should be made by the communities.  Absent any technical expertise that is a recipe for disaster.

Just when I thought it could not get any more absurd, McHugh-Grifa complained that the transportation recommendations did not consider the potential effect of climate refugees.  She said that:

As climate conditions worsen, we in our region anticipate that we will see an increase in climate migrants and refugees that move to our area from other parts of the states and countries.  There is no indication that the transportation panel has taken these kinds of population shifts into account or is considering how the transportation needs of any given region may change over the coming decades

I agree that climate refugees will be a problem in New York but it will not be because of people moving into the state.  Instead, if these draconian policies come to pass, there will be a mass exodus out of state.

Response to Transportation Advisory Panel Recommendations

Transportation is a key climate justice concern.  However, I think that in general the working group and for that matter the transportation advisory panel vision for transportation is out of touch with the reality of transportation in the suburbs and rural areas.  For example, McHugh-Grifa stated that doubling the service would still be inadequate.  That brings up the question just how much of an improvement to service would be necessary to entice people away from their personal cars.  For example, I cannot conceive of any scenario where I would use public transit to go grocery shopping.  As disappointing as it may be for public transit advocates, the fact is that outside of New York City housing has evolved around the use of automobiles.  Changing that dynamic would require massive transformation of the rest of the state’s infrastructure.

The specific response to the transportation recommendations was presented by Eddie Bautista, Executive Director of the NYC Environmental Justice Alliance, who has a B.A. from N.Y.U. and an M.S. in City and Regional Planning from Pratt Institute.  His presentation starts at 28:20 in the meeting recording

Bautista claims that environmental and climate justices groups across the county are opposed to emissions trading programs like cap and trade. He consistently refers to a single study that claims that these programs not only don’t reduce hot spots but they exacerbate them.  The paper “Carbon trading, co-pollutants, and environmental equity: Evidence from California’s cap-and-trade program (2011-2015)” appears to be consistent with his claims.  Note, however, that a subsequent study that looked at a longer comparison period that “emissions from sources subject to the cap declined 10% between the program’s launch in 2013 and 2018”.  Because GHG emissions are a function of weather and economic conditions there is large annual emissions variability which I believe accounts for the differences between these analyses.  Moreover, the complaint that cap-and-trade programs do not eliminate pollution hot spots demonstrates a fundamental misunderstanding of air pollution control strategies.  Cap and trade programs are designed to address regional pollution problems like acid rain, ozone and global warming.  For those regional pollutants, concentrations are only a concern over large areas and impacts are not localized.  The Clean Air Act established air quality limits to address air pollution hotspots and every source has been evaluated to determine if it affects compliance with those limits.  With the exception of ozone, New York meets all those air quality limits.  Because ozone is a secondary pollutant, emissions from neighborhood power plants cannot create localized hot spots.  As noted with respect to Yeampierre’s presentation, it appears that the only environmental justice acceptable level for air pollution is zero.

I annotated the slide used in his presentation with my italicized comments below:

  • Transportation Climate Initiative (TCI) flaws
    • Best available evidence shows cap and trade systems do not eliminate air pollution hotspots, and often exacerbate them
      • This is a fundamental misunderstanding of air pollution control strategies as described in detail above.
    • Like RGGI, funds generated by TCI are vulnerable to budgetary raids by the Executive and Legislature
      • I agree with this comment
    • Reforms to cap and trade are unlikely to remedy pollution disparities given the program’s inability to surgically reduce mobile source emissions which are more complex to regulate than stationary sources
      • Because cap and trade programs were not specifically designed to address local impacts from any sources this is true.
    • The inherent design flaws of cap and trade result in environmental racism
      • My impression is that environmental racism refers to any disproportionate impact and that the only acceptable solution is no impact whatsoever.
    • The inadequate involvement of EJ groups in the policy process reflects a profound failure of democracy, and bolsters the case for abandoning sector specific carbon pricing policies for a comprehensive carbon fee like that in the CCIA.
      • New York agencies did an extensive outreach process relative to involvement in the Transportation Climate Initiative. I attended several of their meetings and environmental justice advocates were always in attendance and, frankly, it seemed that the majority of attendees were from that segment of society at least at one of the meetings.  I think this is a harsh and unwarranted criticism of the Transportation Climate Initiative stakeholder process.
    • Denial of Home Occupant Justice
      • Protect low and middle income renters by amending the provision on new market rate housing within Transit Oriented Development that is currently limited to home ownership to include renting and rent to own options
        • No comment – way down in the weeds
      • Clean Fuels Standard Concerns
        • Allowing high carbon fuel producers to meet their credit obligations by paying clean producers for their energy is a weak way to enforce the standard -as it lets them offset instead of eliminate their emissions -which by itself won’t guarantee that emission reductions and investments in overburdened communities occur at the necessary speed and scale required by the CLCPA
          • The Transportation Climate Initiative was not designed to meet New York CLCPA net zero societal GHG reduction targets. Instead, they were looking at moderate reductions and this offset option was part of that strategy.  The real question is whether this initiative has value as part of the CLCPA control strategy because these points are valid.
        • Clean air necessitates an ‘electrify everything’ approach.
          • No comment, see below
        • Allowing vehicles to combust lower carbon liquid fuels that still emit criteria pollutants won’t eliminate air pollution hotspots
          • This comment is correct

The second slide had two topics.  Bautista covered the electrify everything that moves topic and at 38:50 of the meeting recording, McHugh-Grifa discussed the hone in on equitable vehicle miles traveled reductions and the extra support for communities facing barriers topics.  She concluded that we need systemic change so we “respectfully request the transportation panel give it another go, ideally with more input from EJ groups or at least more commitment to incorporate the feedback from EJ groups that they have already received”.

  • Electrify Everything that Moves
    • Adopt ZEV for medium and heavy-duty vehicles and carve out explicit targets for trucks and bus conversion that prioritize diesel emission reduction in air pollution overburdened communities
      • As noted previously, widescale implementation of electric vehicles has severe environmental consequences elsewhere
      • As important, advocates for electric vehicles ignore all the downsides that make this technology a non-starter for many.
    • Mandate rapid phase in of the conversion of the state’s fleet to ZEVs
      • While it may be easy to mandate that the state fleet to convert, the question becomes where is the money going to come from.
    • Rapidly expand policies to encourage uptake of EVs –like incentives and enhancement/expansion of charging infrastructure
      • When I attended the TCI stakeholder meetings at least one speaker extolled the virtues of electric cars. Based on my reading I believe that you can make the case for one as the second car in the family which could be used most of the time.  The problem is that there are many instances where an EV does not make sense, e.g., the occasional long trip where in route charging would be necessary.
  • Hone in on Equitable VMT Reduction
    • Establish a New York State-supported Equitable (Fair & Affordable) Transit-Oriented Development (E-TOD) effort via the Regional Economic Development Councils or through a New York Statewide E-TOD Program.
    • Include at least 20% affordable housing minimum for all new TOD
    • Amend Municipal Home Rule Law to explicitly allow fees on new development to offset public transportation service costs
    • Require at least 50% of transportation sector climate monies to be spent on non-car programs
      • As noted before, I don’t think TOD is a viable alternative outside of the NYC metropolitan area so this strategy has limited value
  • Extra Support for Communities Facing Barriers
    • Within the Consolidated Funding Application (CFA) of the Regional Economic Development Councils, mandate prospective developers and employers to identify how their prospective projects (and related NYS funding requests) consider public transportation options for low-income workers.
    • Incentivize hiring of disadvantaged workers in transit manufacturing by enabling companies to get a credit for setting aside a certain proportion of their workforce for hiring them
      • No comment

Response to Energy Efficiency (EE) and Housing Recommendations

The Climate Justice Working Group made the point that this panel’s presentation was done better than the transportation panel and that they handled the climate justice considerations better.  The response to the EE and Housing recommendations was presented by Rahwa Ghirmatzion, Executive Director of PUSH Buffalo who studied English literature and economics at University of Buffalo starting at 40:48 in the meeting recording.  Because this article is already too long and because I don’t take exception to much of their comments on this panel’s recommendations my review will be much shorter. 

Ghirmatzion made a good point that the recommendations did not acknowledge New York’s energy affordability goal that households should not be paying more than 6% of their income on energy costs.  The point was also made that the baseline for state goals should be made available with a system to track progress relative to those goals.  I agree completely.

Her presentation discussed the need to support the transition to electric heating/cooling/cooking quickly.  The working group is convinced that people in disadvantaged communities want a “safety net style guarantee of renewable energy to every household”.  I have a hard time reconciling those initiatives that I believe will markedly increase energy costs with EJ advocacy support for them.  Given that there have been programs available for years where consumers can sign up for wind and solar power supply programs but participation has been abysmal, I believe that most ratepayers really only care how much it costs.  How can the advocates push for programs that will increase costs?

In the second slide of the response to the EE and Housing panel, Ghirmatzion recommended additional actions.  Of particular note was the suggestion to calculate costs and benefits holistically with considerations of the health impacts associated with poor indoor air quality and insufficient thermal comfort as well as the cumulative cost burden related to housing, energy, transportation, and healthcare.  Those are very good points.  There has been very little information on costs provided to date and total costs are the key.  One final point regarding the suggestion to tweak energy efficiency programs.  Energy efficiency has been part of New York energy programs for decades.  I have doubts that there is much more that can be done and have yet to see an evaluation of effectiveness relative to the goals.

Because of the length of this post, I am not going to discuss the questions and answers session starting at 48:00 in the meeting recording.

However, I have to mention Yeampierre’s response to the question at 1:35:44 about replicable solutions that could be expanded to further climate justice goals.  Her response at 1:36:49 illustrates my concern about lack of expertise leading to wasted time and effort related to the approach of advocacy panels setting policy.  She argues that current projects that use the industrial waterfront have been successful and suggests that using the waterfront as a delivery hub could be appropriate.  She suggested that this could be a way to connect to economically depressed farmers upstate by way of refrigerated barges to the waterfront to distribute healthy food.  This is a non-starter.  There is a reason that barges are used for bulk commodities that do not have delivery time constraints – they are slow.  Healthy food is fresh food and the range of suppliers within even a day of the New York City waterfront is so small that they could not possibly supply any meaningful fraction of the needs of the City.

Conclusion

I don’t think anyone disagrees with the concept that disproportionate environmental impacts on disadvantaged communities are a bad thing and should be addressed.  Unfortunately, the Climate Justice Working Group approach to this is fatally flawed.  On one hand their overview of climate justice did not include the concept of compromise so their comments on the panel recommendations were not constructive criticisms, they were demands for change.  Their criticism of the lack of detail in the recommendations is warranted but I don’t think the background and education of the working group is sophisticated enough to understand the nuances and unintended consequences of all the panel recommendations anyway.  On the other hand, their apparent goal is elimination of all environmental impacts to disadvantaged communities.  The reality of environmental regulation is that trade-offs and compromises are necessary because zero-risk policies are impossible to implement.  More importantly, pushing for minimal risks in one location means that risks are increased elsewhere as I explained relative to the rare earth metals used for energy storage. 

In my opinion, the Climate Justice Working Group’s rationales and recommendations are driven more by special interests and emotion than fact.  The summary article on the Pacific NW heatwave by Dr. Mass included a section on the politicization and miscommunication of science that was evident in this presentation.  I entirely endorse some of the comments he made:

  • “Hyping global warming puts unrealistic and unnecessary fear into the hearts of our fellow citizens.” 
  • “Global warming is an issue we can deal with, but only if truthful, factual, and science-based information is provided to decision-makers and the nation’s citizens.”
  • Politicians have “put political agendas ahead of truth and we are all the worst for it”.

In this instance I am willing to give the environmental justice advocates a pass on science accuracy especially given that the CLCPA and the state spokesmen have consistently hyped unrealistic global warming fears.  The bigger concern is the attitude of the Climate Justice Working Group vis-à-vis to any modification of their demands.  Because some of those demands are based on scientific mis-understandings and ignore worse unintended consequences it is not in the best interest of society as a whole, as compared to their narrow constituency, to implement all of their demands. 

Contrary to their belief the CLCPA says their role is to consult with the advisory panels and Climate Action Council not be the final arbiter of the enabling strategies of the scoping plan.  My impression is that they have adopted a “take it or leave it” position regarding their recommendations.  It will be interesting to see if the Climate Action Council adopts a scoping plan that addresses the science or bows to the emotion-based approach of the Climate Justice Working Group.

Climate Leadership & Community Protection Act Heat Pump Propaganda

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses one aspect of the Energy Efficiency & Housing Advisory Panel enabling strategy recommendations, namely heat pump propaganda.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

In my post on the Energy Efficiency & Housing Advisory Panel scoping plan recommendations to the Climate Action Council I noted that in their presentation the first mitigation strategy is an initiative to modify building codes and standards as shown in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025 and for multifamily and commercial buildings by 2030. The presentation notes that by 2030, more than 200,000 homes per year will be upgraded to be all-electric and meet enhanced energy efficient standards.

I think garnering support for this initiative is a major challenge for proponents.  New York homeowners have extensive experience dealing with winter weather and heating their homes.  Selling the changeover to an electric heating system will be a heavy lift particularly for anyone who has lived through a multi-day wintertime electric outage.   

The panel recognizes this and included education as a possible mitigant many times throughout their recommendations.  For example, one of the components required for delivery for Energy Efficiency & Housing Advisory Panel Enabling Initiative #4: Public Awareness and Consumer Education is to:

Support and scale up multilingual public and consumer education efforts through a large-scale, coordinated awareness, inspiration and education campaign; traditional and broad reaching media, digital communication, “influencer” style campaigns, user-generated campaigns, out of home displays, magazines, mailers, virtual tours; resources for installers, distributors, home-visiting workforce, other supply chain actors to educate consumers, customer-facing resources and tools.

When I read this I cringed because there are so many instances when the climate-related proclamations from the state are not just a little wrong they are off-scale wrong and can only be call propaganda. Propaganda is defined as material disseminated by the advocates of a doctrine or cause.  There are many propaganda techniques including “card stacking”.  This technique is a feature of the CLCPA:

It involves the deliberate omission of certain facts to fool the target audience. The term card stacking originates from gambling and occurs when players try to stack decks in their favor. A similar ideology is used by companies to make their products appear better than they actually are.

In this post I will present an email I recently received from the New York State Energy Research & Development Authority describing the use of heat pumps for home heating and cooling in the following section.  I will then discuss aspects of the email that make heat pumps appear better than they actually are.

Even when the CLCPA was still a proposal it was obvious that electric heating would be necessary to meet the greenhouse gas emission reduction targets proposed.  I wrote a post titled Air Source Heat Pumps In New York over two years ago that explains how heat pumps work and describing a research study that showed the problems with heat pumps in cold climates that make them worse than the NYSEDA description.  I will summarize the technology and the fundamental problem here but if you are interested in more details, I refer you to my previous post.

According to the Department of Energy heat pumps are very efficient because they move heat rather than converting it from a fuel like combustion heating systems do.  Air source heat pumps move energy from the air and ground source heat pumps move energy from underground water.  Note that because ground source heat pumps require digging, air source heat pumps are the preferred retrofit technology.  Unfortunately, there is a big problem with air source heat pump systems and improperly designed ground source heat pumps.  In particular when the weather gets really cold there is insufficient energy in the air or underground water to provide adequate heat when it is transferred. 

Myth Buster: The Heat Pump Edition

The following is the text from a NYSERDA email titled “Myth Buster: The Heat Pump Edition”.  It also is available in a web link.

With the beautiful days of summer upon us, there’s no better time to reevaluate your home’s current heating and cooling options than right now.

If your current system is reaching its end-of-life or if you’re just looking for ways to save energy and money while keeping your home as comfortable as possible this summer, you may want to consider a heat pump as an alternative heating and cooling option. Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.

You’ve probably heard a few things around heat pumps and the New York State climate that may have you scratching your head, but we’re here to help dispel four of the most common myths around heat pumps to help put your mind at ease.

Myth #1: Heat pumps don’t work in cold climates. 

This is one of the most common myths we hear about heat pumps – that they’re only effective in warm environments. The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit. Even in subzero temps, high quality heat pump units can heat up quickly and provide even, comfortable heating without cold spots throughout your home and without the need for supplemental heat.

Myth #2: Heat pumps create heat. 

Heat pumps don’t actually create heat — they simply move it from one place to another. Even during the winter, there is some degree of heat that still exists in the air or the ground. Heat pumps remove this heat and transfer it into your home.

Myth #3: Heat pumps are useless during the summer months.

Although they are called “heat pumps,” these systems are actually two-in-one, capable of heating and cooling. During the summer, heat is drawn out of the home, and, through the use of a reversing valve, which essentially flips the flow of coolant through the system, allows air to be cooled before re-entering the home. 

Myth #4: There is only one kind of heat pump.

When it comes to heat pumps, you actually have two primary options – a ground source heat pump or an air source heat pump. Also known as a geothermal heat pump, ground source heat pumps draw air from the ground and transfer it evenly into your home, and reverse the process during the summer. Air source heat pumps extract heat from the air outside and distribute it evenly into your home. As with geothermal heat pumps, the process is reversed during warmer months.

Discussion

I will address the propaganda in the components of the NYSERDA email below.

In the introduction, NYSERDA claims “Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.”  A moment’s thought raises the question: how can the type of heating system affect hot and cold spots?  In order to make a heat pump viable, the structure has to be very well insulated and any air infiltration reduced as much as possible.  That kind of structure will reduce the number of random hot and cold spots.  As I understand it, the retrofit approach is to replace a fossil-fired furnace with a heat pump replacement.   Any random hot and cold spots from issues with the existing duct system won’t be addressed by a heat pump per se.  To address those issues the heating system ductwork would have to be replaced.  Moreover, in order to make the heat pump viable the insulation and infiltration issues need to be addressed.

The first myth addressed is “Heat pumps don’t work in cold climates”.  The American Council for an Energy-Efficient Economy published a paper that illustrates the cold climate region problem with air source heat pumps:  Field Assessment of Cold Climate Air Source Heat Pumps (ccASHP).  The report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps were directly compared to propane and heating oil furnaces.  The report notes that “During periods of very cold temperatures when ccASHPs do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.”  The NYSERDA document does not mention the need for a backup system and, frankly, it is not clear how retaining a fossil-fired backup system will be allowed by the CLCPA.  As a result, the backup system will be highly inefficient radiant electric heat.

Figure 2 from the document graphically shows the problem.  In this field study homes were instrumented to measure the heat pump and furnace backup usage.  Backup furnace usage was relatively low and the heat pump provided most of the heat until about 20 deg. F.  For anything lower, heat pump use went down and the furnace backup went up.  Below zero the air source heat pumps did not provide any heat and furnace backup provided all the heat.  NYSERDA claims “The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit”.  Obviously when the temperature is lower than -13 aka when you want heat the most, an air source heat pump is worthless.

The second myth is “Heat pumps create heat”.  I have no issue with the response itself but the comment “Even during the winter, there is some degree of heat that still exists in the air or the ground” does not address the flaw described earlier.  In particular, there always is some heat in the air but the question is when does the amount of heat become so low that extracting usable heat is not viable.

The third myth is “Heat pumps are useless during the summer months”.  This is a great advantage to this technology because they can be used in reverse in the summer to provide air conditioning.  In more southerly locations this makes the technology a good choice as long as there is backup heating capability for the rare cold snap. 

The last myth is “There is only one kind of heat pump”.  I have no issue with this response.

Conclusion

To sum up my discussion, I believe that there are two problems with the plan to deploy air source heat pumps.  While air source heat pumps might work most of the time the fact is that when the need for heat is greatest in New York, they won’t provide sufficient heat so a backup system is needed. I believe radiant electric heat will be the preferred option for air source heat pump conversions. When the CLCPA mandate for all electric heating is implemented along with electric vehicles I am sure that local electric distribution systems will have to be upgraded at considerable expense.  Ultimately the problem is that these worst-case conditions for heat correspond to the worst annual wind and solar resource availability.  Where is the energy for this heating boondoggle going to come from? 

In several different proceedings I have voiced my concerns about air source heat pump technology in Upstate New York when temperatures are below zero.  In those comments I referenced the results from Field Assessment of Cold Climate Air Source Heat Pumps.  I recommended that NYSERDA do a similar analysis using the newer technology that allegedly eliminates the issues raised in the study.  The response has been crickets.  Until such time that there is a follow up study that supports NYSERDA’s claims and refutes the results of this study, I don’t believe any heat pump propaganda from NYSERDA.

There is another aspect to the plan to electrify home heating.  I don’t think the system is going to work well during typical cold snaps and I have serious doubts about the worst-case polar vortex outbreaks.  Unfortunately, the very worst case is an electric outage in the winter.  I survived a multi-day electric outage in the winter using a gasoline powered generator to provide power to my natural gas furnace.  The Department of Energy heat pump description noted that heat pumps move heat because they move heat rather than converting it from a fuel like combustion heating systems do.  That overlooks the ability of combustion heating systems to store fuel for use when needed.  That is a critical resource for electric outages that proponents of heat pumps ignore.

At the end of the day, I think there will be tremendous pushback when the all-electric heating requirements are rolled out.  For me personally, the requirement for an all-electric home is a deal breaker for remaining a resident of the state.  I don’t think I am the only one.

Update on Climate Leadership & Community Protection Act Emissions and the Value of Carbon

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Earlier this month I documented issues with the benefits calculations methodology that I expect will be used to show that the “benefits” of Greenhouse Gas emission reductions outweigh the costs.  The New York State Department of Environmental Conservation (DEC) recently updated their Value of Carbon guidance and this post describes the changes and, more importantly, the lack of one change I recommended.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The DEC updates to their Value of Carbon Guidance are available at Value of Carbon Guidance and updated supplemental materials. The most notable change is that DEC settled on a 2 percent discount rate as the central value, but will also report impacts at one and three percent.  All calculated values are updated in the new version as a result of this action. 

In my previous post I noted that the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal.  I believe that the guidance approach is wrong because it applies the social cost multiple times for each year of an emission reduction.  I submitted comments and recommended that the Guidance be revised.  When I reviewed the recent revisions, I noted that the there was no change to the guidance so I sent a follow up email asking whether my concern had been discussed.  My correspondence with DEC on this topic is available here

In brief my concern is that the Guidance section entitled “Estimating the emission reduction benefits of a plan or goal” includes the following example:

The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $123 per metric ton. The value of the reductions in 2021 are equal to $123 times 5,000 metric tons, or $635,000; in 2022 $124 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.

I explained that it is inappropriate to claim the benefits of the annual reduction over any lifetime or to compare it with avoided emissions.  Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $123 or $6,150,000, but the guidance approach estimates a value of $36,410,000 using this methodology. The social cost calculation sums projected benefits for every year subsequent to the year the reductions are made out to the year 2300.  Clearly, using cumulative values for this parameter is incorrect because it cumulatively counts those benefits repeatedly.  I also contacted social cost of carbon expert Dr. Richard Tol about the use of lifetime savings and he stated that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”.  Note that Dr. Tol is using the social cost of carbon nomenclature rather than value of carbon label. 

I received the following response:

We did consider your comments and discussed them with NYSERDA and RFF. We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level. 

When applying the Value of Carbon, we are not looking at the lifetime benefits rather, we are looking at it in the context of the time frame for a proposed policy in comparison to a baseline. Our guidance provides examples of how this could be applied. For example, the first example application is a project that reduces emissions 5,000 metric tons a year over 10 years. In the second year you would multiply the Value of Carbon times 10,000 metric tons because although 5,000 metric tons were reduced the year before, emissions in year 2 are 10,000 metric tons lower compared to the baseline where no policy was implemented. You follow this same methodology for each year of the program and then take the net present value for each year to get the total net present value for the project. If you were to only use the marginal emissions reduction each year, you would be ignoring the difference from the baseline which is what a benefit-cost analysis is supposed to be comparing the policy to. 

The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action. 

Discussion

DEC believes that their comparison of policies under consideration relative to the no-action baseline is appropriate but they ignore the ultimate purpose of the value of carbon.  At the end of the day, it should be used to determine whether the control policies instituted to meet the reduction targets of the CLCPA provide social value by reducing GHG emissions at a control rate ($ per ton) that are less than the projected social costs. Instead, the integration analysis will compare not only the emission reductions per year but also the avoided emissions relative to a no-action baseline over the time frame of the policy. 

 The calculation of avoided emissions is a public relations ploy along the lines of the claim that an emissions reduction policy is equivalent to taking so certain number of cars off the road.  It may be a very nice number but what is it good for?  Consider, for example, the CLCPA target of a 40% reduction in greenhouse gas (GHG) emissions from 1990 levels by 2030.  In order to evaluate compliance with that target the state will calculate emissions in 2030 and compare them to 1990 levels.  Evaluation of the CLCPA targets includes no consideration whatsoever of avoided emissions or cumulative reductions.

More importantly, in the context of the value of carbon, it is absolutely incorrect to use avoided emissions or lifetime reductions.  DEC’s Value of Carbon guidance defines the social cost of carbon as:

An estimate, in dollars, of the present discounted value of the future damage caused by a metric ton increase in emissions into the atmosphere in that year or, equivalently, the benefits of reducing emissions by the same amount in that year. It is intended to provide a comprehensive measure of the net damages—that is, the monetized value of the net impacts—from global climate change that result from an additional ton of emissions.

Glaringly, there is no mention of avoided emissions or cumulative reductions.

Conclusion

If the societal benefits of GHG emission reductions are greater than the control costs for those reductions, then there is value in making the reductions.  If that is not the case then New York should re-think its mitigation targets and policies and concentrate on “no regrets” policies such as adaptation and resiliency investments.  If New York wants to make a contribution to climate change mitigation, then money should be invested in research and development to produce mitigation measures that are cheaper than the social costs.

It is obvious listening to the Climate Action Council meetings that the “plan” is to prove the value of the advisory panel emission reduction recommendations by calculating the social costs and comparing them to the reduction costs.  Obviously, this is “thimble and the pea” time and the CLCPA hucksters will be inflating the benefits at every opportunity and discounting the costs at the same time.  DEC’s response to my comment concluded that “The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action”.  In the first place the concept of a value on carbon is contrivance designed to justify mitigation policies. Secondly the DEC values of carbon proposed exceed the Federal values to further inflate the “benefits” by choosing assumptions that get higher values.  To top it all off, now we know that the CLCPA integration analysis will use the values of carbon incorrectly to further inflate the benefits.

Another theme in the Climate Action Council meetings is constant reference to their allegiance to the “science”.  In this instance the science says apply the value of carbon only to emission reductions and not to avoided emissions or cumulative emission reductions.  That fact is inconvenient so the real “science” is ignored. 

Climate Leadership and Community Protection Act Adaptation and Resilience Recommendations

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Land Use and Local Government Advisory Panel Adaptation and Resilience Recommendations presented at the June 8, 2021 Climate Action Council meeting.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Buried in the CLCPA are two amendments to § 9. Chapter 355 of the laws of 2014, constituting the community risk         and resiliency act that add two new sections 17-a and 17-b.  The amendments read as follows:

  • 17-a. The department of environmental conservation shall take actions to promote adaptation and resilience, including:

(a) actions to help state agencies and other entities assess the reasonably foreseeable risks of climate change on any proposed projects, taking into account issues such as: sea level rise, tropical and extra-tropical cyclones, storm surges, flooding, wind, changes in average and peak temperatures, changes in average and peak precipitation, public health impacts, and impacts on species and other natural resources.

b) identifying the most significant climate-related risks, taking into account the probability of occurrence, the magnitude of the potential harm, and the uncertainty of the risk.

(c) measures that could mitigate significant climate-related risks, as well as a cost-benefit analysis and implementation of such measures.

  • 17-b. Major permits for the regulatory programs of subdivision three of section 70-0107 of the environmental conservation law shall require applicants to demonstrate that future physical climate risk has been considered. In reviewing such information, the department may require the applicant to mitigate significant risks to public infrastructure and/or services, private property not owned by the applicant, adverse impacts on disadvantaged communities, and/or natural resources in the vicinity of the project.

One of the tenets of pragmatic meteorologists is that extreme weather is going to happen with or without climate change.  Therefore, adaptation and resilience measures for known extreme weather risks is an obvious “no-regrets” approach to mitigate weather-related impacts.  This post will discuss the approach proposed and the solutions suggested for adaptation and resilience. 

Adaptation and Resilience Recommendations

The Land Use and Local Government Advisory Panel outlined the perceived problem, described 12 adaptation and resilience recommendations in three categories, and claimed a number of benefits and impacts in the presentation to the Climate Action Council (recording here).  

One of the ironies of the presentation was that there were repeated appeals to the “science” even as the discussion ignored the scientific process.  Central to the scientific method is the idea of empirical falsification whereby theories are scrutinized and tested using data and facts.  Importantly, this means evaluation of all the data.  Albert Einstein once said, “No amount of experimentation can ever prove me right; a single experiment can prove me wrong.”  The CLCPA process routinely picks and chooses its supporting science arguments but ignores any conflicting evidence.

In order to justify the adaptation and resilience recommendations there was a slide listing “New York’s climate vulnerabilities”.  The CLCPA rationale for the transition away from fossil fuels is that climate change is a reality and our future is at stake.   I recently summarized recent articles debunking the “climate emergency” meme.  I have also set up a page that provides links to posts on the claims that the effects are being seen now and there is a climate emergency that dictates action now.  I also have a page with posts highlighting the  difference between weather and climate which is constantly mistaken by Climate Leadership and Community Protection Act (CLCPA) advocates.  Based on that work, I believe the slide is mostly cherry-picked baloney.

The justification for action veers even further from the science in the slide “Significant risk in continuing GHG emissions”.  The claim that there could be 100s of billions of dollars of damages per year is only possible “under a high emissions scenario”.  That scenario has been described as “increasingly implausible with every passing year”.  Roger Pielke, Jr. explains “Evidence indicates the scenarios of the future to 2100 that are at the focus of much of climate research have already diverged from the real world and thus offer a poor basis for projecting policy-relevant variables like economic growth and carbon dioxide emissions.”  Nonetheless, the CLCPA advisory panels and state agencies trot out this propaganda at every opportunity.  The fact is that they pick and choose the quotes that support their claims for inevitable climate catastrophe and ignore all contradictory findings.  That is not “science”.

The panel proposed 12 enabling strategies in three categories.  Under “Building Capacity” they proposed four enabling strategies: AR1: Commit to creating, implementing and updating a comprehensive and equitable state climate change adaptation and resilience plan; AR2: Incorporate equitable adaptation and risk-reduction considerations into relevant state funding and regulatory programs, projects and policies; AR3: Strengthen meaningful community engagement and public education, and build adaptive capacity across all sectors; and AR4: Identify and evaluate options for supporting equitable adaptation and resilience practices and projects, and to enhance insurance protection.  The “Communities and Infrastructure” theme had five strategies: AR5: Provide state agency planning and technical support for equitable regional and local adaptation and resilience plans and projects; AR6: Evaluate opportunities to ensure equitable consideration of future climate conditions in land-use planning and environmental reviews; AR7: Develop policies, programs, and decision support tools to reduce risks associated with coastal and inland flooding; AR8: Develop policies and programs to reduce human risks associated with new patterns of thermal extremes; and AR9: Ensure the reliability, resilience and safety of a decarbonized energy system.  The last category, “Living Systems” had three enabling strategies: AR10: Develop policies and programs to reduce risks threatening ecosystems and biodiversity; AR11: Enhance climate resilience and adaptive capacity of agricultural community, while preparing to take advantage of emerging opportunities; and AR12: Develop policies and programs to preserve and protect the ability of forest ecosystems to sequester carbon.  I am not going to address each of these strategies but will highlight some issues with some of them.

“Building capacity” refers to yet another plan with its associated bureaucracy, including adaptation and risk-reduction considerations into relevant state funding and regulatory programs, projects and policies; identification and evaluation of options for supporting equitable adaptation and resilience practices and projects. Finally, there is the indoctrination recommendation to “strengthen meaningful community engagement and public education” no doubt continuing the theme of carefully selected “science” as the rationale for all this planning.

I agree with the concept of a state adaptation and resilience plan but I believe that it would be more appropriate to emphasize observed extreme weather rather than alleged climate impacts.  Most of the people involved in the CLCPA implementation don’t understand, don’t want to understand, or understand but have vested interests to ignore the fact that we don’t understand the climate system well enough to project how much of an effect, if any, reductions in GHG emissions will have on observed weather.  The fact is that society does not have a resilient plan for extreme weather so even though the rationale is wrong, the concept of a plan to address extreme weather is a good one. 

The proposal includes an update the New York State Energy Research & Development Authority’s (NYSERDA) ClimAID report.  The last edition squandered a lot of money for climate scientists to run models and claim that they could distinguish the climate signal in New York.  Naturally all the results were consistent with New York’s climate agenda.  I expect nothing different this time.  Unfortunately, the enabling strategies continually refer to using the projections from this analysis in their planning processes.  If the analyses use the inappropriate emissions projections described above, the result will over-estimate potential effects and unnecessary resources will be expended for unlikely projections.

The theme of “communities and infrastructure” is to develop a planning process that incorporates consideration of future climate conditions. Specific strategies for coastal and inland flooding as well as “new patterns of thermal extremes” are proposed.  The benefit of implementation is: ”reduction of climate risks results in direct health and safety benefits”.  This includes the biggest oversight in the presentation.

The final enabling strategy for communities and infrastructure is “Ensure the reliability, resilience and safety of a decarbonized energy system.”  The Climate and Community Investment Act’s Legislative findings and declaration stated that Superstorm Sandy “caused at least 53 deaths and $32 billion in damage in New York state”.  In February 2021, severe winter weather in Texas caused at least 151 deaths, property damage of $18 billion, economic damages of $86 billion to $129 billion, and $50 billion for electricity over normal prices during the storm.   For years prior to the storm about $66 billion was spent on wind and solar in Texas.   In addition, the wind and solar sectors collected about $21.7 billion in local, state, and federal subsidies and incentives.  The problem in Texas is that when electricity is needed most, weather conditions are least conducive to wind and solar production.  New York is embarking on the same approach, has the same renewable resource availability problem, and should expect the same sort of impacts if a winter storm knocks out the electric system when heating and transportation are electrified.  This enabling strategy is critical but not because of climate impacts.  It is much more likely that the transition to renewable energy to meet the CLCPA targets will be the problem that affects reliability, resilience and safety.

The theme “living systems” had three enabling strategies: policies and programs to reduce risks threatening ecosystems and biodiversity, “enhance climate resilience and adaptive capacity of agricultural community” and policies and programs to preserve and protect the ability of forest ecosystems to sequester carbon.  These enabling strategies suffer from the same oversight as the previously discussed reliability, resilience and safety strategy.  The greatest threat to New York’s living system is the land needed to build all the wind and solar facilities needed to produce enough renewable energy to replace fossil fuels.  An analysis done for NYSERDA on wind power and biodiversity found that: “5,430 square kilometers (1.3 million acres) of land in New York that are both suitable for wind power development and avoid areas that are likely to have high biodiversity value. Using an estimate of 3.0 MW/square kilometers, this translates to a megawatt capacity estimate of 16,300 MW (± 9,000 MW) for New York’s terrestrial landscape.”  The latest projections suggests that twice as much wind power development will be required which obviously means that development will occur in areas of high biodiversity value.  Surely the space needed for wind and solar development will also adversely affect agriculture lands and forests.  Also unrecognized is the fact that in rural areas where electric outages are common residents commonly use wood stoves for backup.  When the requirement for all electric homes kicks in, I think the demand for wood for heating will soar which will adversely affect the ability of forest ecosystems to sequester carbon.

Benefits and impacts

The presentation to the Climate Action Council had three slides describing benefits and impacts.  The first argued that because disadvantaged communities are most vulnerable to climate change it presents an opportunity for the CLCPA implementation to address those vulnerabilities.  While I have no issue with the concept that disadvantaged communities should be targeted, I worry that the potential for all the programs to increase energy costs will mean that many of those least able to afford higher energy prices will not get the support they need to prevent energy poverty.  The disconnect between inevitable higher energy prices with very little direct benefits to those least able to afford those increases and the support for programs that cause higher energy prices by environmental justice organizations befuddles me.  Ultimately poorer people will have a more difficult time adapting and becoming more resilient to extreme weather and the alleged effects of climate change.  I will address this issue when I post on the recommendations from the Climate Justice Working Group

Health benefits are commonly ascribed to actions that consider climate change.  The presentation’s slide lists direct health benefits.  Someone, somewhere following the climate change funding bandwagon has undoubtedly made claims for those benefits.  I leave it the reader to consider how likely these alleged benefits could be linked to climate change as opposed to other factors

Another common theme for CLCPA proponents is that implementing these programs will create jobs.  During this process no one has raised the possibility that higher energy prices might force businesses to re-locate or go out of business so job losses are a real potential.    There is one other aspect of this slide that needs to be highlighted.  There is a graphic image that includes a quotation that states that UCLA professor Christa Tirado said in 2011 “in 2020, the UN has projected that we will have 50 million climate refugees”.  It is 2021, and rather than relying on a ten-year old projection I believe it would be more appropriate to document where the climate refugees are.  Absent that verification I can only label this as another example of cherry-picked propaganda.

Conclusion

In my 45-year air pollution meteorology career there has been more than one instance where I got the right answer but for the wrong reason.  For example, while evaluating air quality models that predict the impacts of power plants, I found that the models were protective of human health and welfare because they conservatively predicted downwind concentrations compared to observations.  However, there were instances when the models predicted the highest concentrations for one set of meteorological conditions and the observed highest concentrations occurred during a different set of conditions.  Right answer for the wrong reason.

In my opinion this sums up the CLCPA adaptation and resilience recommendations.  I agree that this is something that should be done because our current infrastructure is not resilient to observed extreme weather.  However, the rationale for these recommendations is that they need to be done because of climate change impacts.  Proponents of the CLCPA believe that any unusual weather is due to climate change caused by human emissions of greenhouse gases.  That opinion flies in the face of the “science” that the naïve believe supports their position and common sense.  Given that climate has always been changing and that historical CO2 levels have varied more than current observations, common sense says that whatever effect anthropogenic greenhouse gas emissions have on weather is a tweak and not the primary driver of observed weather variations. 

Finally, I showed that the greatest threat to the reliability, resilience, and safety of the electric system is not climate change but the proposed plan to rely on intermittent and diffuse wind and solar resources to provide most of the electric energy in the state.  Furthermore, the greatest threat to ecosystem biodiversity is the land use that will have to be converted to utility-scale wind and solar facilities.  There simply is not enough land suitable for wind development that does not have high biodiversity value to prevent development where it will have significant impacts.