Category: NY Climate & Community Protection Act

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Power Generation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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.

Power Generation Strategy Comments

I am disappointed by this panel’s strategies.  Arguably the strategies from this panel are the most important because a basic tenet of decarbonization is electrification of everything.  If the proposed strategies are not realistic then everything else fails.  I have no seen no sign that there is sufficient focus on strategies that address reliability and affordability of a completely transformed electric sector.

In a post on the peaking power plant problem in New York City I included a section on public policy concerns.  I have previously described how the precautionary principle is driving the CLCPA based on the work of David Zaruk, an EU risk and science communications specialist, and author of the Risk Monger blog.  In a recent post, part of a series on the Western leadership’s response to the COVID-19 crisis, he described the current state of policy leadership that is apropos to this panel.  He explains that managing policy has become more about managing public expectations with consultations and citizen panels driving decisions than trying to solve problems.  He says now we have “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”.  That is exactly what is happening on this panel in particular.  Facts and strategic vision were not core competences for the panel members.  Instead of what they know, their membership was determined by who they know.  The social justice concerns of many, including the most vocal, are more important than affordable and reliable power.  The emphasis on the risks of environmental justice impacts from the power generation sector is detracting from the need to develop a scoping plan that ensures affordable and reliable electricity.

It is not clear that the members even understand the enormity of the challenge.  I used the panel’s email address for public comments last October to suggest a workshop to explain how energy systems work and quantify how much energy is needed and where to provide reliable power to give the panel members a common basis.  I even included an overview of the energy system to show why the workshop is needed.  There is no sign that anyone on the panel is aware of my comments and there hasn’t been a workshop.  I naively believed that that the deep decarbonization workshop would address this need.  Unfortunately, the workshop did not provide any discussion of the reliability challenges.  Instead, the workshop mostly reinforced the notion that CLCPA targets will be met because of the political will of the State.  Long-duration energy storage is the key need and a presentation on that was useful but it did not address the availability or applicability to New York so it is not clear if there is a viable solution to this critical requirement in the timeframe needed.  The keynote, hydrogen, and carbon sequestration presentations all sound great superficially but no context relative to New York needs was given and they all have serious technological or implementation issues.

The panel organized itself into four sub-groups: equity, barriers, solutions for the future, and resource mix.  They presented ten strategies in the presentation to the Climate Action Council.  I address their strategies below.

The equity sub-group presented three strategies.  I don’t think these should be stand-alone strategies.  Instead, these concerns should be incorporated into strategies for the transition similar to how equity considerations were handled by all the other panels.

The first strategy addressed community Impact suggesting the development of recommendations to identify and proactively address community impacts relating to health concerns, access to renewables and energy efficiency, and siting.  Four equity concerns are described:

• • • • Reduce disproportionate impacts in overburdened communities (e.g. the operation of high emission power generation facilities result in significant health concerns for neighboring communities)
      • Consider means for increasing access to energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities
      • The siting of renewable projects and their potential impact on local communities both in the short and long term, particularly in rural areas
      • The impacts on communities (e.g. jobs, revenues, etc.) where energy facilities are being retired

The operation of high emission power generation facilities refers to peaking power plants which has become a rallying topic for environmental justice advocates.  Its inclusion confirms my suspicions that panel members need to be provided background information because there are some basic misunderstandings. I prepared and submitted a comment to powergenpanel@dps.ny.gov explaining that the presumption that these peaker plants are contributing to local health impacts because of ozone and particulate matter impacts is simply a wrong premise.  I described another problem in another comment that explained that there is a mis-understanding which New York City power plants are for peaking purposes and which ones are used for other services.

Considering means to increase energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities is also problematic.  This is a power generation strategy so energy efficiency is a different panel’s concern.  In my opinion if this is included then this approach for peaking power should have been a stand-alone strategy. The rationale is to provide equity but in order to do that there are technological challenges that have to be addressed.  There are so many challenges that it deserves its own focus but the naïve under-estimation of the challenges emphasized the goal itself over the implementation effort needed.  The remaining two equity concerns are non-controversial and could have been easily incorporated into other implementation strategies as necessary.

The second strategy is “Access and Affordability for all (Enabling) –Develop recommendations to ensure New Yorkers have access and can afford to participate meaningfully in NYS’s clean energy future”.  Inherent in this strategy is the belief that people want to be able to access clean energy presumably by participating in a community project if they cannot install solar panels at home.  Forgotten is the fact that ratepayers have had the opportunity to purchase “green” energy for years but that subscription to those offerings has always been low.  Overlooked is the fact that if participating means lower prices for participation in specific programs it also means that everyone not participating in those kinds of programs is footing the bill for everyone who does.  As long as there are any people with already unacceptable energy burdens this strategy may do more harm than good.

The final strategy from this subgroup is “Workforce Development (Enabling) –Develop recommendations to enable an equitable clean energy workforce”.  Again, this clearly is more appropriate as an equity concern in implementing strategies rather than as a stand-alone strategy.

The Barriers sub-group presented two strategies both of which should get higher priority than suggested by the presentation:

• • • • Clean Energy Siting
      • Energy Delivery & Hosting Capacity

Because the primary decarbonization strategy is electrification, clean energy siting is a primary consideration.  This sub-group listed eight issues to explore:

• • • • Optimizing new transmission builds
      • Collocated storage with renewable energy projects
      • Correctly designing clear and transparent price signals for both energy and interconnection costs
      • How to properly track progress and make course corrections as process progresses
      • Provide standardized property tax assessments for renewable projects
      • Encouraging more robust host community and PILOT plans to increase benefits for community members
      • Explore reducing timeframe and restrictions for siting on brownfields and unused industrial land
      • Siting projects closer to end user areas

The first four issues are fundamental implementation issues.  Because wind and solar energy is diffuse, transmission has to be developed to get it where it is needed.  Because wind and solar energy is intermittent, it is not dispatchable and energy storage is needed to get it when it is needed.  New York’s electricity system is de-regulated so the market will dictate whether these resources are developed.  The ambitious schedule of the CLCPA targets means that tracking progress is a fundamental requirement to achieve those targets.  I agree with them all.  The remaining four issues are less important because they address comparatively minor implementation concerns.

Energy delivery and hosting capacity is another primary consideration.  The sub-group listed six issues to consider:

• • • • Upgrading aging infrastructure and optimizing the location and operation of new transmission projects, including transmission of off-shore wind, and removing regulatory barriers that make optimization difficult
      • Upgrading the transmission system to be able to host more distributed energy resources
      • Easing interconnections on both the bulk and distribution levels
      • Energy delivery extends beyond transmission to include storage, especially as the saturation of intermittent resources increases
      • How should the economic tradeoff between new transmission, energy curtailment, and energy storage be considered
      • How to properly track progress and make course corrections as needed

All of these are fundamental consideration issues.  There is one glaring omission however.  Wind and solar energy produce asynchronous generation but the transmission grid is synchronous.  The need for ancillary services to provide that support must be included.

Solutions for the future addresses the fact that implementation of the CLCPA targets is pushing the limits of technological capabilities. Unfortunately I believe that is contrary to the presumption of many that meeting the goals is only a matter of political will.  Two issues were raised:

• • • • Technology and Research Needs
      • Market Solutions –Maximize the market participation of different technologies in a way that adds to system efficiency & send correct price signals to resources over time

The rational for technology and research noted that:

• • • • Adoption of new technology to enable CLCPA goals must be integrated with more traditional investments for continued safe and reliable operation of the grid
      • Timeframes for adoption of new technology on the electric grid must be accelerated from the typical timeline of 5+ years from initial commercial product availability to deployment at scale

Unfortunately, reality as expressed as a potential implementation challenge is that “demonstration and validation of technology frequently requires large scale projects in real world use cases that are both costly and require coordination of many entities.”  Clearly there is need for a feasibility study to determine what can be counted on from existing technology and what new technology is needed either for feasibility or affordability.  Last year the International Energy Agency (IEA) published “Special Report on Clean Energy Innovation” that concludes that innovation is necessary for jurisdictions to fulfill their de-carbonization targets.  The Energy Transition Plan Clean Energy Technology Guide summarizes 400 component technologies and identifies their stage of readiness for the market.  It should be used in a feasibility study to rate the potential availability of any technology proposed.

The other issue of market solutions should be a big concern.  New York’s electricity system is de-regulated so the market is expected to provide the necessary resources.  However, uncertainty is a problematic issue with investors.  As a result, new technology may require guarantees for market investors to provide the support that market advocates believe will appear.

The resource mix subgroup presented three strategies:

• • • • Growth of renewable generation and Energy Efficiency
      • Effectively Transitioning away from Fossil Fuel Energy Generation
      • Deploying Energy Storage and Distributed Energy Resources (DERs)

The rational for the first strategy sums up the basis for my concerns very well:

“The CLCPA requires 70% renewable electricity by 2030 and 100% carbon free electricity by 2040. We anticipate demand growth of 65% to 80%, dependent on the scale and timing of electrification and whether there are clean alternatives for transportation and buildings, such as bioenergy. The level of electrification needed to achieve GHG reduction goals will increase overall electric load and shift the system peak from summer to winter. There remains a large amount of renewables that must be procured and developed to reach the goals and NYS needs to incorporate flexibility and controllability as we electrify these sectors in order to create a more manageable system.”

As noted before, a feasibility study for the technology is needed. A primary prerequisite is an official estimate of the projected loads when other sectors are electrified.   However, I have an even more basic feasibility concern. As a party to the Department of Public Services (DPS) resource adequacy matters proceeding, docket Case 19-E-0530, I have submitted comments (described here and here) based on my background as a meteorologist who has lived in and studied the lake-effect weather region of Central New York.  Both E3 and the Analysis Group have done studies of the weather conditions that affect solar and wind resource availability in New York.  However, to my knowledge (neither consultant has ever responded to my question on this topic), they have not considered the joint frequency distribution of wind and solar or used solar irradiance data from the NYS Mesonet. In my opinion, both parameters have to be considered together and using airport data or models for cloud cover are inadequate.  The Mesonet data set is the only way to have information that adequately represents the local variations in cloud cover caused by the Great Lakes.  In order to adequately determine the combined availability of wind and solar I recommend using that data set for the renewable resource availability feasibility study.

The second strategy, “Effectively Transitioning away from Fossil Fuel Energy Generation” could be used as the outline for all the strategies of the panel.  The rationale states: “As renewable penetration increases, how do we transition away from fossil fuels while maintaining reliability and safety standards?”  The normal convention for priority ranking is to put the most important issues first in the presentation.  It is discomforting that this is placed ninth of the ten strategies.  It brings up the question just what are the priorities of this panel if reliability and safety concerns are ranked so low?

The final strategy from this workgroup was “Deploying Energy Storage and Distributed Energy Resources (DERs)”.  In my opinion, there was insufficient emphasis on technological feasibility in the discussion of energy storage in this strategy.  As mentioned earlier, a major shortcoming in these strategies is the lack of any mention of the need for transmission ancillary services.  There is recognition that long duration storage will be needed but the fact that the few large battery systems currently deployed are being used for ancillary services and not storage is an obvious barrier that has not been included.  Another concern I have with this strategy is that the definition of DER has changed to exclude distributed generation using fossil fuels.  Has anyone thought to ask the hospitals with DER systems whether they can put up with the limitations of renewable DERS for their obviously critical need for constant electric power?  An ice storm that knocks power off for days will quickly over-tax the capabilities of any renewable and energy storage system to keep a hospital running.

Missing Points

I have mentioned previously that the major missing point in these strategies is that ancillary services are not mentioned.  Someone, somewhere has to address the frequency control and reactive power needs of the grid.  Obviously, that has to be included in the strategies.  It goes beyond simply adding it to a strategy because it is not clear how those services can be incorporated into the market signal to provide them.  For example, there are advocates for a carbon price on electricity generation.  In this approach any generator that emits CO2 will have to include a carbon price in their bid which serves to provide the non-emitting generators with more revenue.  However, solar and wind generators are not paying the full cost to get the power from the generator to consumers when and where it is needed.  Because solar and wind are intermittent, as renewables become a larger share of electric production energy storage now provided by traditional generating sources will be needed but there is no carbon price revenue stream for that resource.  Because solar and wind are diffuse, transmission resources are needed but solar and wind do not directly provide grid services like traditional electric generating stations.  Energy storage systems could provide that support but they are not subsidized by the increased cost to emitting generators.  When the carbon pricing proposal simply increases the cost of the energy generated, I think that approach will lead to cost shifting where the total costs of fossil fuel alternatives have to be directly or indirectly subsidized by the public.  This result is not in the best interests of low-income ratepayers.

Funding and affordability considerations received short shrift from this panel.  In light of the fact that the New York Independent System Operator has proposed a carbon pricing initiative for the electric sector it would seem that a strategy to address that approach or something else should be included.  There is another aspect of affordability that should also be addressed.  The Department of Environmental Conservation recently released its guidance on the value of carbon.  Because the electric sector has documented control costs, this panel should include a strategy to determine if the marginal abatement cost approach should be used for recommendations to the Climate Action Council.

Conclusion

This was the only panel that included specific strategies to address environmental justice concerns.  All the other panels incorporated those concerns within their strategies and it would have been appropriate to do the same here.  It appears that the idealogues on this panel are more concerned about those concerns than affordability and reliability.  In my opinion those should be the primary concerns of this panel because those factors will impact the disadvantaged people of New York the most.

Because of the importance of power generation to the electrification needed to reduce GHG emissions in all sectors, this panel should focus its attention on the challenges of a transition to an electric system that is dependent upon wind and solar resources.  I recommend that strategies include a feasibility study of technology needed for the transition, a resource availability study and a cumulative environmental impact analysis.  Until this feasibility studies are complete any strategies are simply guessing and the absence of a cumulative environmental impact assessment could mean that the impacts from the cure are worse than impacts from the disease.

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Energy Efficiency and Housing Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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.

 General Comments

I believe that the primary consideration of any implementation strategy should be affordability and reliability for the energy system of New York.  Energy use is largely inelastic so increased energy costs are hidden regressive taxes.  Our society needs dependable energy so current reliability standards must be maintained.  In general, each strategy must address potential costs and who would pay, whether there are co-benefits that would offset costs, any impacts on energy reliability, the feasibility of the proposed action, and the GHG reduction potential.

I believe that the CLCPA implementation strategies should consider cumulative environmental impacts of the renewable energy development proposed.  As far as I can tell the only related environmental impact analysis was the Department of Public Service (DPS) Final Generic Environmental Impact Statement and the Final Supplemental Environmental Impact Statement for CASE 14-M-0101 – Reforming the Energy Vision and six other cases.  The supplemental impact statement evaluated the potential environmental impacts of the Clean Energy Standard mandating that 50% of all electricity consumed in New York by 2030 be supplied by renewable resources.  Of course, the CLCPA upped the ante and now 60% of all electricity of all electricity must be supplied by renewable resources by 2030.  The important point is that the amounts and types of new renewable generation that may be needed to meet the CLCPA goals are much larger than anything evaluated by the State to date.   The supplemental impact statement evaluated a base case large scale renewable on-shore wind increment of approximately 29,000 GWh (9,508 MW) and a high-end case of approximately 40,000 GWh (14,504 MW) of large-scale on-shore wind energy would be necessary to meet the goal.  The Analysis Group “Climate Change Impact Phase II – An Assessment of Climate Change Impacts on Power System Reliability in New York State” draft final report released in October 2020 projected that New York would have to develop all of the projected National Renewable Energy Lab’s technical potential on-shore wind capability of 35,200 MW – three times what has been evaluated.  Similarly, no one has evaluated the environmental impact of the latest estimates of utility-scale solar and off-shore wind.

I have a general concern about the CLCPA mandates for investments.  It is entirely appropriate that there should be an emphasis on environmental and social justice but I have concerns about the State’s approach.  Given that all other jurisdictions that have attempted to reduce GHG emissions have increased the cost of energy, it is likely that will be the case in New York too.  I think strategies have to consider cost-effectiveness to reduce the regressive impact on those who can least afford those increased costs, regardless of location, who are living in energy poverty or already have a disproportionate energy burden.  This means that strategies that do not reduce costs or have low GHG reduction potential should be ranked very low for future consideration.

Comments on Proposed Strategies

The Energy Efficiency and Housing Advisory Panel had 16 strategies in five scoping categories.

The first scope was titled as “Mandates that require energy efficiency improvements and on-site emissions in building and appliance with dates as market signal” and included two strategies:

• • • Expand State energy & building codes (with date signals) to drive the transition to electrification & building efficiency and
    • Modify State Appliance Standards (for example, ban fossil fuel appliances sales and installations). Consider building performance standards for large buildings to meet 2050 and interim targets with a focus on onsite emissions.

I don’t think the public is going to be willing to make the sacrifices called for in these strategies.  It would be best for all concerned to get out there with publicity now to gauge acceptability.  There are all sorts of issues. For starters, how will house trailers be considered.  For the rural poor this is often all they can afford and it is simply not possible to improve energy efficiency much.   There also is an implementation issue associated with housing sector date-certain efficiency standards.  What happens to someone trying to sell an old house after the certain date. Presumably, they will be on the hook to spend whatever is needed to get up to the efficiency standard to be able to sell and that means losing a big chunk of equity in their home or the house is priced out of the market and they cannot sell the house.

Three strategies were listed in the “Financing and incentives for building efficiency and electrification at scale” scope:

• • • • Inducing market/behavioral change (e.g., taxes, registration fees, carbon levies) that incentivize market providers (owners, developers, lenders etc.) and residents to reduce emissions and transition to electrification;
      • Shift lenders to quantify energy efficiency in single/multifamily/commercial (e.g. underwriting to savings); and
      • Financial incentives for owners, developers and residents (e.g. cash incentives, pay as you save, low-interest financing, more agile of existing programs to get to 2050 and interim targets, etc.), with emphasis on low and middle income owners.

The biggest hurdle for these strategies is cost.  In many instances the capital cost of the electric option is more expensive than the fossil fuel option.  Moreover, I see absolutely no reason to expect that the cost of electricity will go down because that has not been the case in any jurisdiction that has attempted to meet GHG reduction targets.  I also have reservations about taxes, registration fees or carbon levies and the proposed emphasis on disadvantaged communities.  In the first place the requirement for targeted investment benefits may have the perverse effect of increasing the overall cost of energy because those investments may not be the most cost-effective approaches to reducing CO2 emissions.  If that is the case then anyone who is not a direct beneficiary of financial incentive benefits is going to be hurt. The Climate Action Council needs to track energy poverty or energy burden and the effect of these policies on those who can least afford additional energy costs so that no one (whether or not they are in a dis-advantaged community) is literally left out in the cold.

The third scope was called “Training and education of building decarbonization to improve behavior and operations for health and comfort and build workforce (enabling strategy)”.  Three strategies were included:

• • • • Workforce development to provide skilled professionals to design, build, operate, & enforce decarbonized building stock;
      • Education -owners, developers, design professionals and other stakeholders: resources on capital planning, all-electric buildings, electrification-ready, etc. Mandatory energy performance disclosures and building consumption data (public facing); certified product declarations for materials/equipment; and
      • Education-residents/businesses: performance, economics., environmental quality, operation and maintenance for low-carbon technologies.

Clearly, we need to train professionals to design, build, and operate the decarbonized building stock but what is the meaning of enforce decarbonized building stock? When proposing building decarbonization strategies you have to prove that decarbonization will be affordable, maintain current levels of reliability, not lead to unintended environmental consequences that exceed the alleged impacts of climate change in New York, and actually have some sort of quantifiable effect on climate change.

The “Technology innovation and demonstration to drive better performance, reduce costs, and increase customer confidence” scope had four strategies:

• • • Research and development to improve cost/performance of solutions for all-electric buildings (e.g., cold climate heat pumps, geothermal, etc.);
    • Research, development, and demonstration for hard-to-electrify buildings (e.g., on district steam, steam-heated, hydronic distribution) and advance scalable solutions and potential cost reductions (e.g., community geothermal, industrialized fabric/modular, virtual tools);
    • De-risking demonstrations to help critical customer groups who may lack access to resources and information (e.g., coops/condos); and
    • Approaches to reducing embodied carbon (e.g., new tech to reduce GHG emissions from materials/construction/transportation).

The American Council for an Energy-Efficient Economy published a paper that raises issues with air source heat pumps:  Field Assessment of Cold Climate Air Source Heat Pumps.  The 2016 report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps (ccASHPs ) were directly compared to propane and heating oil furnaces.  The study found these systems have the greatest potential for adoption in cold-climate regions where natural gas is not available for space heating; ccASHPs can offset the use of more expensive delivered fuels, and for homes with electric resistance heat, can result in a significant reduction in electrical use; that it is feasible for a utility energy efficiency program to receive credit for the energy savings achieved from ccASHPs through the reduction in fuel oil and propane;  and 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.  These conclusions are not compatible with the CLCPA targets.

In addition to the feasibility of wide-spread use in New York there is another issue.  I did a simple case study that illustrates my concern that wide-spread implementation of air source heat pumps coupled with increased use of renewables will be difficult.  In my analysis the meteorological conditions on New Year’s Eve 2018 show that the proposed Horseshoe solar facility with a nameplate capacity of 180 MW and a wind farm with a nameplate capacity of 100 MW would have been just able to cover the conversion of 2,737 homes to air source heat pumps.  However, energy storage capable of at least 372 MW-hr also has to be available somewhere.  There already are 47,000 homes using electricity and another 15,000 homes that are supposed to be cost-effective candidates for conversion just in two neighboring counties to the facility.  Most importantly, this is just one component of residential electricity load which is one component of total load.

The strategies proposed by this Advisory Panel are appropriate but the details should make it clear that a similar study in New York on the latest air source heat pumps is required.  That should be coupled with an assessment of the renewable energy resources.  It is not clear to me that it is possible to meet the multi-day winter doldrum period while relying on wind and solar.  Analysis of the data shows that no amount of over-building solves this problem.  Extraordinary amounts of storage are needed.  In order to determine just how much of energy storage will be required much better estimates of the load expected for electrifying homes and transportation are needed.

The final scope “Resilience and climate adaptation strategies for all-electric building, hazard mitigation planning and building retrofits” had four strategies.

• • • Supporting/coordinating improved resiliency solutions for all-electric building & resilient spaces for vulnerable pops.;
    • Grid and transmission resilience and independence;
    • Electrification paired with supplemental heating sources;
    • Improving building stock to withstand the impacts of climate change.

Resiliency is a buzz word employed to suggest that these policies will be improvements to systems so that they can better recover from difficult events.  What are the resiliency solutions for all-electric buildings when there is an ice storm?  According to Wikipedia (https://en.wikipedia.org/wiki/January_1998_North_American_ice_storm): “The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern Quebec, New Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months.  The only way those people survived is because they had alternatives to electricity.  When electricity is the only option available then what?

Conclusion

I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study.  It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar.  The only way this might work will require extraordinary amounts of energy storage, wind, and solar development.  When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.

From what I have heard the consensus opinion on the advisory panels is that air source heat pumps are an unqualified solution to residential heating.  The Minnesota field study suggests otherwise.  It would be appropriate for the panel to include a strategy for New York to replicate that study to prove that this solution will work here. In addition, a strategy to assess the potential impacts to society when the inevitable next severe ice storm occurs should be included.

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Energy-Intensive and Trade-Exposed Industries Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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 have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  Each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

Comments

I am not sure what to make of this panel’s charge.   Industrial sectors within EITE panel scope include manufacturing, mining, and construction and only total ~7% of State emissions.  The types of companies included in these sectors are vastly different so will likely require many different technologies to reduce emissions.  They also compete not only with similar companies within New York but also with companies outside the state and country.  Energy costs for any company in New York will surely increase as the decarbonization of the energy industry ratchets down emissions, they are being asked to also decrease their emissions with immature and potentially infeasible technologies, and they have to compete with companies unfettered by those constraints.  The panel has a Sisyphean task trying to offer any viable strategy.

The Panel has proposed 12 strategies in six topics.

The first scope topic is “Provide financial incentives and technical assistance for the decarbonization of the EITE sectors”.  It proposes four strategies:

• • • Provide technical assistance to help identify economically viable decarbonization pathways and to provide comprehensive energy management planning;
    • Provide financial incentives for decarbonization projects;
    • Refer economic assistance recipients to resources that will result in lower-emitting projects; and
    • Leverage low-cost hydropower to provide support for industry

Clearly if the State wants reductions from this sector it will need to provide assistance but there is no guarantee that there are solutions available for the challenge.  The backup is payments to try to reduce costs.  It is not clear where this money is going to come from given that every other strategy from every other panel also needs funding.

The panel proposes a strategy to “Create incentives for business to capitalize on low-carbon economy opportunities” that will create preferential standards for the public procurement of low-carbon building materials.  If a preferential standard is needed to drive the use of low-carbon building materials it means that alternative is more expensive.  That makes it a hidden tax of the program and another instance of increased costs that someone will have to pay.

The third scope topic “Identify and support technological innovations to enable deep industrial decarbonization” proposes four strategies:

• • • Develop a comprehensive Innovation Roadmap to address knowledge gaps and to guide key priorities for deep decarbonization investment in the areas of carbon-tech, low-carbon fuels, and carbon removal;
    • R&D funding for early stage decarbonization technologies;
    • Demonstration pilot funding for high impact solutions in coordination with private market; and
    • Identify potential for innovation clusters to leverage supply chains and infrastructure for novel solutions

These are all necessary strategies.  However, it is not clear how the panel will integrate them into recommendations for the Climate Action Council.  At some point the Council will need to recommend specific plans to achieve specific reductions to meet the CLCPA targets and these strategies only can offer the hope that someday, something will be available to meet some unspecified reduction.

There is the obligatory strategy for workforce development training that will provide workforce development on existing and new innovative emission reduction technologies that affect EITE industries.  This presumes that there actually be solutions that reduce emissions that keep New York manufacturing, mining, and construction competitive.

There is a strategy to “Increase the available data on industrial GHG emissions to help prioritize efforts and monitor progress” which would require additional industrial facilities to report their GHG emissions.  This should be limited only to companies that actually produce GHG emissions.  Any company that runs a generator should only be required to provide fuel use information.

The final strategy is to “provide economic incentives to grow the green economy” by leveraging “the State’s climate policies to develop an in-state supply chain of green economy companies by engaging in business development discussions and offering incentives through programs such as NYSTAR, NY Ventures and Excelsior Tax Credits”.  Again, this means more and more competing for funds from as yet unidentified sources.

Conclusion

As part of a CLCPA mandate to evaluate the impact to energy-intensive and trade-exposed industries, this panel has gone through the motions attempting to address concerns that are likely irreconcilable.  In today’s global economy New York’s industrial sector has to compete not only within this country but everywhere else too. The inevitable extra costs of energy will make production more expensive and less competitive.  The requirements to make GHG reductions in their industrial processes reduces competitiveness further.

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  In particular, this post is my reaction to the Transportation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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 have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  In brief, each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

General Comments

My impression of these transportation strategies is that there is a dis-connect between their goals and reality.  Reality is that there are on the order of 9.4 million vehicles registered in New York State with 1.9 million in New York City.  According to the ChargeNY website on 12/2/2020 there were 58,856 electric vehicles or 0.6% of the total and more than half of those are plug in hybrid electric vehicles and supporting their future use is just more fossil fuel infrastructure so they will have to be banned.  One hundred years ago there was a choice between electrified public transit and personal automobiles and by 1920 the interurban and trolley network that covered much of the state was already in decline because of the convenience of personal transport.  I find it hard to imagine that the majority of people would be willing to make the sacrifice of giving up their car.

Strategy Comments

The first strategy “Transportation Electrification” proposes to adopt regulatory approaches and supporting policies to increase the sale of medium and heavy-duty zero emission vehicles to 30% by 2030 and the sale of light-duty zero emission vehicles to 100% by 2035, and require greater use of zero emission non-road vehicles.  This strategy is mostly wishful thinking.  The fact is that zero emission vehicles are not available with all the capabilities as currently available vehicles.  For example, the minivan offers enough room for all the kids and baggage can be used for hauling pretty big items.  It can be used to go 250 miles in any weather without the need for a long stop to re-charge.  Without an equivalent vehicle Christmas trips to the grandparents are a much more complicated endeavor.  Another example of a transportation element not addressed yet is recreational vehicles.  I own a motor coach, use it often and my experience suggests that an electrification mandate will kill the industry in NY.

The rationale for this strategy claims that zero emission vehicles save consumers money spent on fuels and maintenance neglects total costs.  Many people cannot afford new vehicles and there is a very limited used EV market.  Many people worry about the cost of replacement batteries for used cars.  The head of Toyota raised the issues of the energy loss inside the electric vehicle value chain and the depreciated costs of developing a massive electric vehicle support infrastructure for ten million vehicles.  I would add that the hidden environmental costs of the rare earth elements and other metals needed for electrification should also be addressed.  The car battery in each automobile weighs 1,000 pounds and fabrication requires digging up, moving and processing 250 tons of earth somewhere else – this CLCPA implementation mandate is going to cause massive environmental impact leakage.

The Clean Fuels strategy proposes to “Adopt a market-based approach and supporting policies to increase the availability and affordability of clean transportation fuels (renewable biofuels, green hydrogen, electricity) in New York”.  This strategy should address the environmental impacts of biofuels.    Hydrogen is nice in theory but because it has to be compressed or liquified for storage is impractical in reality.  Electrification has serious border issues if New York or even the Transportation Climate Initiative region continue to go down this path without the rest of continent following suit.

There are two components to the Public Transportation strategy:

• • • Identify policies and programs that would double the availability/accessibility of upstate and downstate suburban public transportation services statewide by 2035 and
    • Identify policies and programs to support system reliability/network expansion projects identified by MTA in their twenty-year needs study.

As noted previously, there used to be an extensive public transit system in the state that died out where public needs could not be met.  The strategy claims there is “unparalleled support for public transportation based on NY being the least energy per capita for transportation purposes” overlooks the fact that is almost entirely due to New York City.  Even if you manage to double availability and accessibility in New York City that is an easy task relative to the rest of the state.  Current land use patterns preclude substantial increases in public transit services outside of metropolitan areas.  Consider that, for example, using public transit from the New York State Energy Research & Development Authority office building to the State Capitol is a 9.7 mile, 14 minute drive or a 46 minute bus ride that includes a one mile walk.  Of course, that does not include waiting time for the bus.  Rather than a vague plan with aspirational goals the strategy clearly needs to be in sufficient detail to explain what would be required to make this actually work.

The final strategy, Smart Growth and Transportation System Efficiency, also has two components:

• • • Transportation-Oriented Development—Align roadway, residential and commercial development to be proximate and accessible to public transportation and consider holistic GHG emissions in smart growth developments;
    • Low-and Zero-Carbon Transportation Modes—Expand access to low-or zero-carbon transportation modes (biking, walking, carpooling) for first mile/last mile connections to transit and destinations.

While there certainly are areas where transit-oriented development can be done, to think it has widespread applicability outside the New York City metropolitan area is completely wishful thinking.  Advocates for this just have to admit that current land use patterns make this strategy useless.  The transportation modes component is another great theory proposed by someone who would not have to deal with impracticalities for anyone in rural areas and most suburban areas.  It boils down to the reality that anyone who has a remote car starter to deal with the inconvenience of a cold car is not going to use public transit in the winter.

Conclusion

I think that upon closer examination all of these strategies have flaws that make them unacceptable for the vast majority of people outside the echo chamber of transportation-related climate solutions ideology.  The only way these strategies can get started much less implemented is if the public does not catch on.  Experience shows that when the effects of these policies on transportation costs and personal choices become known to the general public that a backlash will occur.

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.  It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  However, no one has shown what effect this law could actually have on global temperatures.  This post provides that information.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels, I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  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.

Analysis

For this analysis I simply adapted the calculations in Analysis of US and State-By-State Carbon Dioxide Emissions and Potential “Savings” In Future Global Temperature and Global Sea Level Rise[1]  to estimate the potential effect.  This analysis of U.S. and state by state carbon dioxide 2010 emissions relative to global emissions quantifies the relative numbers and the potential “savings” in future global temperature and global sea level rise.   These estimates are based on MAGICC: Model for the Assessment of Greenhouse-gas Induced Climate Change so they represent projected changes based on the Intergovernmental Panel on Climate Change estimates.  All I did in my calculation was to pro-rate the United States impacts by the ratio of different New York inventory emissions divided by United States emissions to determine the effects of a complete cessation of all New York’s emissions.

There is a fundamental assumption in this approach.  The emissions in the primary reference are based on Intergovernmental Panel on Climate Change (IPCC) methodologies.  In order for these estimates to be correct the emission inventories have to be calculated the same way.  New York’s CLCPA inventory only followed IPCC approaches when the results comported with the political narrative and differ when more “appropriate” numbers can be derived.  The largest issue in this regard is that the CLCPA inventory includes upstream emissions from the extraction and transport of fossil fuels so their inventories include emissions from outside the state.  Consequently, you cannot directly compare New York’s inventory to other jurisdictions because of the double counting of these emissions.  The CLCPA inventory also uses a global warming potential GWP) of 20 years whereas everyone else uses GWP of 100 years.  The CLCPA regulation does provide the GWP-100 emissions for comparison purposes and in the response to my comment about the upstream component I was assured that somebody else would address that problem some day some place.  In the meantime, we cannot directly compare inventories.

Next best thing is to provide all the inventory results for your information.  The official CLCPA 1990 emission inventory was recently promulgated in New York’s Part 496 regulation.  As shown in the CCPA Part 496 Potential “Savings” in Future Global Temperature I estimated the benefits of getting 1990 emissions to zero for four inventories.  I evaluated the CLCPA Part 496 inventories for all the greenhouse gases (CO2, CH4, N2O, PFCs, HFCs and SF6) included in the law and just CO2.  In order to compare the potential effects the way the rest of the world prepares inventories, I evaluated the CO2 and GHG inventories from Table S-1 in the last New York State Energy Research and Development Authority inventory.

Results

The table shows that for the CLCPA Part 496 inventories there would be a reduction, or a “savings,” of between approximately 0.0097°C and 0.0081°C by the year 2100.  To give you an idea of how small these temperature changes are consider changes with elevation and latitude.  Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000-foot increase in elevation above sea level.  The projected temperature difference for all the greenhouse gases is the same as a 39-inch change or 32 inches if only the CO2 emissions are considered.  The general rule is that temperature changes three (3) degrees Fahrenheit for every 300-mile change in latitude at an elevation of sea level.  The projected temperature change is the same as a change in latitude of less than a mile.  The impacts calculated using inventories the way the rest of the world calculates them are even less.

The CLCPA should also be considered relative to the rest of the world.  According to the China Electricity Council, about 29.9 gigawatts of new coal power capacity was added in 2019 and a further 46 GW of coal-fired power plants are under construction.  If you assume that the new coal plants are super-critical units with an efficiency of 44% and have a capacity factor of 80%, the reductions provided by the CLCPA greenhouse gas inventory will be replaced by the added 2019 Chinese capacity in less than two years or four and a half years if the 2019 capacity and the units under construction are combined.  Recall that the CLCPA inventory is incompatible with IPCC methods.  When using the compatible NYSERDA inventories New York’s impact on global warming will be replaced by the added 2019 Chinese capacity in less than on year or two and a half years if the 2019 capacity and the units under construction are combined.

Conclusion

There is an obvious reason that New York has never provided an estimate of the impact of any of its greenhouse gas reduction initiatives on global warming.  The impacts are simply too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions.  In the context of global emissions New York’s efforts will be subsumed quickly by other countries that are morally obligated to provide the tangible benefits of affordable abundant energy to their citizens.  At this time those benefits are only possible using fossil fuels.  Until such time that there is a lower cost alternative to fossil fuels for those countries it is immoral to expect them to forgo those benefits because of marginal climate impacts as aptly explained by Dr. Bjorn Lomborg in his book “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet”.