Climate Leadership and Community Protection Act 1990 Emissions Inventory

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  On August 14 New York State Department of Environmental Conservation (DEC) Commissioner Basil Seggos released proposed regulations to reduce greenhouse gas emission statewide and implement the CLCPA.  A key part of this regulation is defining the baseline 1990 emission inventory and this is a quick initial post about the inventory.

Up until this time the “official” New York greenhouse gas emission inventory was prepared by the New York State Energy Research and Development Authority (NYSERDA)  According to the latest edition of the NYSERDA GHG emission inventory Table S-2 New York State GHG Emissions 1990–2016 the New York State 1990 GHG emissions were 236.19 MMtCO2e.

The CLCPA mandates specific requirements for the 1990 emission inventory that I am positive no legislator who voted for the law understood.  The most impactful requirement was to specify that the global warming potential (GWP) be calculated over a 20-year time horizon.  The following section of the Intergovernmental Panel on Climate Change (IPCC) describes time horizons and the GWP.

Reference: Myhre, G., D. Shindell, F.-M. Bréon, W. Collins, J. Fuglestvedt, J. Huang, D. Koch, J.-F. Lamarque, D. Lee, B. Mendoza, T. Nakajima, A. Robock, G. Stephens, T. Takemura and H. Zhang, 2013: Anthropogenic and Natural Radiative Forc­ing. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

“The GWP has become the default metric for transferring emissions of different gases to a common scale; often called ‘CO2 equivalent emis­sions’ (e.g., Shine, 2009). It has usually been integrated over 20, 100 or 500 years consistent with Houghton et al. (1990). Note, however that Houghton et al. presented these time horizons as ‘candidates for discussion [that] should not be considered as having any special sig­nificance’. The GWP for a time horizon of 100 years was later adopted as a metric to implement the multi-gas approach embedded in the United Nations Framework Convention on Climate Change (UNFCCC) and made operational in the 1997 Kyoto Protocol. The choice of time horizon has a strong effect on the GWP values — and thus also on the calculated contributions of CO2 equivalent emissions by component, sector or nation. There is no scientific argument for selecting 100 years compared with other choices (Fuglestvedt et al., 2003; Shine, 2009). The choice of time horizon is a value judgement because it depends on the relative weight assigned to effects at different times. Other important choices include the background atmosphere on which the GWP calculations are superimposed, and the way indirect effects and feedbacks are included (see Section 8.7.1.4).”

According to the draft regulation released on August 14, § 496.4 Statewide Emission Limits (a) For the purposes of this Part, the estimated level of statewide greenhouse gas emissions in 1990 is 401.38 million metric tons of carbon dioxide equivalent, using a GWP20 as provided in the IPCC assessment report.

More to come on this topic.

Climate Leadership and Community Protection Act Implementation Risk Management

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (Climate Act) and this summer the implementation process is in full swing.  This post addresses risk management concerns about the implementation process.

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 effects of energy policies related to doing “something” about climate change.  I have written a series of posts on the feasibility, implications and consequences of this aspect of the Climate Act.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Climate Act establishes a Climate Action Council at §75-0103 that will develop a scoping plan to implement the requirements of the law.  The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act.  The current emphasis is implementation of plans to meet the requirement to reduce GHG emissions from electricity production by 70% in 2030 and eliminate them altogether by 2040.  In my opinion, the proponents of the Climate Act believe that meeting the aspirational goal of a carbon-free electric system by 2040 is simply a matter of political will.  I am not nearly as optimistic because every time I look at any aspect of that transition I find unexpected complications, unintended consequences, and ever higher costs.

The basis of this article is work by the Risk Monger, a blog “meant to challenge simplistic solutions to hard problems on environmental-health risks”. The author of the blog, David Zaruk, is an EU risk and science communications specialist since 2000, active in EU policy events and science in society questions of the use of the Precautionary Principle. He is a professor at Odisee University College where he lectures on Communications, Marketing, EU Lobbying and PR. In my opinion, he clearly explains the complexities of risk management and I recommend his work highly.  I found his work apropos to the Climate Act implementation process.

Precautionary Principle

The Precautionary Principle is a strategy to cope with possible risks where scientific understanding is incomplete.  Unfortunately, many rely on this idea that to be safe we have to eliminate all risks as a precaution.  Zaruk explains that the problem is that policy-makers and politicians have confused this uncertainty management tool with risk management.  The conclusion of a recent series of posts on the failures of risk management of the COVID-19 response, while fascinating on its own, also provides a cautionary tale relative to New York’s energy policy and implementation of the Climate Act.

New York’s Climate Act is generally driven by the precautionary principle approach.  New York is trying to remove the risks of climate change impacts despite our lack of complete knowledge about climate variations.  For example, the Regulatory Impact Statement (RIS) for proposed revisions to the Part 242 CO2 Budget Trading Program states that “Overwhelming scientific evidence confirms that a warming climate poses a serious threat to the environmental resources and public health of New York State”.  After pointing out that anthropogenic GHG emissions have increased and that ambient levels of CO2 are “higher than at any point in the past 800,000 years”, the RIS goes on to say “The large and persuasive body of research demonstrates through unequivocal evidence that the Earth’s lower atmosphere, oceans, and land surfaces are warming; sea level is rising; and snow cover, mountain glaciers, and Greenland and Antarctic ice sheets are shrinking”.  In order to confront those risks the Climate Act focuses on greenhouse gas emission reductions but does not include a process to ensure that their cure is not worse than the alleged disease.

Risk Monger’s Risk Management Approach

Zaruk outlines seven steps of risk management:

        1. Scenario Building – all options must be mapped out;
        2. Risk Assessment – collect and refine data and evidence;
        3. Risk Analysis – weigh data against benefits and consequences;
        4. Apply Risk Reduction Measures – identify vulnerable groups and reduce exposures on them;
        5. Risk Communication (Empowerment) – inform public of risks and how to protect themselves;
        6. As Low as Reasonably Achievable (ALARA) – reduce exposures to a reasonable level vis-à-vis social well-being; and
        7. Refine ALARA: continuous exposure reductions – continually lower exposure levels so as to ensure benefits at higher safety levels

If these steps fail, apply the precautionary principle – As benefits and social goods will be lost, this is the last step and should only be temporary

These seven steps are the basis for twelve strategies he proposes as an alternative policy approach for rational discussion.  He believes that using these risk management strategies would have provided a better solution to the COVID-19 crisis and I believe that it would be appropriate to consider his alternative with respect to the Climate Act.

Zaruk argues that the docilian mindset, demanding a world with zero-risk, helped drive a solution that caused economic and social collapse in Western economies trying to reduce the effect of the virus outbreak.  Unfortunately, as he points out, there are influential forces lobbying for even more precaution.  His strategies for better risk management are entirely appropriate to consider with respect to the transition to an energy system that eliminates the use of fossil fuels because of the risks to affordability and reliability.  In the next section I address his strategies in this context.

Risk Management Strategies

The Risk-Monger’s first strategy is to place precaution properly in risk management.  The Climate Act is taking the precautionary step to ban the use of fossil fuels for electric generation by 2040.  Zaruk argues that stopping an activity can have significant consequences so it is more appropriate to implement this kind of stringent policy at the end of the process when “our capacity to prevent harm has failed or the value of the benefits could not be justified”.  The fact is that there are undeniable benefits to fossil fuels and alternative technologies are not well developed which could cause reliability problems and increase costs.  The Climate Act targets put the “cart before the horse” by not evaluating the potential consequences of the alternatives before setting the targets.

Two other strategies are related.  He argues that setting up government risk management units to provide independent oversight and foresight about emerging issues has tremendous value and proposes to have an independent risk assessment process outside of the political process that can present their findings to the public without interference.  Zaruk notes that “While Churchill’s saying: ‘Scientists should be kept on tap, but not on top’ stands as a truism of modern democracies and accountability, it does not mean that political leaders can be allowed to try to hide facts or deny evidence by pressuring their advisers”.  Unfortunately, this is directly opposite of the actions of the Cuomo Administration.  In the summer of 2019 a group of retired Department of Public Service employees submitted a letter that stated “Until the current administration, Governors have generally respected the plain language of the Public Service Law (PSL), which … safeguards the mission of the DPS to serve not political interests but the public interest.”  Based on my private discussions with staff at different agencies, the Governor’s minions micro-manage every decision based on political ramifications. This mindset permeates the state effectively eliminating any criticisms by industry in general and the utility industry in particular.

Zaruk recommends a strategy to promote scenario building in the governance process:

“Contrary to common practice in policymaking today, it is not a sign of weakness to have a Plan B or consider alternative eventualities. Examining a multitude of scenarios allows a risk manager to prepare for any situation, avoid black swans and limit unforeseen consequences. In most cases it is common sense: you better reduce your exposure to risks if you can imagine a wide range of scenarios and likelihoods and suitably prepare for them. “

The Climate Act mandates a scoping plan to implement an energy transition to meet the aspirational goals to reduce GHG emissions.  To me a scoping plan implies that there is no question about feasibility and the plan is simply a matter of picking the components to assemble the plan.  I have my doubts about the feasibility of the Climate Act targets.  There is no question in my mind that in order to prepare for any situation, avoid black swans and limit unforeseen consequences that outreach to many disciplines is necessary.  For example, as a meteorologist, I have spent some time trying to determine renewable resource availability for long duration periods of low renewable resources (most notably a period of calm winds in the winter when solar is at a minimum).  One scenario that I think is necessary is to look short-term at solar resource availability using an existing representative data set.  There has been no indication that state planners are considering the use of that resource.  My expectation is that the scoping plan will develop a narrow set of options that will allegedly meet the targets of the Climate Act but will sacrifice current reliability standards that reflect many different scenarios.

There are two recommended strategies directly at odds with the Climate Act implementation process: ensure expertise lies at the foundation of risk management and bring in different sources of expertise.  Zaruk points out that the European Union had an independent chief scientific advisor but that when there were results that were not politically correct, activist lobbying led to the abolishment of the position.  The position offered the opportunity to double-check policies to make sure that it represents science in the public interest and not just science that represents the most vocal proponents.  He explains that “Risk management needs to be based on the best evidence, not the strongest political ideology but as precaution serves as an easy, expedient, blameless solution, the battle to undo its dominance will be challenging”.  Such a function would be useful in New York but in the current Administration is clearly a non-starter.

He goes on to explain the need for different sources of expertise by noting that “limiting your advice pool is how mistakes are made”.    He states:

“I can’t count how many times in 2020 I have heard people talk about “the” science as if you simply needed to put a question into a machine and the answer would come out. Science is complex, often contested and defines itself by a method of challenging its theories and paradigms. Only consensus-loving neophytes (and a Swedish teenager) would talk about “the” science as if it meant something certain. Part of the risk management process is to plan out scenarios based on the best available scientific voices at that time.”

The Climate Action Council mandated to develop the scoping plan to implement the Climate Act ignores the importance of expertise.  The Council has 22 voting members: 12 political appointees who head various agencies and the rest non-agency experts: two appointed by the governor, three each appointed by majority leaders of the Assembly and Senate and one each appointed by the minority leaders of the Assembly and Senate.  The ten at large members shall “include at all times individuals with expertise in issues relating to climate change mitigation and/or adaptation, such as environmental justice, labor, public health and regulated industries”. In my opinion, it is lunacy that the Council that is supposed to determine how the future energy system of the state is supposed to operate does not specify energy system expertise as a criterion.  The bottom line is that none of these 22 people have relevant expertise for choosing options for a reliable energy system.

The only hope for New York’s future energy system is the requirement that the “The council shall convene advisory panels requiring special expertise and, at a minimum, shall establish advisory panels on transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, and agriculture and forestry”. The advisory panels are charged “to provide recommendations to the council on specific topics, in its preparation of the scoping plan, and interim updates to the scoping plan, and in fulfilling the council’s ongoing duties”.  My concern is that it is not clear how any of these panels can provide recommendations that are inconsistent with the agendas of the Council that is weighed so heavily for those who believe that the meeting the goals is simply a matter of political will.  The plan for the Climate Act is directly at odds with these risk management expertise strategies.

Zaruk states that the key to risk management is that we should not be aiming for safe, but rather safer.  He defines this step: “As Low as Reasonably Achievable (ALARA)” and includes a strategy to use ALARA as a return to risk realism.  He explains:

“This zero-risk mindset, this demand for total safety, is built on a false objective. We should not be aiming for safe, but rather safer. But what level of safer is safe enough? Like any situation with uncertainty, it depends on the circumstances, needs and realities. If you are dying of thirst in a desert, what level of water purity will you accept? This is always a question of what is reasonably achievable. The principle goal for risk managers is to reduce exposure to hazards (risks) to as low as reasonably achievable”.

He explains what goes in ALARA:

“Some say it is simply a cost-benefit analysis (and then they would add that you cannot put a price on a human life). Every risk is different (to everyone) and the variables affecting our reasoning range from resources, available equivalent alternatives, time to undesired consequences, public perception of the risk, traditional practices, accountability, trust relations and the public willingness to change certain lifestyle habits.”

My primary concern with the Climate Act is the risk to electric system reliability that will occur when the system has to rely on intermittent and diffuse renewable energy.  There is a related principle particularly applicable to the Climate Act.  The Pareto principle states that, for many events, roughly 80% of the effects come from 20% of the causes. The primary worry here, in the absence of using an ALARA strategy, is that 80% of the risks to the electric system will occur as the amount of fossil fuel use goes below 20% of the total.  As noted before, I expect the primary problem will be the need for dispatchable electric power when renewable resources are low (think a calm period in the winter when solar resources are weak).  The great advantage of fossil-fired power plants is dispatchability and the risks of losing this firm capacity must be evaluated.

He concludes this strategy as follows:

 “There is no one rule guiding risk management as ALARA. Each situation looks at what is reasonable and what is achievable. Dreamers and idealists want a world that is simply unachievable; pragmatists could probably achieve more. Continuous improvement is a key element to ALARA. It is not just to lower the risk to what is reasonably achievable, but to then push that exposure reduction even lower … continuously in an iterative, reasonable process.”

Zaruk also recommends some long-term strategies that are not directly applicable to Climate Act implementation but would serve New York’s policy process well.  They all relate to public education and I think the primary target should be politicians and policy making bureaucrats.  He suggests that we all need to accept that risk management is not about assuring 100% safe and that means we have to abandon the precautionary logic.  In order to manage the expertise necessary for risk assessment we need to develop a viable means for public consultation.  With that in place then we can create a community trust/communication mechanism.  All this can promote a risk resilient population.

Conclusion

I spend a lot of time writing about the oncoming train wreck of New York’s Climate Act.  I wrote this hoping someone, somewhere with some influence might pick up on the need to step back and assess the risks of trying to meet the aspirational goals.  Zaruk has much more influence but is frustrated by the fact that the precautionary principle is driving so much current policy.  His conclusion, after writing 15 articles on the response to COVID-19, is what I expect to be the likely outcome of the Climate Act on its present trajectory:

“I do not have the millions of euros of foundation-fed interests, the guru-led tribal passion or activist-driven fear-making machinery of the privileged zealots. What that crap-cash has bought them over the past two decades (relying on a misplaced precautionary policy tool) is expedience, irresponsibility and catastrophic risk management failure. And now as these relentless fundamentalists line up again at the public trough, we are facing economic collapse, famine and their insistence on even more precaution.”

Climate Leadership and Community Protection Act Value of Carbon

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (Climate Act) and this summer the implementation process is in full swing.  I have written a series of posts on the feasibility, implications and consequences of this aspect of the law based on evaluation of data, but those posts are generally technically oriented.  A key component in this process is the Value of Carbon or Social Cost of Carbon which is supposed to place a price on emissions of greenhouse gases (GHG) relative to climate change impacts  Because the concept is complicated and important for the implementation and justification of the Climate Act and I have prepared this is a non-technical summary to explain to those outside the bubble of this process what this means.

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 effects of energy policies related to 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

The Climate Act establishes a Climate Action Council at §75-0103 that will develop a scoping plan to implement the requirements of the law.  The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act.  The current emphasis is implementation of plans to meet the requirement to reduce GHG emissions from electricity production by 70% in 2030 and eliminate them altogether by 2040. 

This post addresses section § 75-0113 in the law.  In that section the Climate Act explicitly mandates how the value of carbon will be determined:

  1. No later than one year after the effective date of this article, the department, in consultation with the New York state energy research and development authority, shall establish a social cost of carbon for use by state agencies, expressed in terms of dollars per ton of carbon dioxide equivalent.
  2. The social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions. As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero.
  3. In developing the social cost of carbon, the department shall consider prior or existing estimates of the social cost of carbon issued or adopted by the federal government, appropriate international bodies, or other appropriate and reputable scientific organizations.

Value of Carbon

The law states that “The social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions”. The Social Cost of Carbon (SCC) is the present-day value of projected future net damages from emitting a ton of CO2 today.  The idea is that New York will calculate the dollar-value of the Climate Act’s effect on climate change due to changes in greenhouse gas emissions. 

What that means to the public is when the costs of the control strategies proposed to meet the Climate Act targets are announced they will be compared to the benefits calculated using this metric, and, presumably will show that the benefits out-weigh the costs.  For example, a recent report contains this paragraph:

“NYSERDA estimates that the proposed Tier 1 procurements, as set out in Section II.c.1 below, – from 2021 to 2026 – would lead to a levelized impact on electricity bills of less than 0.5% (or $0.35 per month for the typical residential customer). Taking into account the value of the avoided carbon emissions, these procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects.”

The net benefit of $7.7 billion is certainly impressive, however, it is important to understand how the value was calculated in order to determine whether the alleged benefits are valid.  In the following I will interpret specific statements in the Climate Act.

According to the Climate Act: “As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero”.  The department referred to is the New York State Department of Environmental Conservation.

The first SCC basis possibility would be “based on marginal GHG abatement costs”. In this application, the marginal cost measures the cost to reduce a ton of greenhouse gas.  Presumably the goal is to develop a Marginal Abatement Cost Curve which is “a succinct and straightforward tool for presenting carbon emissions abatement options relative to a baseline (typically a business-as-usual pathway)”. This curve “permits an easy to read visualization of various mitigation options or measures organized by a single, understandable metric: economic cost of emissions abatement”.  For each control option, a block with width equal to the amount of potential reductions and height equal to marginal cost of the option is prepared.  An example, based on the widely cited 2007 McKinsey & Company study and reproduced for the King County Strategic Climate Action Plan, is shown below combining various measures from different sectors.  Note that if there are sufficient savings from the energy efficiency measure, consider residential lighting in this example, then those benefits out-weigh the costs and the marginal abatement cost is negative.

The second Climate Act carbon value alternative is “the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere and that refers to the SCC.

In order to estimate the SCC impact of today’s emissions it is necessary to estimate total CO2 emissions, model the purported impacts of those emissions and then assess the global economic damage from those impacts.  The future projected global economic damage is then converted to present value. Finally, the future damage is allocated to present day emissions on a per ton basis to get the SCC value.  The SCC is already used in New York to, for example, determine the value of “zero emission credits” which is a subsidy to generating nuclear facilities.

There are value-judgement choices in each step of the SCC calculation process.  As shown below different choices in only two of the many parameters lead to an Obama-era SCC value of $50 in 2020 vs. the current SCC value of $7 in 2020.  Needless to say the difference of over seven times in this value has an impact on cost benefit calculations.

To this point New York has used the Obama Administration’s SCC values developed by the Interagency Working Group on the Social Cost of Carbon (IWG).  In 2017, President Trump signed Executive Order 13783 which, among other actions, disbanded the IWG and stated that the estimates generated by the Interagency Working Group were not representative of government policy.  Currently Federal projects use SCC estimates based on the same approach as the IWG that differ in two aspects: the only damages that were considered were those in the United States and different values were used to convert to present costs. 

Figure 1: Prior and Current Federal Estimates of the Social Cost of Carbon Dioxide in 2018 U.S. Dollars, 2020-2050 from the recent GAO report show that changing just those two variables results in very different damage estimates.  As shown in the table below, at the common 3% discount rate, the prior federal estimate and the one currently used in New York was $50 but the current federal estimate is only $7. 

Prior and Current Federal Estimates of the Social Cost of Carbon, per Metric Ton, at a 3 Percent Discount Rate in 2018 U.S. Dollars

 
Year of emissionsPrior estimates (based on global climate change damages)Current estimates (based on domestic climate change damages)
2020$50$7
2030$60$8
2040$72$9
2050$82$11

Source: GAO analysis of data from the Interagency Working Group on Social Cost of Greenhouse Gases, EPA, and the United States Gross Domestic Product Price Index from the U.S. Department of Commerce, Bureau of Economic Analysis. | GAO-20-254

Initially, the social cost of carbon sounds like authoritative science.  However, the differences boil down to the value judgements used to choose the parameters used to determine the benefits of the Climate Act.  The previously mentioned NYSERDA claim that one particular aspect of the plan would lead to a levelized impact on electricity bills of less than 0.5% (or $0.35 per month for the typical residential customer) sounds great. In their words, “taking into account the value of the avoided carbon emissions, these procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects”.  However, the electric bill cost is real, everyone is going to pay that and the social cost of carbon “benefit” value depends on the judgement of those developing the numbers.

Consider whether New York should address global impacts, nation-wide impacts, or for the sake of argument, just the benefits that would accrue to New Yorkers if their emissions are reduced.  There is no doubt that because there are global impacts that looking at global impacts should be considered but what value is that to a New Yorker already on the edge of energy poverty.  If the cost of energy goes up significantly, and other jurisdictions that tried to implement less ambitious GHG emissions reductions programs has seen significant increases, then those New Yorkers least able to afford energy increases will be hit hard.  Therefore, I think it is entirely appropriate to provide New Yorkers with benefits based on all three geographical coverages.

Another little recognized aspect of the SCC calculation methodology is that the costs are calculated far into the future.  Proponents argue that because most of the warming caused by carbon dioxide emissions persists for many years, changes in carbon dioxide emissions today may affect economic outcomes for centuries to come.  The GAO report notes: “To create a social cost of carbon estimate for emissions occurring in a given year, models use discounting to convert the projected monetized climate damages into a present value. This process involves reducing the damages in each future year by a percentage known as the discount rate”.   As the graphs show, a higher discount rate reduces future values to a greater degree than applying a lower discount rate. If we use a higher discount rate, then we are weighting today’s costs as more important than impacts hundreds of years in the future.  The emotional alternative is worded as leaving the world a better place for our grand-children by using a low discount rate.  Note that the Climate Act specifies using a discount rate of zero that will surely show very high social costs of carbon.  But remember that the impacts of climate change will become more evident much further in the future than our direct descendants so choosing a low discount rate that considers future impacts and current costs as equally significant not only means that our grandchildren will have to pay high prices now but won’t even see the benefits.

There is another aspect to paying now for potential damages far in the future.  The money spent today is not available to spend on projects that could alleviate future damages.  For example, if sea-level rise is a concern, then spending money today emulating the Dutch experience keeping the ocean out of their land would make more sense.  Similar arguments for many of the damages included due to climate change can also be made but are routinely ignored by proponents of a high SCC value.

Context

Finally, I want to point out that the SCC, as proposed for use in the Climate Act, has two basic flaws.  In general, there is no consideration of benefits of GHG emissions and, particular to our situation, it does not consider NY’s actions relative to the world’s actions.  The effect of the two items is related.

In most environmental impact assessments, a primary consideration is the direct consequence of the action.  In this case, if New York reduces its GHG emissions how will global warming be affected.  Prior to the passage of the Climate Act I calculated the potential change.  If the Climate Act were to stop emitting 218.1 million metric tons (1990 emissions) the projected global temperature rise would be reduced approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  In order to give you an idea of how small this temperature change 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 is the same as going down 27 inches.  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 going south two thirds of a mile. 

Another aspect of environmental impact assessment is a discussion of trade-offs.  However, the social cost of carbon does not consider any of the benefits of carbon dioxide.  The “CO2 fertilization effect” — the fact that rising emissions are making plants grow better, is not considered.  The satellite data show that “there has been roughly a 14 per cent increase in the amount of green vegetation on the planet since 1982, that this has happened in all ecosystems, but especially in arid tropical areas, and that it is in large part due to man-made carbon dioxide emissions”.  More importantly, Alex Epstein in the Moral Case for Fossil Fuels makes a compelling case for using fossil fuels use because: “the cheap, plentiful, reliable energy we get from fossil fuels and other forms of cheap, plentiful, reliable energy combined with human ingenuity, gives us the ability to transform the world around us into a place that is far safer from any health hazards (man-made or natural), far safer from any climate change (man-made or natural), and far richer in resources now and in the future.”

The International Energy Agency claimed that world population without access to electricity fell below 1 billion in 2017.  In order to reduce that number further, improve access to more electricity, and reap the benefits of abundant, reliable of energy, developing countries are building fossil-fired power plants.  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%, all the reductions provided by the Climate Act will be replaced by the added 2019 Chinese capacity in just over three years or less than an year and a quarter if the 2019 capacity and the units under construction are combined. If construction of all coal plants elsewhere were included, then the time to subsume New York reductions would be even less.

Conclusion

Up until this point the State of New York has thus far relied on a single value of the SCC.  While that may be necessary for use in calculating credits for emissions reductions, elsewhere, and particularly in the case of claimed benefits relative to the costs of the program, it is more appropriate to consider a range of values because of the massive uncertainties associated with this metric. 

The  comments on the SCC prepared by Dr. Richard Tol in a Minnesota Public Utilities Commission hearing on that state’s use of the SCC provide a technical discussion of potential problems with the SCC. Dr. Tol is Professor of the Economics of Climate Change at Vrije Universiteit Amsterdam and a Professor of Economics at the University of Sussex and has direct experience estimating the social cost of carbon.  He concludes: “In sum, the causal chain from carbon dioxide emission to social cost of carbon is long, complex and contingent on human decisions that are at least partly unrelated to climate policy. The social cost of carbon is, at least in part, also the social cost of underinvestment in infectious disease, the social cost of institutional failure in coastal countries, and so on.”

According to the National Academies, the present value of damages reflects society’s willingness to trade value in the future for value today.  The Climate Act mandates that the carbon value consider a zero discount rate that means that value in the future equals value today.  However, the fact that New York’s potential emission reductions will be subsumed by increases elsewhere means that the valuation arguments are theoretical and that in practice New York reductions are only symbolic.

The calculation and use of the SCC is complicated and subject to mis-interpretation.  Such is the case with NYSERDA’s claim noted earlier that “these procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects”.  In response to my question about the calculation of lifetime benefits, Dr. Tol explained that the SCC should not be compared to lifetime savings or costs.  Therefore, the $7.7 billion net benefit claim is incorrect.

In conclusion, New Yorkers should be aware of the back story of the social cost of carbon benefits claimed to date for Climate Act projects when compared to the costs.  The costs to implement the Climate Act will be real changes to ratepayer bills.  The benefits claimed are based on numerous value judgements, ignoring world-wide emission increases that will subsume New York’s reductions, and, if lifetime benefits are claimed, are much higher than appropriate.  For all intents and purposes, today’s costs for the Climate Act will provide negligible benefits to those paying the bills.

NY Climate Act Implementation – Electric Generation De-Carbonization Pathways

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done.  On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law may suggest will be done.  This post analyzes the electric generation analysis approach.

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.

I did a post on the Pathways to Deep Decarbonization in New York State Presentation  that can be viewed on the video of the webinar.  The Pathways to Deep Decarbonization in New York State – Final Report  itself and two appendices: Appendix A: Methods and Data  and Appendix B: Literature Review of Economy-Wide Deep Decarbonization and Highly Renewable Energy Systems  were included in the meeting materials.  This post addresses electric generation in the final report and Appendix A.

E3 Modeling

The E3 analysis uses models to simulate which combinations of resources can be used to meet the Climate Act goals, how the transmission grid can provide those resources and the renewable capacity needed to maintain reliability.  I will address these three models below.

E3 used their PATHWAYS model to “create strategically designed scenarios for how the State can reach its 2030 and 2050 GHG goals. The model is built using ‘bottom-up’ data for all emissions produced and energy consumed within the State.   It identifies GHG reduction measures from transportation, buildings, industry, electricity, and other sectors, and captures interactions among measures to create a detailed picture of emissions reductions and costs through 2050”.  E3 notes “that as a ‘stock rollover’ model, PATHWAYS considers realistic timing of investments to replace appliances, vehicles, buildings, and other infrastructure. It pays special attention to the dynamics between electricity generation and new loads from transportation and buildings, as well as the role of low-carbon fuels such as advanced biofuels, hydrogen, and synthetic fuels”.

I believe there is a major problem with their “stock rollover” model.  As far as I can tell, it does not consider the readiness of the technology proposed.  The International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that notes:

“Without a major acceleration in clean energy innovation, net-zero emissions targets will not be achievable. The world has seen a proliferating number of pledges by numerous governments and companies to reach net-zero carbon dioxide (CO2) emissions in the coming decades as part of global efforts to meet long-term sustainability goals, such as the Paris Agreement on climate change. But there is a stark disconnect between these high-profile pledges and the current state of clean energy technology. While the technologies in use today can deliver a large amount of the emissions reductions called for by these goals, they are insufficient on their own to bring the world to net zero while ensuring energy systems remain secure – even with much stronger policies supporting them.”

I have shown that E3 ignored these limitations in its assessment of the technology needed to provide electricity when they claimed “Deep decarbonization in New York is feasible using existing technologies”.  That statement mis-characterizes the actual situation.  As IEA points out feasibility depends upon making all parts of the technological application process, what they call the value chain, commercially viable.  The fact is that for the E3 technologies proposed to address the winter peak problem, one or more aspects of commercial viability, availability limitations, or public perception make the E3 recommendations risky bets for future reliability and affordability.

In order to consider effects of the transmission grid on the de-carbonization effort, E3 used their RESOLVE model:

Our modeling approach also incorporates detailed electricity sector representation using E3’s RESOLVE model. RESOLVE is used to develop least-cost electricity generation portfolios that achieve New York’s policy goals, including 100% zero-emission electricity, while maintaining reliability.

For this study, RESOLVE was configured with six zones: two zones representing the upstate and downstate portions of the New York electricity system and four zones representing the external markets that interact with New York.

It is beyond the scope of my analysis to quantitatively determine whether this resolution is sufficient to represent the New York grid relative to the generation portfolios.  Qualitatively, however, the fact that New York City, which has specific transmission load constraints and a requirement for a minimum level of in-city generation, is lumped with Long Island suggests that this is a significant deficiency.

In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore. It is important that the solar and wind resources be evaluated based on geographically representative short-term data so that site-specific temporal effects can be included. E3 calculates the “effective load-carrying capability” which they define as the amount of “perfect capacity” that could be replaced or avoided with wind, solar, or storage while providing equivalent system reliability.

The values in this analysis were developed using E3’s reliability model, RECAP. The model assesses generation resource adequacy for a power system based on loss-of-load probability analysis but is inherently flawed for this application because it does not consider the observed renewable resource availability which can only be quantified by a detailed look at historical meteorological data such as I have proposed.

Electricity Demands

E3 correctly notes that it will be challenging to meet increased electricity demand due to electrification of vehicles and buildings while at the same time reducing, and eventually eliminating, GHG emissions while maintaining system reliability.  E3 predicts that electricity demand may increase by 65% to 80% depending on the “scale and timing of electrification”.  The electricity requirements depend upon how much of a role bio-fuels and synthetic fuels can play in replacing fossil fuels.  This analysis suffers from the lack of consideration of technical readiness for those technologies.  The IEA report lists very few bio-fuel and synthetic fuel technologies that have reached sizeable deployment and have all designs and underlying components at high technological readiness levels.

Peak Demands

The report explains that the transformation will “change the timing and magnitude of consumers’ electricity demands and create a “winter peaking” system in New York, owing to new demands from electric space heating”.  They go on to claim “Flexibility in electric vehicle charging patterns and building loads can significantly reduce peak demands and the need for new electric generating capacity. Flexible loads can serve a similar role to battery storage, shifting demand to times of high renewables output.”

“Figure 17 illustrates this evolution of the system peak—and the impacts of electric load flexibility over time”.  Because I think winter load is the greater future concern, I will discuss winter instead of summer information.  Figure 17 Annual summer and winter peak electricity demands shows how the peak electricity demand is expected to change.  I was unable to find the corresponding data for the annual summer and winter peak electricity demands portion shown in the figure but I estimate from the figure that the winter statewide peak load will be 24 GW in 2020 and in 2050 the peak load will be 35 GW with flex loads and 43 GW without flex loads.

The bottom portion of Figure 17 Average hourly loads by month is confusing at first glance.  It shows the average hourly load as it varies by each month.  E3 used their models to generate load shapes and develop their claim that there is 8 GW of peak load shaving available in 2050.  There is insufficient information to critique that claim but I am struck by the appearance of the 2020 and 2050 hourly load shapes.  In 2020 heating is a small component of load but in 2050 it will be much larger.  Consequently, I expect that the components of the load shape will change so I would expect some kind of change in the shape.  Instead it appears that the load is just larger and there is no change in the shape.  Importantly it is not clear why the load can be shaved.  Where do you shift the heating component that makes up the sharp increase early in the morning?  If you heat your home at 3:00 AM it will be cold by 7:00 AM during the peak.  Moreover, note that there does not appear to be as much flex load available at the peak later in the day that is roughly the same magnitude.  Consequently, I am not convinced of their arguments that 8 GW of load can be shaved off the winter peak.

Resource Portfolios

E3 claims that New York State has “access to diverse in-state renewable energy resources and zero-emissions technology options, as well as access to adjoining states, provinces, and regional transmission systems which offer additional options for zero-emissions energy supply”.  The E3 analysis used their RECAP model to determine “the new resources required to reliably meet electricity demand in buildings, transportation, and industry with 100% zero-emissions electricity for the upstate and downstate regions of New York”.

Although E3 claims that their analysis models the reliability contributions of intermittent and limited-duration resources, the fact that they did not use a comprehensive and more representative meteorological data set as input makes that claim weak in my opinion.  The worst-case reliability problem in the no-fossil-fuel future is very likely to be the worst-case wind and solar resource availability period not the peak load.  Unfortunately, it is possible that the winter conditions that create future peak loads may also exacerbate renewable resource availability so the two conditions may overlap.  I don’t think anyone has adequately addressed this issue yet.

E3 claims: Our analysis finds that New York can reliably meet growing electricity loads with 100% zero-emissions electricity by relying on a diverse mix of resources, including:

          • Onshore and offshore wind
          • Large-scale and distributed solar
          • In-state hydro and existing and new hydro imports from Quebec
          • Existing nuclear capacity
          • Existing and new combined cycles (CC) and combustion turbines (CT) utilizing zero-emissions biogas
          • New natural gas-fired combined cycles with carbon capture and sequestration (CC-CCS)

Eventually I will try to quantify the resources of each of these resources so that I can compare their projections with others.  The lack of data in this regard makes that task daunting.  I do want to make one observation.  Figure 18, Projected Installed Capacity (top) and Annual Electricity Generation (bottom), shows huge increases in bioenergy installed capacity in both scenarios.  However, note that the annual generation for those categories is small.  I cannot imagine a business case for developing that kind of capacity for such limited output so I believe it is likely that bioenergy will have to be heavily subsidized to make it available as they propose.

Transmission

E3 explains:

New investments in transmission will be needed to enable the delivery of 100% zero-emission electricity, including:

          • Local transmission upgrades to integrate new renewable resources
          • Additional transmission to deliver renewable resources from other regions, especially Quebec, into New York
          • Bulk transmission capacity from upstate New York to downstate load centers

Although New York has started the process of adding bulk transmission capacity it is not clear how much more will be needed.  I have yet to see anyone explain if any of the off-shore wind will be considered in-city generation for reliability purposes.  The DPS White Paper on CES procurements to implement the Climate Act includes a proposal for a Tier 4 procurement to encourage will directly extend financial support for renewable energy delivered into the New York City control zone but that discussion did not address in-city generation requirements.

 Firm Capacity

E3 explains that “Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”

Firm capacity allows the system to have adequate resources available during prolonged periods of low renewable energy output. I agree with the E3 description that “The State’s need for firm resources would be most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  E3 says that the hourly loads in their analysis are based on six years of historical weather 2007-2012.  I asked E3 what monitoring locations were used but never heard back.  I believe these data are from the National Weather Service climatological sites.  If that is the case they are not representative of the whole of New York and that NYS Mesonet data available from every county in the State should be used instead.

Conclusion

The first proposal to meet the Climate Act targets that was presented to the Climate Action Council can only be considered an overview.  The E3 analysis does not impress me.  While their models give the veneer of respectability to the projections, the reality is that the inherent over-simplifications of their models under-estimates the difficulties of the transition in New York and gives a false sense of security to their assurances that implementation will succeed.

Despite the limitations, the analysis does make important points.  I agree with their conclusion that the transition will “change the timing and magnitude of consumers’ electricity demands and create a “winter peaking” system in New York, owing to new demands from electric space heating”.  They point out that a multi-day period of low renewable energy availability will be a particular problem in the winter and state that: “Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”

After their presentation to the Climate Action Council, members asked E3 about the use of renewable natural gas as one of the firm capacity resources.  Apparently, some believe that renewable natural gas is not a renewable energy resource according to the Climate Act.  Be that as it may, I suspect that E3 has found that without sufficient firm capacity resources the only alternative to maintain reliability will be extraordinary amounts of energy storage.  Energy storage is very expensive and E3 might have included renewable natural gas energy to limit energy storage use to keep the costs down.

Although E3 claims to bring “clear, unbiased analysis to the critical issues facing the energy industry today” I don’t think that is possible to be unbiased and work for the New York Climate Action Council.  New York’s Climate Act is predicated upon the belief that decarbonization is only a matter of political will.  Unfortunately, that belief is inconsistent with the firm capacity challenge for the winter peak.  It will be interesting to see how the Council deals with inconvenient issues that challenge the notion that this transition is not pushing the envelope of electric system reliability.

NY Climate Leadership and Community Protection Act “Benefits”

I was prompted to prepare this post while reading the White Paper on Clean Energy Standard Procurements to Implement New York’s Climate Leadership and Community Protection Act (white paper) prepared by the New York Department of Public Service (DPS) and the New York State Energy Research and Development Authority (NYSERDA) because that document claims a “net benefit of around $7.7 billion” over the lifetime of projects they believe are required to meet the goal that 70% of electric energy will be produced by renewable energy by 2030 (70 by 30).  Although I have written about the approach used by the State before I believe it is necessary to re-iterate my concerns in the current context.

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

In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (Climate Act) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.

The legislation includes not only the 70 by 30 requirement but also a mandate to eliminate all fossil fuel use in the electricity sector by 2040. I have written a series of posts on the feasibility, implications and consequences of this aspect of the law based on evaluation of data.

Unfortunately, the politicians that passed the Climate Act never bothered to figure out how it could be done.  Among problems to resolve are development of a plan for renewable resources and an implementation plan to pay for those resources.  The DPS has a mandate to establish a program whereby jurisdictional load serving entities (today’s jargon for what used to be called the electric utilities) secure renewable energy resources to serve the 70 by 30 target.  The white paper explains how they propose to do this.  It includes the following:

        • Description of the key provisions in the Climate Act relating to the 70 by 30, including the role of jurisdictional LSEs and the definition of renewable energy systems;
        • Projection of the quantity of renewable energy that must be deployed to achieve 70 by 30;
        • Establishes average annual procurement targets for different tiers in the existing procurement process;
        • Proposal for a new tier for the procurement process; and
        • Cost and benefit analysis.

The following quote from the cost and benefit analysis sparked my interest:

“NYSERDA estimates that the proposed Tier 1 procurements, as set out in Section II.c.1 below, – from 2021 to 2026 – would lead to a levelized impact on electricity bills of less than 0.5% (or $0.35 per month for the typical residential customer). Taking into account the value of the avoided carbon emissions, these procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects.”

This post will show the fallacies in this benefit claim.

Social Cost of Carbon

It is New York State policy to calculate benefits of greenhouse gas emission reductions using the Social Cost of Carbon (SCC).  The SCC is the present-day value of projected future net damages from emitting a ton of CO2 today.  In order to estimate the impact of today’s emissions it is necessary to estimate total CO2 emissions, model the purported impacts of those emissions and then assess the global economic damage from those impacts.  The projected global economic damage is then discounted to the present value. Finally, the future damage is allocated to present day emissions on a per ton basis to get the SCC value.

I have previously argued that there are several technical reasons that the single value the State of New York has thus far relied on should not be used exclusively.  It is more appropriate to consider a range of values because of the massive uncertainties associated with this metric.  The  comments on the SCC prepared by Dr. Richard Tol in a Minnesota Public Utilities Commission hearing on that state’s use of the SCC better explain potential problems with the SCC.

Dr. Tol is Professor of the Economics of Climate Change at Vrije Universiteit Amsterdam and a Professor of Economics at the University of Sussex and has direct experience estimating the social cost of carbon.  In his testimony, Tol explains that there are differences between SCC and traditional damages cost methodologies: “The causal chain for the social cost of carbon is rather long, complex and contingent. In this way it is different from the traditional damages cost methodology for a pollutant like mercury or lead.”  He uses a couple of examples to explain that the many interactions between purported changes to the environment from a changed in the greenhouse effect due to a ton of CO2 depend upon assumptions every step of the way which makes it “rather difficult to the climate effects of CO2 emissions.”  He concludes: “In sum, the causal chain from carbon dioxide emission to social cost of carbon is long, complex and contingent on human decisions that are at least partly unrelated to climate policy. The social cost of carbon is, at least in part, also the social cost of underinvestment in infectious disease, the social cost of institutional failure in coastal countries, and so on.”

My biggest concern is that tweaking any one of many inputs to the SCC calculation radically change the results. New York uses the SCC values developed by the Obama administration. In 2017, President Trump signed Executive Order 13783 which modified two aspects of the calculation:  only considering damages occurring within the United States and employing discount rates of 3 percent and 7 percent for the use of this parameter in regulatory policy. The Obama values used global damage numbers and discount rates of 2.5 percent, 3 percent, and 5 percent. The difference between those two assumptions results in a SCC for domestic economic impacts at a 7 percent discount rate would be $2.20 in the year 2050, while the SCC for global economic impacts at a 2.5 percent discount rate would be $100.62. These changes reflect economic and policy judgements without advising the public what is happening.  When the costs hit the consumers, someone is going to have a lot of explaining to do.

Lifetime Benefits

Despite these issues, New York State uses the SCC without conditions to claim benefits from their proposed investments.  The white paper states “Taking into account the value of the avoided carbon emissions, these procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects.”  NYSERDA regularly calculates benefits based on the lifetime of their projects.  This is a different approach than that used in air pollution control regulation cost reduction calculations.  In the Environmental Protection Agency’s Reasonably Available Control Technology rule when you calculate the cost effectiveness of a control program, the cost of the control system is divided by the annual emissions reduction to get the dollars per ton reduced.  There is no consideration of lifetimes.

If you are interested in the cost of the Climate Act, you need to know the annual reductions possible from technologies implemented to reduce emissions.  The Climate Act specifies reductions from 1990 annual emissions so the apples to apples comparison is the annual reduction.  On the other hand, in a NYSERDA energy efficiency program, the avoided energy saved by the efficiency program equates to money saved.  It seems reasonable to count the total savings to the ratepayer.

When it comes to the SCC, I believed that it was inappropriate to consider lifetime savings but could not find anything specific in the literature to validate my belief.  I contacted Dr. Tol and asked the following question:

There is a current proceeding where NYSERDA is claiming that their investments are cost-effective but they use life-time benefits.  I concede that the ratepayer cost-benefit calculation should consider the life-time avoided costs of energy and can see how that reasoning might also apply to the social cost of carbon.  However, in the following definition, SCC is the present-day value of projected future net damages from emitting a ton of CO2 today, I can interpret that to mean that you shouldn’t include the lifetime of the reduction.  Am I reading too much into that?

His response explains that the use of life-time savings or costs is inappropriate:

Dear Roger,

Apples with apples.

The Social Cost of Carbon of 2020 is indeed the net present benefit of reducing carbon dioxide emissions by one tonne in 2020.

It should be compared to the costs of reducing emissions in 2020.

The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year).

stay healthy

Richard

Dr. Richard S.J. Tol MAE
Professor
Department of Economics, Room 281, Jubilee Building
University of Sussex, Falmer, Brighton BN1 9SL, UK

Conclusion

I am convinced that the majority of New York State ratepayers are unaware of the ramifications of the Climate Act and even if they know about it, it is unlikely that they know how the state calculates its claims that the costs will be out-weighed by the benefits.  In this instance, the quotation: “there are three kinds of falsehoods, lies, damned lies and statistics” could be modified to “there are three kinds of falsehoods, lies, damned lies and climate benefit estimates”.

This post explains that the SCC is a weak tool for climate policy.  I am most concerned that the SCC values are not robust because small changes in any of the large number of assumptions give contradictory results.  When used in policy making, like the Climate Act, the values chosen are politically expedient rather scientifically based.  The costs of the Climate Act will be enormous and I believe it is incumbent upon its advocates to explain their analyses and use of the SCC.

However, this post also shows that even if you accept the SCC as a valid approach and use the values chosen by New York, then the cost benefits claimed by NYSERDA, in general, and the white paper, in particular, are flawed because they rely on life-time benefits.  Today’s SCC is the net present benefit of reducing carbon dioxide emissions by one ton this year.  The SCC should not be compared to life-time savings or life-time costs.  As a result, the claim that the “procurements are estimated to yield a net benefit of around $7.7 billion over the lifetime of the projects” is wrong.

 

NY Climate Act Implementation – IEA Special Report on Clean Energy Innovation

Update July 6, 2020: I looked at the ETP Clean Energy Technology Guide in more detail and found their ratings for anerobic digesters.  I have modified the relevant section.

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done.  The International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that directly relates to this implementation effort that I believe should be required reading for New York’s Climate Action Council.

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.

On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law’s supporters acknowledge will have to be done.  I took issue with the presentation’s claim that “Deep decarbonization in New York is feasible using existing technologies” previously and in this post will highlight key points made in their Special Report on Clean Energy Innovation (“EIA Report”) that are relevant to New York’s Climate Act Implementation.

Introduction

New York’s Climate Act requires that the Climate Action Council prepare a plan for “net zero emissions in all sectors of the economy” in the following:

§ 75-0107. Statewide greenhouse gas emissions limits.

1. No later than one year after the effective date of this article, 24 the department shall, pursuant to rules and regulations promulgated after at least one public hearing, establish a statewide greenhouse gas emissions limit as a percentage of 1990 emissions, as estimated pursuant to section 75-0105 of this article, as follows:

a. 2030: 60% of 1990 emissions.

b. 2050: 15% of 1990 emissions.

§ 75-0103. New York state climate action council.

11. The council shall on or before two years of the effective date of this article, prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule established in section 75-0107 of this article, and for the reduction of emissions beyond eighty-five percent, net zero emissions in all sectors of the economy, which shall inform the state energy planning board’s adoption of a state energy plan in accordance with section 6-104 of the energy law. The first state energy plan issued subsequent to completion of the scoping plan required by this section shall incorporate the recommendations of the council.

The E3 presentation echoes the belief of the supporters of the Climate Act that achieving the net zero goal is essentially just a matter of political will.  However, the IEA report suggests that optimism is mis-placed:

“Without a major acceleration in clean energy innovation, net-zero emissions targets will not be achievable. The world has seen a proliferating number of pledges by numerous governments and companies to reach net-zero carbon dioxide (CO2) emissions in the coming decades as part of global efforts to meet long-term sustainability goals, such as the Paris Agreement on climate change. But there is a stark disconnect between these high-profile pledges and the current state of clean energy technology. While the technologies in use today can deliver a large amount of the emissions reductions called for by these goals, they are insufficient on their own to bring the world to net zero while ensuring energy systems remain secure – even with much stronger policies supporting them.”

Analysis

In order to focus my analysis on a manageable component of the Climate Act implementation plan I am going to address one component of the electric sector de-carbonization pathway.  E3 and I agree that the biggest problem for a de-carbonized electric system is going to be the winter peak when solar resources are low and the potential for a large high-pressure system could mean that wind resources are near zero for several days.  E3 claims the New York winter statewide peak load will be 24 GW in 2020 and in 2050 the peak load will be 35 GW with flex loads and 43 GW without flex loads when the added demands of electrifying transport and heating are added to the system. E3 offered a combination of five options to meet the challenge: large-scale hydro resources, renewable natural gas, synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power.  I will look at these technologies with respect to the IEA report and feasibility in New York to determine if the 2040 de-carbonized electric system goal is realistic.

There are two technologies listed that are mature and have long histories of development: large-scale hydro resources and nuclear power.  However, New York needs additional resources to meet this demand challenge and I believe it is unlikely that either technology can be counted on in New York.  Although nuclear should be considered the fact that the completed nuclear power plant at Shoreham was never operated, the closing of one operational unit at Indian Point in 2020, and the planned closing of the last operational unit at Indian Point in 2021 suggests that new nuclear in New York is extremely unlikely.  I am comfortable saying that there are no significant sources of undeveloped hydro available much less permittable in New York.  There is a potential for Canadian hydro-power that will likely be considered.

The remaining three technologies are still in the “clean energy innovation pipeline” described in the IEA report.  IEA explains:

“Innovation is not the same as invention. After a new idea makes its way from the drawing board to the laboratory and out into the world, there are four key stages in the clean energy innovation pipeline. But this pathway to maturity can be long, and success is not guaranteed:

Prototype: A concept is developed into a design, and then into a prototype for a new device (e.g. a furnace that produces steel with pure hydrogen instead of coal).

Demonstration: The first examples of a new technology are introduced at the size of a full-scale commercial unit (e.g. a system that captures CO2 emissions from cement plants).

Early adoption: At this stage, there is still a cost and performance gap with established technologies, which policy attention must address (e.g. electric and hydrogen-powered cars).

Mature: As deployment progresses, the product moves into the mainstream as a common choice for new purchases (e.g. hydropower turbines).”

The EIA report notes that de-carbonization comes from four main technology approaches. These are the electrification of end-use sectors such as heating and transport; the application of carbon capture, utilization and storage; the use of low-carbon hydrogen and hydrogen-derived fuels; and the use of bioenergy. EIA explains that each of these areas faces challenges in making all parts of the technological application process, what they call the value chain, commercially viable in the sectors where reducing emissions is hardest.  The IEA report uses the technology readiness level (TRL) scale (complete description in Box 3.2 on page 67) to assess where a technology is on its journey from initial idea to market use.  Their evaluation of the TRL for different de-carbonization technologies is summarized in three figures: Figure 3.2 TRL of technologies along the low-carbon electricity value chain, Figure 3.3 TRL of technologies along the CO2 value chain, and Figure 3.4 TRL of technologies along the low-carbon hydrogen value chain.

Figure 3.2 notes that hydropower and nuclear are mature technologies.  While it is straying from my intent to discuss only those technologies proposed for the winter peak, it is interesting that solar PV, solar thermal, wind, and hydrogen from water electrolysis are all listed as an early adoption TRL. 

E3 claims that Carbon Capture Storage (CCS) can be used to address the winter peak.  The EIA report notes that capture, transport and utilization or storage of CO2 emissions as a successful decarbonization strategy hinges on the commercial availability of technologies at each stage of the process as well as on the development and expansion of CO2 transport and storage networks at a sizeable scale (Figure 3.3). In this instance I assume that E3 is referring to CCS combined with natural gas combustion.  According to the EIA report natural gas electricity production coupled with chemical absorption has a demonstration TRL.  The feasibility issue in New York may ultimately be storage because there is no oil production to enhance.  Storage in saline formations has an early adoption TRL but New York refused to allow propane storage because of its impact on community character so I would imagine this could not be permitted either.

E3 claims that “synthetic fuels such as hydrogen” can be used to address the winter peak. I am going to only consider hydrogen synthetic fuel production and that is covered in Figure 3.4.  The EIA report notes:

“The value chain for low-carbon hydrogen is not completely developed at commercial scale today. It comprises many technologies that are necessary to produce, transport, store and consume low-carbon hydrogen, each of them at a different stage of maturity and facing specific technical challenges (Figure 3.4)”. 

The pathway report only mentions the use of hydrogen but not how it would be used for the winter peak.  I assume that E3 proposes to use hydrogen production from electrolysis and that has an early adoption TRL.  In order to have it available for use during the winter peaks it will need to be shipped and stored.  The hydrogen infrastructure for pipelines and tanks are both rated as mature technologies.  If the hydrogen is supposed to be used for heating hydrogen boilers and fuel cells have an early adoption TRL but hydrogen-driven fuel cells only have a large prototype TRL.  If the hydrogen is supposed to be used to generate electricity then high-temperature fuel cells have an early adoption TRL and hydrogen-fired gas turbines have a large prototype TRL.

Updated July 6, 2020: E3 also proposes to use renewable natural gas from anerobic digesters to address the winter peak problem.  I could not find a category in these three figures that I think fits this technology in the EIA report.  The poster version of the technology guide rates biogas from a non-algae feedstock as “Commercial Operation In Relevant Environment – Solution is commercially available, needs evolutionary improvement to stay competitive”. There are questions about the collection and storage infrastructure needed to transport and store it for the winter peak demand as well as how much gas is available relative to the need for the winter peak.  

Conclusion

I believe that this report underscores my belief that the statement “Deep decarbonization in New York is feasible using existing technologies” mis-characterizes the actual situation.  As EIA points out feasibility depends upon making all parts of the technological application process, what they call the value chain, commercially viable.  The fact is that for the technologies proposed to address the winter peak problem, one or more aspects of commercial viability, availability limitations, or public perception make the E3 recommendations risky bets for future reliability and affordability.

I suggest that it would be better for the State to take a measured approach rather than the all-in approach currently envisioned.  The fact is that we don’t know what will work best for New York so it would be better to have a plan that could be adjusted as necessary.  The IEA proposes five innovation principles that I think would be appropriate for New York to incorporate in their Climate Act implementation process. 

For governments aiming to achieve net-zero emissions goals while maintaining energy security, these principles primarily address national policy challenges in the context of global needs, but are relevant to all policy makers and strategists concerned with energy technologies and transitions:

Prioritise, track and adjust. Review the processes for selecting technology portfolios for public support to ensure that they are rigorous, collective, flexible and aligned with local advantages.

Raise public R&D and market-led private innovation. Use a range of tools – from public research and development to market incentives – to expand funding according to the different technologies.

Address all links in the value chain. Look at the bigger picture to ensure that all components of key value chains are advancing evenly towards the next market application and exploiting spillovers.

Build enabling infrastructure. Mobilise private finance to help bridge the “valley of death” by sharing the investment risks of network enhancements and commercial-scale demonstrators.

Work globally for regional success. Co-operate to share best practices, experiences and resources to tackle urgent and global technology challenges, including via existing multilateral platforms.

NY Climate Act Implementation – De-Carbonization Pathways Overview

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done.  On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law may suggest will be done.  This post is an overview summary of that report concentrating on the presentation summary of the draft findings.

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.

Summary

The Pathways to Deep Decarbonization in New York State Presentation  can be viewed on the video of the webinar.  The Pathways to Deep Decarbonization in New York State – Final Report  itself and two appendices: Appendix A: Methods and Data  and Appendix B: Literature Review of Economy-Wide Deep Decarbonization and Highly Renewable Energy Systems  were included in the meeting materials.

I think the best way to summarize the report is to simply reproduce the conclusions in section 5 of the presentation and then discuss the points made:

This report presents E3’s initial strategic analysis to inform New York’s future decisions for meeting GHG goals under the CLCPA. Based on our detailed assessment of pathways to deep decarbonization in New York State, we find the following:

        • Deep decarbonization in New York is feasible using existing technologies. This reinforces the conclusion of many other studies. All needed technologies currently exist and can safely be assumed to realize incremental improvements resulting from significant deployment. A high level of innovation will make the transition easier, but the transition is already technically feasible.
        • There are different pathways to a carbon neutral future. A 30-year transition demands action now across all sectors of the State’s economy but affords some optionality. All scenarios that achieve carbon neutrality show significant progress across the “four pillars” of decarbonization: energy efficiency and conservation, decarbonizing the electricity supply, switching to low-carbon fuels, and negative emissions.
        • Continued research, development, and demonstration is key to advancing a full portfolio of options. Some studies and scenarios rely on technologies that have only been demonstrated in a limited number of applications and require further progress before commercial readiness.
        • Consumer decision-making drives the pace of decarbonization, particularly in buildings and on-road transportation. By 2030, key technologies like plug-in electric vehicles, electric heat pump heating and hot water systems, and other electric appliances in the home (e.g., stoves, clothes dryers) will need to become normalized, meeting or exceeding half of new sales with accelerating adoption through midcentury.
        • Flexibility along multiple dimensions is key to maintaining reliability and reducing cost of a 100% zero-emission electricity system. In the electricity sector, several forms of flexibility are necessary for balancing a 100% zero-emissions grid. Flexible end-use loads and battery storage can provide sufficient short-term (intraday) flexibility to balance high levels of variable renewable output. The more difficult challenge is during winter periods with high heating loads and very low renewable energy production, which can occur over several days. This long-duration (interday) challenge can be solved through a combination of large-scale hydro resources, renewable natural gas (RNG) or synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power.
        • Managed electrification can help mitigate the risk of very high winter peaks. In addition to efficiency and end-use load flexibility, investments in a balanced mix of electric heating system configurations and investment in research and development to continue the improvement in cold climate heat pump performance can help to mitigate potential risk associated with unintended consequences of unmanaged electrification.

Background

The New York State Energy Research and Development Authority (NYSERDA) hired E3 to conduct the strategic analysis of New York’s decarbonization opportunities.  It is strategic in the sense that they worked backwards from the targets and put together measures that would be needed to reach them.

The report notes that:

The CLCPA requires additional reporting of emissions associated with “extraction and transmission of fossil fuels imported into the state,” as well as the adoption of a 20-year global warming potential, a metric that emphasizes the near-term climate impacts of short-lived climate pollutants such as methane. The calculation of a 1990 baseline that includes these new requirements is currently underway.

This report is based on the existing inventory of 1990 emission that uses the 100-year global warming potential commonly used elsewhere.  New York’s irrational[1] war on natural gas includes the 20-year global warming potential in order to maximize the effect of natural gas and methane reductions relative to the targets.

Feasibility

The report claims that “Deep decarbonization in New York is feasible using existing technologies”.  Their definition of feasibility apparently means somewhere, someplace, someone has successfully applied the technology.  Using their criteria I am surprised they did not include nuclear fusion as a technology.  After all fusion plasma has been maintained in a stable state for 70 seconds.  Using their rosy projections surely this technology will be available for use in 2050.

Reality is only two paragraphs away: “Continued research, development, and demonstration is key to advancing a full portfolio of options. Some studies and scenarios rely on technologies that have only been demonstrated in a limited number of applications and require further progress before commercial readiness”.  When the report claims “All needed technologies currently exist and can safely be assumed to realize incremental improvements resulting from significant deployment. A high level of innovation will make the transition easier, but the transition is already technically feasible”, there is a serious effort to stretch feasibility that most people would accept in this context.

I agree with the report’s conclusion that winter periods with high heating loads and very low renewable energy production is going to be a big challenge.  The report claims that this can be solved through “a combination of large-scale hydro resources, renewable natural gas (RNG) or synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power”.  I do not agree that RNG and synthetic fuels such as hydrogen are necessarily feasible at the scale necessary to keep the lights on when New Yorkers need the power the most once heating and transportation are electrified.

One final feasibility comment.  The report notes that “investment in research and development to continue the improvement in cold climate heat pump performance can help to mitigate potential risk associated with unintended consequences of unmanaged electrification”.  This refers to the very real problem that air source heat pumps become much less efficient when temperatures go below 20 deg F.  Their study assumes “that a balanced portfolio of electric space heating systems – including cold climate air-source heat pumps with and without onsite combustion backup as well as ground-source heat pumps – would be deployed”.  Heat pumps are very efficient because they move heat/energy rather than produce it when they provide heating.  Ground-source heat pumps always have energy to move.  The problem that air-source heat pumps have is there isn’t enough energy to provide the heat needed when temperatures are cold.  Absent a repeal of the laws of thermodynamics, it is not clear what additional R&D is going to be able to do for air-source heat pump performance when there is no energy to convert.

De-Carbonization Pillars

The pathways proposed to achieve carbon neutrality show “significant progress across the “four pillars” of decarbonization: energy efficiency and conservation, decarbonizing the electricity supply, switching to low-carbon fuels, and negative emissions”.  I address each pillar below.

While I believe that energy efficiency and conservation are the most effective tools for emission reductions, I also believe that there are limits to what can be practically achieved.  New York is already among the most energy efficient states in the country so future progress will likely be difficult.

My primary concern is decarbonizing the electricity supply because all the analyses that show the availability of renewable resources have to date failed to consider small-scale solar variability.  During winter periods with high heating loads the report notes that very low renewable energy production over several days could be expected but their analysis did not use the NY Mesonet data available from every county to refine their projection.  Given the significant effect that the Great Lakes have on precipitation and cloudiness across much of Upstate New York that is a serious deficiency in their solar resources projections.

The report explains that “Advanced low-carbon liquid and gaseous fuels are key to decarbonizing sectors where electrification is challenging, such as freight transportation, aviation, marine, and high-temperature industrial applications”.  Their fuels analysis includes hydrogen produced from electricity produced by renewables.  The thought is that when all the renewables are built there will be many times when we don’t need the electricity so instead of curtailing production, they will use it to create hydrogen that can be stored for use when the wind doesn’t blow at night.  This may or may not be feasible in my mind and because no jurisdiction has employed this technology in a similar application I tend to think it may not be feasible.

There is another little tidbit related to bio-fuels that needs to be recognized.  The report notes that “the pathways modeled in our analysis can achieve deep decarbonization using available in-state biomass feedstocks that are assumed to be converted to advanced renewable natural gas and renewable petroleum products. We also assume that a small amount of wood consumption remains in 2050 to serve a variety of needs, including residential wood usage in the North Country”.  In this instance does North refer to anything north of New York City?  More importantly, their pathways “retain approximately 16 TBtu of wood consumption statewide in 2050; Compare to 2016 residential wood usage in the North Country of about 3 TBtu”.  I personally don’t think that increasing residential wood usage five times over current use is a “small” amount.

Negative emissions strategies including both natural and working lands and negative emissions technologies make up the fourth pillar.  The report defines “negative emissions” as “the removal of CO2 directly from the atmosphere or from the emission stream of renewable biogenic feedstock combustion (where the carbon emitted was first captured from the atmosphere in the photosynthesis process, resulting in a net decrease in atmospheric carbon)”.  The report states that “With nearly 20 million acres of forest, New York State’s natural and working lands sink is projected to sequester between 23 to 33 MMT CO2e”.  The obvious question that comes up is that given a five-fold increase in residential wood usage isn’t that going to cut down the sequestration potential?

Customer Choice

There are two aspects of this that most New Yorkers do not realize are coming soon to their lives: customer choice and customer energy use.  The report explains that “Consumer decision-making drives the pace of decarbonization, particularly in buildings and on-road transportation. By 2030, key technologies like plug-in electric vehicles, electric heat pump heating and hot water systems, and other electric appliances in the home (e.g., stoves, clothes dryers) will need to become normalized, meeting or exceeding half of new sales with accelerating adoption through midcentury.”  What that translates to is you will only have a fifty-fifty chance to buy fossil-fueled appliances or cars in ten years even if the performance that the report admits has to improve has not reached the level needed for your application.  That does not even begin to consider personal preferences for the capability and reliability of on-site fossil fuels.  I have yet to see an explanation of what will happen when there is an ice storm after everything is electrified.  I value the capability to have heat even when the power is down as a very nice benefit of natural gas.

In order to reduce the amount of energy and storage needed it is necessary to shave the peak load as much as possible.  The report notes that “Flexible end-use loads and battery storage can provide sufficient short-term (intraday) flexibility to balance high levels of variable renewable output”.  I believe that flexible end-use load translates to eventual remote control of customer power use.   The theory is that smart meters can provide enough detailed information that they can be used to charge customers higher rates when the load gets high providing a signal for customers to shift usage.  One of the unintended consequences of heating electrification and the expected change to the annual peak load moving to the winter is that shifting heating load is much less of an option.  In the early morning when temperatures are coldest and people warm up their houses what load can be shifted?  If it is a choice between a blackout or a brownout across the system or limiting power use by individual customers it is not a stretch to think that smart meters will limit usage.

Conclusion

Given the enormity of the challenge to meet the Climate Act targets and the composition of the Climate Action Council membership I suppose it was too much to expect unbiased, fact-based implementation pathways.  However, the exaggerated feasibility claims and internal inconsistencies of this document worry me.  The first key takeaway “deep decarbonization is feasible using existing technologies” is only true with a liberal definition of feasible and existing technologies.

The biggest problem is going to be the winter peak when it is likely that there will be insufficient renewable energy available for multiple days.  E3 offered a combination of five options to meet the challenge: large-scale hydro resources, renewable natural gas, synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power.  Note that New York needs additional resources to meet this new challenge and while large-scale hydro resources and nuclear power are possible sources to think that they can be developed in New York is very unlikely.  Renewable natural gas from anerobic digesters is a proven technology but is it feasible to collect and store enough to meet the winter peak demand.  Synthetic fuel production hasn’t even proven itself as a technology that can be deployed at scale much less meet the collection and storage requirements.  CCS is another technology that has “only been demonstrated in a limited number of applications and requires further progress before commercial readiness” but even if the technology works the bigger issue is where are you going to put the collected CO2.  In order to safely store CO2, you need a particular geological formation and that may mean that this technology cannot be used where it is needed in New York.

The conclusion that “Deep decarbonization in New York is feasible using existing technologies” coupled with the conclusion “Continued research, development, and demonstration is key to advancing a full portfolio of options” is a glaring inconsistency.  Two pathways include a “small” amount of wood consumption in 2050 but it turns out that level is five times the existing level.  Furthermore, that consumption is at odds with the negative emissions needed from forest sequestration.

Based on this, I fear that the scoping plan will not be scrutinized in sufficient detail to maintain reliability and affordability.  The Climate Action Council will merely pay lip service to their responsibilities to the citizens of the State and the result will be disastrously high energy costs and impacts to reliability.

I believe that it is only a matter of time until the Iron Law of Climate, “while people are often willing to pay some price for achieving climate objectives, that willingness has its limits” catches up to the Climate Act. It is not only the enormous costs but it is also the changes in lifestyles that will precipitate public demand to repeal the law.  I believe that is in the best interest of the State to get this over as quickly as possible so I think the time has come to accelerate implementation of New York’s Climate Leadership and Community Protection Act.  In order to meet the requirement for an 85% emission reduction economy-wide by 2050 we should immediately stop all investments in fossil fuel infrastructure.  New Yorkers will have to purchase electric vehicles and stop purchasing gas and oil furnaces, gas stoves and gas hot water systems at some point to meet these goals.  According to the advocates the technology is feasible, available, affordable, and necessary.  Let’s test the willingness of the citizens of the State to meet these goals now and get this over sooner rather than later.

[1] I consider New York’s policies to ban hydraulic fracturing and not permit new natural gas infrastructure irrational because the lower prices that resulted from that technology have been responsible for the majority of the emission reductions observed in New York’s electric sector since 2010.

24 June, 2020 New York Climate Action Council Meeting

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and no less than 85 percent by 2050 from 1990 levels. The law creates a Climate Action Council charged with developing a scoping plan of recommendations to meet these targets.  This post summarizes the second meeting of the Council.

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.

According to the Climate Action Council website: “The New York State Climate Action Council (Council) is a 22-member committee that will prepare a Scoping Plan to achieve the State’s bold clean energy and climate agenda”.  The co-chairs and ten of the members are representatives of state agencies and authorities.  The remaining ten members were chosen by politicians. Advisory panels and the Just Transition Working Group will help develop the scoping plan.  As of this meeting only the working group has been set up.  No word on the six initial panels: transportation; energy efficiency and housing; agriculture and forestry; power generation; energy intensive and trade-exposed industries; and land-use and local government.

June 24, 2020 Climate Action Council Meeting

The meetings and materials web page for the Council lists the meeting materials, a link to a meeting video, and additional resources. This meeting was originally scheduled in April but due to the pandemic was postponed.  Moreover, it has had significant impacts to programs at the agencies because staff have been diverted away from Council activities to assist in the emergency response.  As a result, not much has happened to this effort for several months.

There is a video link but I watched the meeting webinar.  Not listed in the posted agenda was the item co-chair remarks that was long and added nothing to the substance of the meeting.    Skip the first 45 to 50 minutes to get too the presentation by E3 and you will miss nothing  The agenda consisted of the following topics:

      • Consideration of Minutes
      • Presentation by Consultants: Emissions Reduction Pathways Analysis, Energy and Environmental Economics, Inc. (E3)
      • Discussion of Working Groups and Scopes of Work for Advisory Panels
      • Updates on NYS Implementation from DEC: Greenhouse Gas Emission Limits, Value of Carbon Reduction
      • Next Steps

One of the points of emphasis during the meeting was the allegation that there are disparate impacts of the pandemic and of climate change to Environmental Justice (EJ) communities. The Climate Act (§ 75-0117 Investment of funds) has specific requirements on funding for EJ communities:

State agencies, authorities and entities, in consultation with the environmental justice working group and the climate action council, shall, to the extent practicable, invest or direct available and relevant programmatic resources in a manner designed to achieve a goal for disadvantaged communities to receive forty percent of overall benefits of spending on clean energy and energy efficiency programs, projects or investments in the areas of housing, workforce development, pollution reduction, low income energy assistance, energy, transportation and economic development, provided however, that disadvantaged communities shall receive no less than thirty-five percent of the overall benefits of spending on clean energy and energy efficiency programs, projects or investments and provided further that this section shall not alter funds already contracted or committed as of the effective date of this section.

Commissioner Seggos explained the direction of 40% of overall benefits to EJ communities is only a goal and the Council should aim for a higher value.  There also is a requirement for ambient air monitoring in EJ communities.  Presumably DEC’s air quality monitoring programs in four EJ communities counts towards that requirement.

The NYSERDA consultant, E3, presented results of their emissions reductions pathway analyses by sector. This is the first tangible product that describes what will be required to meet the Climate Act. The summary notes that “there is no single pathway to a decarbonized economy, all scenarios that achieve carbon neutrality share significant progress in the following four pillars:

      • Energy efficiency, conservation and end use electrification
      • Switching to low carbon fuels
      • Decarbonizing the electricity supply
      • Negative emissions measures and carbon capture technologies”.

The presentation noted that results are intended to inform the Council discussion not make specific recommendations.  I intend to devote a post to this report in the future.

The “Just Transition” workgroup candidates have been identified and they will likely meet in a month or so.  No information was provided on filling the other workgroups or panels.

There has been progress on the Department of Environmental Conservation (DEC) implementation.  DEC is working on two rulemakings:

      • The Climate Act requires them to establishing emissions limits for 2030 and for 2050 and because the targets are based on 1990 emissions, they have to finalize that as well. There will be a proposal released for public comment in August (end of comments in October).  Emissions limits will be finalized by January 1, 2021.
      • DEC also has to identify the value of carbon as an aid for agency decision making (not for regulatory use).  DEC is considering two options: environmental damages and marginal cost of abatement.  DEC will evaluate a range of discount rates including zero, the social cost of carbon used in other jurisdictions and will provide values for non-CO2 GHG.   A stakeholder conference will be held in July; public comment on the agency guidance document will occur from August – September with a final release in January, 2021

The Climate Act includes a definition of “Carbon dioxide equivalent” or as it is more commonly known global warming potential, that complicates these rule-makings.  The law specifies that that carbon dioxide equivalent “means the amount of carbon dioxide by mass that would produce the same global warming impact as a given mass of another greenhouse gas over an integrated twenty-year time frame after emission”.  The Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change section on Anthropogenic and Natural Radiative Forc­ing uses a 100-year time frame but admits that there is no scientific basis to choose that over other time frames.  The problem is that New York’s requirement for a 20-year time frame means that you cannot compare New York’s emission inventories and costs of carbon to everyone else, including earlier New York work who uses the 100-year time frame.  Consequently, this means more work for DEC to generate numbers consistent with the Climate Act.

Conclusion

There is a long way to go with the Climate Action Council and its charge to develop a scoping plan.  Although the de-carbonization pathways presentation claimed that their initial pathways were feasible, they also admitted that the scale of the transformation was unprecedented.  I will be posting on the pathways and DEC rulemakings in future articles.

One final note.  The membership of the Climate Action Council and the likely makeup of all the working groups and advisory panels is over-whelming convinced not only that there is an existential climate threat but that implementation of the Climate Act is only a matter of political will.  Even the title scoping plan as opposed to feasibility plan suggests there is no question this can be done. In that light, it is not clear if any evidence contrary to their pre-conceived notions could engender change.  However, as Robert Louis Stevenson said: “Sooner or later everyone sits down to a banquet of consequences”.

 

Part 242 Comments on the Regulatory Impact Statement

For the past month or so I have been preparing comments on the New York State Department of Environmental Conservation (DEC)  proposed revisions to their Part 242 CO2 Budget Trading Program rule. I submitted the comments on June 26, 2020. In a companion post I addressed the background for the rule revisions and rationale used for the significant rule changes. This post summarizes my comments on the Regulatory Impact State that justifies the proposed revisions.

I submitted comments because I want my family to be able to afford to continue to live in New York State.  The proposed rule is consistent with the Climate Leadership and Community Protection Act (“Climate Act”) that will necessarily affect the price of energy in New York and based on results elsewhere I believe those costs will ultimately be unacceptable.  I have written a series of posts on the feasibility, implications and consequences of the law.  I am a retired electric utility meteorologist with nearly 40 years of experience analyzing the effects of emissions on the environment.  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.

Introduction

I describe the specifics of the proposed revisions and my concerns in the companion post.  One of the purported benefits of this regulation is that New York’s climate leadership will entice other jurisdictions to emulate New York by setting an example.  However, the justification provided for these revisions provides New York citizens insufficient evidence to support the proposed changes and sets a poor example for others to follow.  I analyzed the claims in the Regulatory Impact Statement (RIS) that were used to justify the proposed actions and I will discuss those comments here.  The RIS has mandatory discussion items and I will not address my comments on items not related to justification of the proposed actions.

Regulatory Impact Statement

The Regulatory Impact Statement (RIS) is a mandated component of DEC rule-making.  It describes the statutory authority and legislative objectives, lists the needs and benefits, estimates costs, changes to paperwork, local government mandates, notes if there is any duplication with other Federal and State regulations, lists alternative, determines if the regulation is consistent with Federal standards and provides a compliance schedule.  I wish I could say that the RIS makes a compelling case for the proposed action but I can’t. This is important because one of the purported benefits of this regulation and New York’s climate leadership is that New York will lead the way for others setting an example that they will emulate.  However, absent compelling arguments, that benefit will not be realized. 

The general approach for current New York energy and environmental rule-making associated with climate change is to unequivocally associate Greenhouse Gas Emissions (GHG) with a litany of climate change impacts that are happening now and will get much worse in the future.  I have been planning to spend time addressing this simplistic argument for a long time and this regulation gave me the opportunity to comment.  In the following sections using the titles from the RIS, I quote text from sections in the RIS and provide my comments in the following italicized, indented sections. 

Introduction

The burning of fossil fuels to generate electricity is a major contributor to climate change because fossil-fuel generators emit large amounts of CO2, the principal greenhouse gas (GHG). Overwhelming scientific evidence confirms that a warming climate poses a serious threat to the environmental resources and public health of New York State – the very same resources and public health the Legislature has charged the Department to preserve and protect. The warming climate threatens the health and well-being of the State’s residents and citizens, the State’s property, and the natural resources held in trust by the State, including, but not limited to, the State’s air quality, water quality, marine and freshwater fisheries, salt and freshwater wetlands, surface and subsurface drinking water supplies, river and stream impoundment infrastructure, and forest species and wildlife habitats. Not only will the proposed Program revisions help to further counter the threat of a warming climate, they will also produce significant environmental co-benefits in the form of improved local air quality, and a more robust, diverse and clean energy supply in the State.

The biggest flaw in the RIS is the failure to quantify the impact of the proposed action on the alleged impacts of a warming climate.  Instead there are vague allusions that the proposed revisions will “help to further counter the threat of a warming climate”.  In order to properly evaluate the benefits and costs of the proposed revisions the RIS should estimate the global warming potential impacts of the proposed action. 

 In the absence of such an evaluation I calculated the effect  of total elimination of New York’s 1990 218.1[1] million metric ton greenhouse gas emissions on projected global temperature rise.  I found there would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  To give you an idea of how small this temperature change is  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 is the same as going down 27 inches.  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 going south two thirds of a mile. 

 Of course, the RIS should project what this particular action will do for global temperature.  The RIS Model Rule Policy Case Program Design Assumption description states that CO2 emissions in New York are projected to be 3.41 million tons lower in the Model Rule Policy Case than in the Reference Case in 2031.  Using the same methodology as before I found there would be a reduction, or a “savings,” of approximately 0.00005°C by the year 2050 and 0.00009°C by the year 2100.  The projected temperature difference is the same as going down 3/8 of an inch and the projected temperature change is the same as going south 50 feet. 

 New York’s actions 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 this program will be replaced by the added 2019 Chinese capacity in 16 days or 6 days if the 2019 capacity and the units under construction are combined.  Clearly, in the absence of worldwide commitments this proposal has no tangible value to the citizens of New York.

 The RIS also claims that the emission reductions will also produce significant environmental co-benefits in the form of improved local air quality, and a more robust, diverse and clean energy supply in the State.  I take issue with the environmental co-benefits arguments simply because I have never seen documentation that confirms those benefits relative to the observed air quality improvements in my lifetime (see for example my evaluation of PM 2.5 in New York City).  Combining claimed benefits for robust and diverse energy supply with a clean energy supply is unsubstantiated rhetoric.  In order for the power supply to be robust it has to be dispatchable whereas wind and solar clean energy is not.  In order for the power supply to be diverse it cannot be shut down by a singular event and wind and solar can be shut down by a relatively common singular set of weather conditions at night.

The Greenhouse Effect and the Warming Climate

A naturally occurring greenhouse effect has regulated the earth’s climate system for millions of years. Solar radiation that reaches the surface of the earth is radiated back out into the atmosphere as long wave or infrared radiation. CO2 and other naturally occurring GHG emissions trap heat in our atmosphere, maintaining the average temperature of the planet approximately 60°F above what it would be otherwise. An enhanced greenhouse effect and associated climate change results as large quantities of anthropogenic GHGs, especially CO2 from the burning of fossil fuels, are added to the atmosphere.

There is no question that the greenhouse effect regulates global temperatures, that additional greenhouse gases will enhance that effect, that anthropogenic GHG emissions have added to the observed trend in GHG atmospheric concentrations, that the climate is warming and that the anthropogenic GHG emissions likely contributed to the observed warming.  However, given that there are many factors affecting climate change and that an enhanced greenhouse effect impacts not only temperature but also moisture which could have a negative feedback, it is naïve to assume that all the observed warming is caused solely by the greenhouse gas effect.

 From 1983 until his retirement in 2013, Dr. Richard Lindzen was Alfred P. Sloan Professor of Meteorology at the Massachusetts Institute of Technology.  He published over 200 papers and books and his research is still cited about 600 times per year.  He recently published another scientific paper (Lindzen, 2020) that raises some important points relative to the greenhouse effect as it pertains to New York’s energy policies:

 Doubling the atmospheric CO2 concentration from 280 ppm to 560 ppm results in just a 1-2% perturbation to the Earth’s 240 W/m² energy budget. This doubled-CO2 effect has less than 1/5th of the impact that the net cloud effect has. And yet we are asked to accept the “implausible” claim that change in one variable, CO2, is predominantly responsible for altering global temperatures.

 A causal role for CO2 “cannot be claimed” for the glacial-to-interglacial warming events because CO2 variations follow rather than lead the temperature changes in paleoclimate records and the 100 ppm total increase over thousands of years produce “about 1 W/m²” of total radiative impact.

Since the mid-1700’s, atmospheric concentrations of GHGs have increased substantially due to human activities such as fossil fuel use and land-use change. CO2 has a very long residence time in the atmosphere and, thus, has a lasting effect on the climate. Average atmospheric CO2 concentrations exceeded 407 parts per million in 2018, which according to ice core data, is higher than at any point in the past 800,000 years and the rate of increase is 100 times faster than previous natural increases at the end of the last ice age.

There are two aspects of these claims.  If you look at the CO2 data going further back in geologic time, as shown in the following grapch, there is nothing particularly unusual about the record breaking CO2 levels of the past 800,000 years  The thing that does stand out however is that we are cooler than in the past.

 The second aspect is the rate of increase claim.  The problem is that measurement resolution of proxy measurements of CO2 and temperature are not as finely resolved as today’s instrumental data.  The only way to directly compare the instrumental data to the pre-industrial proxy data is to filter the instrumental data down to the resolution of the proxy data.  This leads to climate reconstructions with “enhanced variability during pre-industrial times” and “result in a redistribution of weight towards the role of natural factors in forcing temperature changes, thereby relatively devaluing the impact of anthropogenic emissions and affecting future predicted scenarios.”[2]

There is clear scientific consensus that anthropogenic emissions of CO2 are contributing to the observed warming of the planet as presented in the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. The large and persuasive body of research demonstrates through unequivocal evidence that the Earth’s lower atmosphere, oceans, and land surfaces are warming; sea level is rising; and snow cover, mountain glaciers, and Greenland and Antarctic ice sheets are shrinking. The Earth’s climate is changing, with adverse consequences already well documented across the globe, in our nation and in the State. Extreme heat events are increasing and intense storms are occurring with greater frequency. Many of the observed climate changes are beyond what can be explained by natural variability of the climate.

This description of the relationship between CO2 emissions and observed warming does not acknowledge that there is any scientific uncertainty about the greenhouse effect and climate change.  The reality is that there is debate and New York State ignores the potential ramifications.  Dr. Richard S. Lindzen, has summarized the scientific debate as follows:

I will simply try to clarify what the debate over climate change is really about. It most certainly is not about whether climate is changing: it always is. It is not about whether CO2 is increasing: it clearly is. It is not about whether the increase in CO2, by itself, will lead to some warming: it should. The debate is simply over the matter of how much warming the increase in CO2 can lead to, and the connection of such warming to the innumerable claimed catastrophes. The evidence is that the increase in CO2 will lead to very little warming, and that the connection of this minimal warming (or even significant warming) to the purported catastrophes is also minimal. The arguments on which the catastrophic claims are made are extremely weak –and commonly acknowledged as such.

In response to scientific projections of likely severe climate impacts of global average temperatures rise, the U.S. signed the1992 United Nations Convention on Climate Change. In 2016 the United States once again joined 197 countries in ratifying the Paris Climate Agreement, an enhancement to help the implementation of that Convention.

The claim that the United States ratified the Paris Climate Agreement is incorrect.  The United States never properly joined the accord.  It is a treaty that requires the advice and consent of the Senate. Instead, President Barack Obama chose to “adopt” it with an executive order.  The Senate never voted on the treaty.

Impacts from Emissions Already Observed in New York’s Climate

New York’s climate has already begun to change, gradually taking on the characteristics of the climate formerly found in locations south of New York. The need for the reduction of CO2 emissions, including through the reduced emissions cap, budget adjustment, and establishment of the ECR, is clearly supported by numerous direct impacts that have been observed in New York State and presented in the 2011 New York State ClimAID assessment and the 2014 update to ClimAID.

The title of this section exposes a significant error in the understanding of the ClimAID assessments.  In particular, those assessments described observed climate trends but did not attempt to attribute how much of the observed trends were linked to GHG emissions, how much were caused by other anthropogenic effects such as land-use changes and the urban heat-island effect, and how much was caused by natural variability.  For example, the observed monthly data source for average temperature and precipitation was the United State Historical Climatology Network and page 21 of the 2011 ClimAID document states that “this data product is not specifically adjusted for urbanization”.  One of the sites used to describe climate trends was at New York City’s Central Park.  Clearly the urban heat-island has a significant effect on temperature at that location.  Therefore, the RIS presumption that the only cause of all the observed trends was GHG emissions over-estimates their role in observed climate change trends.

These include:

  • Temperatures in New York State have risen during the twentieth century, with the greatest warming coming in recent decades – temperatures have risen on average 0.25°F per decade over the past century. This warming includes an increase in the number of extreme hot days (days at or above 90ºF) and a decrease in the number of cold days (days at or below 32ºF).

Because the effect of the urban heat-island is not considered these trends do not represent the trend due solely to the greenhouse effect.

  • Sea level rise. Sea level in the coastal waters of New York State and up the Hudson River has been steadily rising over the twentieth century, chiefly as a result of thermal expansion of ocean waters, melting of land ice and local changes in the height of land relative to the height of the continental land mass. Tide-gauge observations in New York indicate that rates of relative sea level rise were significantly greater than the global mean, ranging from 0.9 to 1.5 inches per decade.

The fact that New York tidal gauge rates of relative sea level rise are greater than the global mean shows that local changes in the height of land relative to the height of the continental land mass are a significant factor of sea-level rise that no amount of change to the greenhouse effect will affect.

 Although the RIS purports to provide current information, consider an alternative assessment of current climate state based on data and not model speculation.  Ole Humlum a former Professor of Physical Geography at the University Centre in Svalbard, Norway, and Emeritus Professor of Physical Geography, University of Oslo, reported “The State of the Climate 2019,” that presents ten key facts in the Executive summary:

“1. According to the [surface] instrumental temperature record (since about 1850), 2019 was a very warm year, but cooler than 2016.

      1. In 2019, the average global air temperature was affected by a moderate El Niño episode, interrupting a gradual global air temperature decrease following the strong 2015–16 El Niño.
      2. Since 1979, lower troposphere temperatures have increased over both land and oceans, but more so over land areas. The possible explanations include insolation, cloud cover and land use. {Caiazza note: if the greenhouse effect were the only cause of the temperature increase then there should be no difference over land vs over water.}
      3. The temperature variations recorded in the lowermost troposphere are generally reflected at higher altitudes too. In the stratosphere, however, a temperature ‘pause’ commenced in around 1995, 5–7 years before a similar temperature ‘pause’ began in the lower troposphere near the planet’s surface. The stratospheric temperature ‘pause’ has now persisted for about 25 years.
      4. The 2015–16 oceanographic El Niño was among the strongest since the beginning of the record in 1950. Considering the entire record, however, recent variations between El Niño and La Niña are not unusual.
      5. Since 2004, when detailed recording of ocean temperatures began, the global oceans above 1900 m depth have, on average, warmed somewhat. The strongest warming (between the surface and 200 m depth) mainly affects the oceans near the Equator, where the incoming solar radiation is at its maximum. In contrast, for the North Atlantic, net cooling at the surface has been pronounced since 2004.
      6. Data from tide gauges all over the world suggest an average global sea-level rise of 1–1.5 mm/year, while the satellite record suggests a rise of about 3.2 mm/year, or more. The noticeable difference in rate (a ratio of at least 1:2) between the two data sets still has no broadly accepted explanation.
      7. Since 1979, Arctic and Antarctic sea-ice extents have had opposite trends, decreasing and increasing, respectively. Superimposed on these overall trends, however, variations of shorter duration are also important in understanding year-to-year variations. In the Arctic, a 5.3-year periodic variation is important, while for the Antarctic a variation of about 4.5-years’ duration is seen. Both these variations reached their minima simultaneously in 2016, which explains the simultaneous minimum in global sea-ice extent. This particularly affected Antarctic sea-ice extent in 2016.
      8. Northern Hemisphere snow cover extent undergoes important local and regional variations from year to year. Since 1972, however, snow extent has been largely stable.
      9. Tropical storms and hurricanes have displayed large annual variations in accumulated cyclone energy (ACE) since 1970, but there has been no overall trend towards either lower or higher activity. The same applies for the number of continental hurricane landfalls in the USA, in a record going back to 1851.”

Future Impacts from Emissions Predicted for New York’s Climate

Predictions of future impacts associated with emissions in New York further support the need for a substantial reduction in the CO2 emissions cap as well as the budget adjustment and ECR, as outlined in the proposed revisions to the Program. The 2011 New York State ClimAid assessment and 2014 update also examined how sea level rise, changes in precipitation patterns, and more frequent severe weather conditions will affect New York’s economy, environment, community life and human health. ClimAID used regionalized climate projections to develop adaptation recommendations and is a climate change preparedness resource for planners, policymakers, and the public. 

The future impacts assessment in the RIS relies on the 2011 New York State ClimAid assessment and 2014 update that examined how sea level rise, changes in precipitation patterns, and more frequent severe weather conditions will affect New York’s economy, environment, community life and human health.  There are three problems with those assessments: reliance on global climate model simulations, the use of Representative Concentration Pathway 8.5, and the use of a regional climate model.

 Climate sensitivity

Predictions of substantial global warming assume that the climate is very sensitive to an increase in GHG concentrations.  The RIS does not recognize that this is an active debate because of climate feedback in various models and that estimates in peer reviewed studies range from 0.8°C warming to almost 6.0°C warming by 2100.  Clearly such a wide range

of uncertainty means climate model temperature projections remain dubious, at best. In my opinion climate sensitivity estimates based on measured data are more likely to be correct than GCM projected estimates and those estimates are invariably on the lower end of the range.  The problem with the GCM estimates is cloud formationFor example, “Given current uncertainties in representing convective precipitation microphysics and the current inability to find a clear observational constraint that favors one version of the authors’ model over the others, the implications of this ability to engineer climate sensitivity need to be considered when estimating the uncertainty in climate projections.”  To be clear, that means that modelers can conjure up whatever warming amount you want simply by tweaking how clouds form in response to the greenhouse effect.

 Emissions RCP 8.5

In order to make a projection for the future it is necessary to not only project the effect of changing GHG concentrations but also project how emissions will change.  The ClimAID assessment presents a range of possible projections but the worst-case impacts rely on a future emissions scenario that was not intended to be plausible. In short, the likelihood of the projected impacts that “make the case” for the proposed revisions are based on an unrealistic emissions scenario.  While it does make for the scary story needed to justify the proposed action, the fact is that it is inappropriate for use as justification for it.

 Regional Climate Model

One problem with a GCM is that in order to calculate the global climate a coarse horizontal grid is needed simply because of computational requirements.  In order to account for New York-specific impacts using a finer grid resolution ClimAID developed a regional climate model.  I believe they used a statistical technique to estimate regional climate impacts.  If that assumption is correct then their results are flawed.  In particular, the GCM gird resolution is so coarse that effects of the Great Lakes are not included.  However, “These techniques assume that the relationship between large scale climate variables (e.g. grid box rainfall and pressure) and the actual rainfall measured at one particular rain gauge will always be the same.”  Given that precipitation downwind of the Great Lakes is strongly influenced by lake-effect snow and rain, the large-scale precipitation estimates that do not include the Great Lakes means that this is clearly not the case.

Future Impacts from Emissions for New York State’s Resource Sectors

I did respond to all the problematic statements in this section.  As shown above there are serious concerns with the primary projections of temperature change.  The secondary projections of impacts to resource sectors is even more speculative especially because the alleged impacts require specific uncertain climatic outcomes.  I highlighted several issues that demonstrate a lack of nuanced understanding of potential climate change impacts.

In the section on Coastal Zones, the RIS states “Superstorm Sandy gained additional strength from unusually warm upper ocean temperatures in the North Atlantic”.  The RIS correctly does not attribute Superstorm Sandy to climate change.  I do not disagree with the claim that the storm could have gained additional strength from unusually warm temperatures.  I do want to point out that these claims point to the most likely long-term impact of anthropogenic climate change, i.e., impacts will be tweaks to the environment and not primary drivers of environmental change. 

In the same section the RIS claims that New York’s shoreline will be adversely affected by climate change: “The major contributor to sea level rise is thermal expansion and melting of glaciers and ice sheets.”  This section concerns Future Impacts from Emissions and therefore it is incompatible with the Impacts from Emissions Already Observed in New York’s Climate discussion of sea level.  As correctly noted in that section “Sea level in the coastal waters of New York State and up the Hudson River has been steadily rising over the twentieth century, chiefly as a result of thermal expansion of ocean waters, melting of land ice and local changes in the height of land relative to the height of the continental land mass. Tide-gauge observations in New York indicate that rates of relative sea level rise were significantly greater than the global mean, ranging from 0.9 to 1.5 inches per decade”.  Because New York tidal gauge rates of relative sea level rise are greater than the global mean shows that local changes in the height of land relative to the height of the continental land mass are a significant factor of sea-level rise that no amount of change to emissions will affect.

In the section on agriculture the RIS notes that “increased summer heat stress will negatively affect cool-season crops and livestock unless farmers take adaptive measures such as shifting to more heat-tolerant crop varieties and improving cooling capacity of livestock facilities”.  Misleadingly, the section then goes on to say “A loss of milk production efficiency from heat effects could result in the loss of hundreds of millions of dollars annually for New York’s dairy industry” based on the following:

“Dairy farmers will also be impacted since milk production is maximized under cooler conditions ranging from 41°F to 68°F. New York is the third largest producer of milk in the United States, behind California and Wisconsin, with 14.9 billion pounds of milk produced in 2017. During the unusually hot summer in 2005, many New York dairy herds reported declines in milk production of five to 15 pounds of milk per cow per day (an eight to 20 percent decrease).”

The average July temperature in Syracuse is 71, Madison WI is 75, and Sacramento, CA is 77, so two states that produce more milk than New York have higher average temperatures.  Additionally, the RIS mistakenly quotes a milk decrease from a weather event to support an alleged climate impact.

In the section on Air Quality and Public Health Benefits the RIS states:

“In addition to contributing to a 50% reduction in CO2 from affected power plants in New York, it is estimated that the RGGI program provided $1.7 billion in avoided public health costs in New York by reducing associated air pollutants. Across the RGGI region, it is estimated that the RGGI program helped avoid 16,000 respiratory illnesses, up to 390 heart attacks, and 300 to 830 deaths.  At a more local level, according to a 2002 study, the expected health benefits of urban air pollution reductions from climate change mitigation strategies in the New York City area (assuming that they produce an approximately 10 percent reduction in PM10 and ozone concentrations), would be to avoid approximately 9,400 premature deaths (including infant deaths), 680,000 asthma attacks, and 12 million restricted activity days.”

I showed in my companion post that the primary reason for the emission reductions was fuel switching from coal and residual oil to natural gas.  That means that the RGGI contribution to those reductions was on the order of 5% and not 50%.  That also means that the avoided health impacts were mostly due to fuel switching and not RGGI. 

A couple of points about health impacts in general and the referenced 2002 study and the potential impacts of a 10% reduction in PM10 and ozone concentrations in particular.  Between 2000 and 2019 Northeast air quality trends show more improvement than a 10% reduction: PM10  is down 39%, PM2.5 is down 47%, ozone is down 24%, and SO2 is down 86%.  Until such time that DEC can reference a study that shows the actual health benefits associated with the observed air quality improvements, I am not confident that their air quality health claim is accurate.  Also note that future air quality impacts will be much smaller because the higher polluting coal and residual oil sources have already been reduced.  CO2 reductions from natural gas firing will not produce as many reductions in PM and Ozone levels and no change in SO2.

Components of the Proposed Program Revisions

One of the problems with New York’s energy policy is demonstrated by this statement: “The reduction in the CO2 emissions cap to approximately align with current levels represents a critical step to combat the significant challenges presented by climate change and to advance sound energy policies that foster energy efficiency, a reduction in reliance on fossil fuels, and energy independence”.   In particular, New York State has not done a holistic analysis of the energy and environmental alternatives proposed to replace fossil fuels.  For example, this proposal is supposed to foster energy independence but in 2019 the United States was energy independent.  New York’s energy plan proposes to rely on renewable energy which will require battery energy storage.  Both technologies rely on rare elements which are not produced in sufficient quantities domestically to cover the requirements of the New York energy transition so we will become less energy independent.  Furthermore, the production of these rare elements is environmentally destructive so the State is merely leaking environmental impacts elsewhere.

Benefits from the Proposed Program Revisions

This section notes: “The most recent version of the New York State Regional Greenhouse Gas Initiative-Funded Programs Status Report for the quarter ending December 31, 2018 estimates cumulative annual customer bill savings of $293 million.”

Unfortunately, in my companion post I showed that as a GHG emission reduction mechanism, New York’s RGGI investments fail to make investments that are less than the purported cost of the negative externalities for a ton of CO2 emitted today (the Social Cost of Carbon (SCC)).  In fact, the cost per ton removed is an order of magnitude larger than the Obama-era SCC value.  Therefore, New York’s investments are woefully cost ineffective which suggests that our resources should be invested in adaptation because we will not be able to afford the costs of mitigation.

There is a paragraph in this section that describes the Climate Act:

Most notably, as described above, the recently-enacted Climate Act establishes Statewide GHG emission reduction requirements and renewable and clean energy generation targets. In particular, ECL Section 75-0107, which was added by the Climate Act, requires a 40 percent reduction in Statewide GHG emissions from 1990 levels by 2030, and an 85 percent reduction from 1990 levels by 2050. Moreover, Public Service Law Section 66-p, which was also added by the Climate Act, establishes a target to generate 70 percent of the State’s electricity from renewable energy sources by 2030, and to generate 100 percent of the State’s electricity from carbon-free sources by 2040. The proposed revisions to the Program, including the additional reduction in the RGGI CO2 emissions cap and the establishment of the ECR, further the objectives of the Climate Act. Finally, the Climate Act also includes multiple provisions that recognize that historically disadvantaged communities often suffer disproportionate and inequitable impacts from climate change. The proposed revisions to the Program to expand its applicability to include certain smaller sources, many of which are located in such communities, are consistent with these provisions of the Climate Act.

This section concludes with claimed benefits of implementing the proposed revisions:

Climate change is a global problem and effective action at the national and international level is necessary in order to stabilize atmospheric GHG concentrations at acceptable levels. Notwithstanding this, particularly given the current federal Administration’s recent actions to slow or rescind various regulatory and other efforts to reduce GHGs nationally, action now at the State and regional level to reduce GHG emissions and to implement the revisions to the Program will benefit and reduce the risk of injury to New York and its citizens and residents from climate change. The risks of injury from a warming climate increase with the rate and magnitude of the warming, and in turn, the rate and magnitude of warming is primarily dependent upon the level of CO2 emissions. In addition, by implementing the proposed revisions to the Program now, New York and the Participating States can:

        • Reduce the long-term costs of addressing climate change. By acting now, states can avoid the need for more disruptive measures later.
            • As noted previously there is no quantitative estimate of the potential reduction of climate change costs that will accrue due to the proposed action.
        • Position the region ahead of competitors. Taking continued action to reduce the region’s carbon-intensity will create a competitive advantage relative to other parts of the country when additional action is taken at the national and international level.
            • The German attempt to implement a similar but much less ambitious GHG emissions program led to massive price increases: “A German online site Stromreportwrites that since the year 2000 the average electricity price for private households has risen from 13.94 to 30.43 euro cents per kilowatt hour (2019)”.  If the cost of electricity is so much higher than elsewhere it will be a competitive dis-advantage.
        • Capture environmental co-benefits. Reducing power sector carbon emissions provides numerous environmental co-benefits, including reduced emissions of other pollutants associated with fossil-based electricity generation. Additionally, co-benefits will continue to be realized by allocating almost 100 percent of the CO2allowances to the EE&CET account to be auctioned by NYSERDA and have the resulting proceeds utilized for the account’s purposes of furthering the GHG emission reduction objectives of the Program.
            • Future environmental co-benefits will be much smaller than in the past simply because future reductions will be displacing natural gas rather than coal and oil. As shown above, NYSERDA’s investments are not cost-effective relative to the Social Cost of Carbon.
        • Drive new technology. By attaching tangible financial value to avoided carbon emissions, the proposed Program revisions provide additional market incentive for developing and deploying new technologies that can increase fuel efficiency, utilize non-carbon resources (including renewable technologies such as wind and solar power), and reduce or eliminate carbon emissions from combustion sources. In addition, to the extent that the auctioning of allowances will spur additional investments in clean energy technologies, the auctions drive the deployment of new technologies in the State.
          • I believe the cost of avoiding carbon emissions is far greater than the cost of RGGI on operations so this will have little effect on new technology.
        • Promote improved supply-side and demand-side efficiency. The proposed Program revisions create a direct incentive to reduce the fossil fuel inputs required to produce electricity through more efficient generating technologies. This is consistent with the Climate Act’s target to obtain 100 percent of the State’s electricity from carbon-free sources by 2040.
            • The NYSERDA investments in demand-side efficiency have provided tangible benefits. If DEC wants to claim supply-side efficiency gains then they should provide examples.
        • Improve the region’s energy security and reduce its exposure to higher energy prices. By creating a market incentive for low-carbon and non-carbon electricity technologies and by promoting increased supply-side and demand-side efficiency, the proposed Program revisions reduce the Northeast’s long-term exposure to high fossil fuel energy prices. Efficiency improvements and advances in new energy technology fostered by the proposed Program revisions can help buffer the region from the considerable economic risks associated with continued dependence on these fuels.
            • If New York truly wants to reduce exposure to higher energy prices then they should embrace natural gas development which has proven to be the leading cause in decreased prices. In spite of New York’s irrational war on natural gas fracking, that technology has been primarily responsible for the observed emission reductions and associated health benefits in the past decade.
        • Stimulate economic development. The proposed Program revisions provide a positive stimulus for economic growth in the region by creating incentives for new technologies that could be developed in-region, promoting a more efficient and cleaner electricity generating sector, prompting other activities through its offsets program and improving efficiency. NYSERDA’s investment of proceeds from the auctioning of allowances provides further economic benefits.
            • The broken window fallacy negates this claim. In the broken window fallacy – money spent on RGGI allowances, for example, is “money that cannot be spent on food, clothing, health care, or other industries. The stimulus felt in one sector of the economy comes at a direct – but hidden – cost to other sectors”.

Conclusion

I recently listened to the June 24 meeting of the New York Climate Action Council Policy in which New York’s climate leaders repeatedly expounded on the importance of science driving New York policy.  However, as the implementation of this regulation shows, it is more about rhetoric than science.  Science-driven policy should consider all possibilities, make a case for the preferred alternative, and not neglect inconvenient aspects of the proposal.  In this instance the RIS claims over-whelming evidence and dismisses legitimate issues.  I showed in the companion post that no case was made for the proposed revision to the regulation to include smaller sources.  The most egregious problem is that New York has never quantified the potential effect of any of their GHG emission reduction regulations.  The suggestion that changing New York’s contributions to global warming due to GHG emissions, even if you accept the consensus science, will have any measurable effect on the list of alleged problems is clearly not likely.  At this time of unprecedented budgetary crisis, the RIS does not make a case to support these revisions and it is entirely appropriate to ask why this regulation is necessary.

[2] Esper, J., R.J.S. Wilson,  D.C. Frank, A. Moberg, H. Wanner, & J. Luterbacher.  2005.  “Climate: past ranges and future changes”.  Quaternary Science Reviews 24: 2164-2166.

[1] This was the total for 2015 NYS emissions in NYSERDA Greenhouse Gas Inventory 1990-2015. Subsequent editions have lowered the most recent total so this is a conservative value for impacts.

 

CLCPA NYS Wind Energy Resource

New York has established energy policy based on conceptions that do not hold up to numerate scrutiny.  This post addresses the idea that New York wind energy can reliably power the electric system and in tandem with solar energy can replace existing generating resources.  In order for the statewide wind energy resource to be considered a reliable source the distribution of wind energy must not include significant periods with low power output.

In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act.

The legislation requires 70% of the generation supplying New York to be renewable in 2030, statewide emissions of greenhouse gas emissions are to be reduced to 60% of 1990 emissions and elimination of fossil-fired electricity production altogether by 2040.  Unfortunately, the politicians that passed this law never bothered to figure out how it could be done.  I have written a series of posts on the feasibility, implications and consequences of this aspect of the law based on evaluation of data.  This post addresses the wind energy resource of New York.

Approach

I used two sources of data from New York Independent System Operator (NYISO).  For an overview I used the annual report that presents load and capacity data including historical and forecast seasonal peak demand, energy usage, and existing and proposed generation and transmission facilities.  The Load and Capacity Date Report or Gold Book is a featured report in the NYISO document library.  This post and a summary I posted in April 2019 use data in Table III-2 Existing Generating Facilities from those reports to describe the annual wind energy resources available.  I used the 2019 wind date from the April 2020 Gold book in this analysis.  Note that in 2019 all wind energy came from on-shore facilities.

The NYISO Real-Time Dashboard includes a window for the real-time fuel mix that includes the amount of wind generation being generated in the state.  The window also includes a link to historical data.  I downloaded data from June 2018 through September 2019, sorted out the wind production numbers, and then calculated hourly averages.  I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses and in this case I loaded the hourly data and calculated frequency distribution statistics.

Results

The New York State Wind Facility Status table lists 2019 wind data from the NYISO 2020 Gold Book for all the New York wind energy facilities.  The NYISO table provides the name plate ratings and 2019 net energy produced.  In 2018 there were 1,982 MW of wind energy nameplate capacity that generated 3,985 GWh of electrical energy for a state-wide annual capacity factor of 24.5%.  Note that there is a wide variation of capacity factors, that the highest is 37.4%.  All the capacity factors greater than 30% are from more recent larger turbines. The Chateaugay Wind Power facility and the Jericho Rise Wind Farm are in the same general area so I expect that the wind resource would be similar.  In 2019 the Chateaugay capacity factor was 21.1% and the Jericho Rise capacity factor was 33.4%.  I believe the main reason for the difference is the size of the turbines – the blade tip height for Jericho Rise is 18.5m (60.7 ft) higher than at Chateaugay. The Chateaugay turbines have a hub height of 80m and a rotor diameter of 77m while the Jericho Rise turbines have a hub height of 80m and a rotor diameter of 114m.  Overall, New York wind facilities only provide a quarter of their name plate capacity.

Another wind-resource issue is the distribution of the hourly output.  The NYS Hourly Wind Frequency Statistics June 2018 through September 2019 document lists frequency distribution data for sixteen months of operations in New York.  The histogram of wind output categories shows that low output is more frequent than high output.  The frequency tabulation for wind table shows that there were 25 hours when none of the 24 wind facilities in the state produced any power and that 36% of the time less than 200 MW per hour was produced.  The probability plot graphically shows the skewed distribution and the percentiles indicate that half the time hourly wind output is less than 324 MW.

If New York has to rely on renewable energy in the future it is important to know the frequency distribution of wind at night.  I addressed this by simply looking only at four hours either side of midnight.  The NYS Night Hourly Wind Frequency Statistics June 2018 through September 2019 document lists the same statistics for this limited data set.  While there are only a couple of hours with no wind output and the frequency of hours with output less than 200 MW was down to 31% there still is a significant number of hours when the lack of solar and low wind output.  That means that energy storage is going to be absolutely necessary.

Another aspect of concern is the duration of low wind periods.  I used the same data format as the wind frequency statistics but only included 2018 data to determine how long light periods lasted – a critical parameter when it comes time to try to rely on wind energy to provide reliable power.  I calculated the length of time the total NYS wind energy resource failed to exceed various thresholds from 100 MW to 600 MW.  The 2018 Total NYS Wind Energy Light Wind Energy Periodss table lists the longest calm periods for each threshold.  For example, the longest period when less than 100 MW of the state’s total wind capacity of 1,982 MW was 58 hours ending on 9/13/2018 at 1800.  In the second section of the table frequencies are listed.  There were 12 periods when less than 100 MW of wind capacity was available for 24 hours, 5 periods for 36 hours, and one period of 48 hours.

Conclusions

Annual capacity factors average 25%.  All the turbines with capacity factors greater than 30% are using turbines that with tip heights greater than 425 ft.  Although that improves performance it also means that there are greater environmental impacts.  I believe we cannot expect much improvement for future on-shore wind development simply because I assume that the best locations have already been developed.

The distribution of hourly wind output was a mild surprise to me because  I did not think it would be as bad as it is.  Advocates for renewable power maintain that it is possible to address the problem of calm winds at one location by simply adding facilities in other locations so that somewhere the wind will be blowing.  If that were the case using New York resources the hourly distribution would not show that 5% of the time the total wind energy production for the entire state was less than 20 MW.  Furthermore, I suspect that even expanding the location of wind facilities to off-shore New York and adjoining jurisdictions is not going to significantly reduce the number of hours when wind resources are going to have to be supported by significant amounts of energy storage.

The fact that night time wind generation also shows significant hours with low levels exacerbates the need for energy storage.  In an earlier post I estimated how much energy storage would be needed for one example period.  These results reinforce my position that New York State has to do a comprehensive analysis of the availability of renewable resources to determine a strategy for meeting demand with an all-renewable system.  Until that is complete we are only guessing whether the ambitious goals of the CLCPA can be met much less how much this is all going to cost.