NY Climate & Community Protection Act – Page 7 – Pragmatic Environmentalist of New York

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

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

On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council. All the speakers but one made the point that today’s renewable energy technology will not be adequate to mantain current reliability standards and that a “yet to be developed technology” will be needed. This post addresses the study that was the basis for the claim by Vote Solar that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” is fatally flawed.

Background

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

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

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

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

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

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

Local Solar Roadmap

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

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

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

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

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

The new, smarter approach is described as follows:

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

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

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

WIS:dom®-P

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

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

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

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

The mathematical formulation of the objective function is:

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

Ultimate Problem

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

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

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

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

Conclusion

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

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

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

Background

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

New York Historical Energy Sources

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

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

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

Conclusion

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

Climate Leadership & Community Protection Act Electric Vehicle Propaganda

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

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

Background

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

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

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

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

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

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

Four Reasons to Consider an Electric Vehicle

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

There’s no denying that over the past several years the demand for electric vehicles (EV) has increased. In New York State, driving electric is a great opportunity for vehicle owners to make a positive environmental impact, lowering their carbon footprint while helping the State reach its ambitious clean energy and climate action goals.
Transportation accounts for 42% of New York State’s greenhouse gas emissions, meaning that every EV that replaces a gas-powered vehicle will help make a difference.
Making the switch to an electric vehicle is a big decision. The more knowledge you have, the more informed your choices will be. If you’re still on the fence about making the switch, here are four additional things to consider:
1: Electric vehicles will save you time and money.
Compared to gasoline-powered cars, EVs are more energy efficient and cost about 50 to 70% less to operate per mile. EV motors don’t need oil changes, you’ll be making fewer visits for regular maintenance and repairs. And since your car will run on electricity, not gas, you won’t need to make trips to the gas station.
2: Electric vehicles are clean, quiet, and fun to drive
There is no loud engine, but electric vehicles deliver fast acceleration and surprising pick up that make them exceptionally fun to drive. EVs also boast a variety of different technological advantages, including the ability to preheat your car without garage emissions, or to turn up the bass on your speakers without engine distortions.
3: There are tax credits and rebates available to help you purchase your EV.
With an electric car charger provided by your vehicle’s manufacturer, you can simply plug into a standard home outlet to charge your car. You can also upgrade your home to a Level 2 charger, which requires an electrician to install but increases the speed of charging up to 10x compared to a standard outlet. And if you need to charge your EV while you’re out and about, rest easy: there are thousands of available charging stations throughout the State that are easy to find through mobile apps and through the NYSERDA website.
4: There are tax credits and rebates that can be put toward purchasing an EV.
Use the Drive Clean Rebate to take up to $2,000 off the price of an electric car at the time of purchase. You can also combine that rebate with the existing federal tax credit for electric cars, which provides up to $7,500 for the purchase of a new electric car.

Discussion

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

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

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

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

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

Conclusion

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

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

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

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

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

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

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

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

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

Background

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

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

Climate Justice Framework

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

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

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

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

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

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

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

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

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

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

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

Working Group Observations on Enabling Initiatives

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

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

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

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

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

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

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

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

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

Response to Transportation Advisory Panel Recommendations

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

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

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

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

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

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

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

Response to Energy Efficiency (EE) and Housing Recommendations

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

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

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

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

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

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

Conclusion

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

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

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

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

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

Climate Leadership & Community Protection Act Heat Pump Propaganda

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

Background

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

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

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

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

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

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

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

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

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

Myth Buster: The Heat Pump Edition

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

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

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

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

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

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

Myth #2: Heat pumps create heat.

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

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

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

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

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

Discussion

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

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

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

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

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

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

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

Conclusion

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

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

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

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

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

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

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

Background

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

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

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

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

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

I received the following response:

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

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

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

Discussion

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

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

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

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

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

Conclusion

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

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

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

Climate Leadership and Community Protection Act Adaptation and Resilience Recommendations

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

Background

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

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

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

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

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

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

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

Adaptation and Resilience Recommendations

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

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

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

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

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

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

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

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

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

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

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

Benefits and impacts

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

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

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

Conclusion

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

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

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

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

Background

According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide. All these recommendations will be incorporated into the integration analysis which is a modeling effort by the State. They will develop the scoping plan that outlines what is needed to meet the law’s requirements. Once the scoping plan is accepted State agencies will implement codes and regulations. My posts describing and commenting on the strategies are all available here.

Although no costs have been provided there have been discussions at Climate Action Council meetings that indicate that the Council is positioning itself to prove that their investments are “cost-effective”.

I will outline how the benefits analysis should be calculated and how the state is doing it.

Emissions

The first step is to define the emissions. The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations. GHG emission inventories have been developed for many years. Prior to the CLCPA New York State followed the Inter-governmental Panel on Climate Change guidelines. It makes a lot of sense to use those guidelines for consistency and inter-comparability. However, the authors of the CLCPA chose to do things differently

According to the Revised Regulatory Impact Statement (RIS):

Under the CLCPA, statewide greenhouse gas emissions include both greenhouse gas emissions from all sources located within the state and certain sources that are located outside of the state that are associated with in-state energy consumption. In particular, the statute requires that statewide greenhouse emissions include both: (1) “the total annual emissions of greenhouse gases produced within the state from anthropogenic sources,” and (2) “greenhouse gases produced outside of the state that are associated with [a] the generation of electricity imported into the state and [b] the extraction and transmission of fossil fuels imported into the state.” ECL § 75-0101(13). Moreover, the CLCPA defines “carbon dioxide equivalent” as a measurement of global warming potential based on a twenty-year timeframe. ECL § 75-0101(2).

The RIS goes on to explain:

The Energy sector includes five (5) main categories: (a) Fuel Combustion, (b) Fugitive Emissions, (c) Electricity Transmission, (d) Imported Fuels, and (e) Imported Electricity. The latter two categories are not included in IPCC protocol or other governmental greenhouse gas inventories, but as described above are two key distinct requirements of the CLCPA for this rulemaking. These two categories represent an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption.

The RIS explains the inclusion of a category for imported fuels:

The most significant difference between the 1990 baseline, as set forth in the CLCPA and developed for the proposed rule, and other governmental greenhouse gas inventories is the inclusion of emissions associated with “the extraction and transmission” of imported fossil fuels. Because of the novel nature of this CLCPA requirement, as compared to other standard governmental inventories following the IPCC protocol, the Department undertook an analysis of these emissions in collaboration with NYSERDA. This analysis considered emissions from extraction and processing (production) through transmission or transportation to the New York border, but did not include emissions from infrastructure construction and maintenance outside of the state or from the manufacture of equipment or facilities outside of the state. The fuels included are the same as those addressed in the in-state analysis, or coal, natural gas, distillate, diesel, residual fuel, jet fuel, kerosene, LPG, motor gasoline, and other petroleum fuels (lubricants, petroleum coke, and unspecified napthas).

The inclusion of these two categories adds to the baseline and any reduction benefits are increased. Importantly, note that the lifecycle, fuel cycle, or out-of-state upstream emissions associated with wind and solar energy development are not included in any state analysis.

Value of Carbon

In section §75-0113, Value of Carbon the CLCPA 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” and that “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 total monetary estimate of not emitting NY’s 1990 emissions is shown here for different years. We don’t know when the emissions occurred or will occur so we need to consider a range. If every ton is reduced in 2021, the value of carbon benefits at a 2% discount rate is $681,266 million. If every ton is reduced in 2050, the value of carbon benefits at a 2% discount rate is $1,115,104 million.

Games New York Plays

In late February, 2021 I wrote to DEC and Climate Action Council about a problem with the New York State guidance document Establishing a Value of Carbon, Guidelines for Use by State Agencies (the “Guidance”). In particular the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal. I believe that the guidance approach is wrong because it applies the social cost multiple times for an emission reduction. I recommended that the Guidance be revised.

In the Guidance section entitled “Estimating the emission reduction benefits of a plan or goal” an example is included:

The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $127 per metric ton. The value of the reductions in 2021 are equal to $127 times 5,000 metric tons, or $635,000; in 2022 $129 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.

The Integrated Working Group (IWG) damages approach value is the net present benefit of reducing carbon dioxide emissions by one ton. The calculation methodology determines that value from the year of the reduction out to 2300. It is inappropriate to claim the benefits of the annual reduction over any lifetime. Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $127 or $6,350,000, but the guidance approach estimates a value of $37,715,000 using this methodology.

I also argued that if 1990 emissions were reduced in 2021 the benefits of completely eliminating those emissions equals $681 billion. If we assume that the emissions are reduced to zero in 2050 by reducing emissions each year by the same amount, the annual reduction times that year’s social cost sums to $886 billion. However, if the social costs are multiplied by the cumulative reductions the costs sum to $15,373 billion, nearly twice as much as summing the annual reduction values. Furthermore, the cumulative reduction approach is over 23 times higher than if the reductions were all achieved in one year. My final argument that it is inappropriate is: if the social costs were calculated out to 2300, then when do you stop calculating cumulative reductions for the social cost benefits for permanently retiring a source of greenhouse gas emissions?

New York’s record using this approach goes back to 2020. The 2010 Climate Action Plan interim report calculated the cost per avoided emissions using cumulative emission reductions. The Regional Greenhouse Gas Initiative (RGGI) and the New York State Energy Research & Development Authority (NYSERDA) reports on the investment proceeds from the RGGI tax both improperly use cumulative emission reductions. The NYSERDA Clean Energy Dashboard also highlights values using cumulative emission reductions. By the way I have submitted comments regarding this issue to RGGI and NYSERDA and no changes have been made to the reports.

Conclusion

The use of cumulative emission reductions to claim more benefits is a common New York practice. New York should include annual reductions in all its GHG emission reduction reports but does not. All emission reduction targets are set based on emissions at a certain time and never include cumulative values. Social cost of carbon or other carbon reduction valuation schemes also consider reductions at a certain time and exclude cumulative values. I have raised this issue with New York State agencies and aside from a “thank you we will look into it” from DEC there has been no response.

When the inevitable high costs of CLCPA implementation are released to the public, they will no doubt be couched in some sort of value of carbon benefit comparison. Obviously, the fundamental problem is that the costs will be real and the benefits will be made up. This post shows that even the contrived value of carbon arguments are insufficient, that the CLCPA mandates emission categories contrived to increase emissions, and that the state has systematically over-estimated GHG emission reduction benefits in this context for years.

Summary of Enabling Strategies Submitted to the Climate Action Council

According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration for the Scoping Plan that will be used to achieve the necessary greenhouse gas (GHG) emissions reductions economy-wide. Advisory panels were created to develop recommendations for the Scoping Plan and made presentations at the April 12, 2021 Meeting and the May 10, 2021 Meeting and recordings of the presentations are available. I provide links to all those recommendations and my posts describing them here. The following summarizes what has been suggested.

In the past month or so the same politicians who managed to foist the CLCPA upon the citizens of New York advocated for the Climate and Community Investment Act (CCIA) which was intended to provide funding to support the CLCPA implementation efforts. I wrote several posts on the legislation and talked to my local assemblyman’s office about my concerns. In that conversation a WHAM report that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon was mentioned as the main reason the assemblyman was not supporting the legislation.

The costs for the enabling strategies are not known but it will be expensive so this is going to prove very unpopular based on the response to the CCIA. The Transportation Advisory Panel proposed a strategy to transition to 100% zero-emission light duty vehicle sales which I believe mandate that all light-duty vehicles sold starting in 2035 have to be electric. The panel claims that by 2028 electric vehicles (EVs) will be comparable in cost to an internal combustion engine. Of course, all the infrastructure to support EVs in public ($1 billion to the utilities so far) will have to be covered, homeowners who purchase the vehicles will have to purchase at home charging support, and when every home has an EV the local electrical distribution systems will have to be upgraded as I discussed in my comments on the transportation panel strategies.

The energy efficiency and housing advisory panel sector emissions were the highest of any sector. As a result, the primary mitigation strategy is to phase out fossil fuel use in buildings. A primary enabling strategy is to change codes and standards as shown in the following slide. The plan is to amend the state codes for new construction, including additions and alterations, to require a plethora of specific requirements including solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness. They propose to adopt these all-electric state codes for single family residences by 2025. Note that a homeowner that chooses to an addition or alteration could be covered by the same requirements. In 2030, gas/oil replacements will be prohibited when heating and hot water systems have to be replaced in homes and in 2035 electric stoves and driers are mandated replacements. I expect that there is a requirement that when a house is sold after 2030 that it will have to be all-electric. If you prefer to use natural gas for home heating, hot water, and cooking you will not have that choice.

The presentation notes that “Resilience is of critical importance”. There is a major disconnect between the advisory panel and the public in this regard. For the public, a slogan does not keep the house warm. In the event of extreme weather such as an ice storm many people had experience surviving because of fossil fuel options. I doubt the public will willingly give up the resilient capabilities of natural gas and fuel oil for heating. I described these issues in more detail in this post.

The Land Use & Local Government Advisory Panel proposed a theme facilitating “responsible siting and adoption of clean energy sources” apparently oblivious to the fact that clean energy siting requires much more land than available at any of the priority development areas simply because wind and solar energy are diffuse and require large areas to collect it. The Agriculture and Forestry Advisory Panel proposed enabling strategies to avoid forest conversion and avoid agricultural land conversion because of the role of forests and farmlands in sequestering carbon. There is no recognition or plan to address the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last state impact statement that evaluated wind energy cumulative impacts. Note that there are less than 2,000 MW of wind turbines today. Responsible siting, minimizing conversion of sequestration land, and reducing cumulative impacts of thousands of turbines while developing the thousands of wind turbines is a significant challenge.

The waste advisory panel recommendations illustrate one overarching problem with these panels. In light of the critical need for firm, zero-emissions resources and the fact that the methane emissions from municipal solid waste landfills, digesters at water resource recovery facilities, livestock farms, food production facilities and organic waste management operations are a major percentage of the total emissions, it only seems logical to address both problems by collecting and using that gas. However, as I showed in my analysis of the waste strategies, there are passionate ideologues involved that don’t agree. The meeting minutes note “concern regarding renewable natural gas, suggesting that there is a limited opportunity for it to contribute to Climate Act goals and believes that efforts in this area benefit the source without contributing additional environmental benefits”. Another member “expressed his concerns about how to move ahead with biogas if it is combusted as this would clearly increase net co-pollutants locally, and suggested the Council consider applications for biogas that would not be combusted (such as fuel cell technology at wastewater treatment plants)”.

The Energy-Intensive and Trade-Exposed Industries Advisory Panel illustrates a less-than flattering aspect of the CLCPA. The strategies for the small and declining industrial, mining, and manufacturing sector were described as “heterogeneous”. This means that there are many different sources so economy of scale is not going to reduce costs. Clearly New York’s unilateral transition off fossil fuels will increase relative energy costs relative to other jurisdictions and industries will have to leave to survive. They conclude that this sector needs currently unavailable solutions to produce emission reductions and remain viable within the state. It seems pretty obvious that this advisory panel was included as a political ploy to placate the industrial sector. Unfortunately, there is not much that can be done to reduce emissions significantly or prevent the remaining industries from fleeing the state out of necessity.

The Power Generation advisory panel is arguably the most important because in order to meet the targets all the other sectors will have to be electrified. The recommendations are available in a slide presentation. I did a review of final recommendations, and, because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations. At the start of the process, I also posted on the membership of this panel. The Albany politicians who nominated the members of the panel chose people whose ideological agendas are aligned with the CLCPA presumption that the transition away from fossil fuels is simply a matter of political will. As a result, they included enabling strategies for the process of, for example, developing off-shore wind, but the related strategy did not include costs for actually developing offshore wind facilities or offer enabling strategies for it.

The ultimate problem replacing fossil fuels with renewable wind and solar energy is providing power during periods when both renewable resources are near zero. In their presentation to the Power Generation Advisory Panel on September 16, 2020, E3 included the following slide that notes that illustrates the winter doldrum issue. Incredibly, the panel recommendations did not specifically address this issue.

Conclusion

This post highlights some of the aspects of the enabling strategies needed to meet the CLCPA emission reduction targets that I believe the general public does not know are headed their way. Given the constant harping from politicians and the media about the existential threat of climate change many might believe implementing this law is appropriate. However, the question is just how much is the public willing to pay and how many limitations on personal choice will they accept?

All these recommendations will be incorporated into the integration analysis modeling effort by the State. Technical staff at the agencies will develop the scoping plan that outlines what is needed to meet the law’s requirements and maintain reliability. The scoping plan goes to the Climate Action Council for review and comment and the public even gets a chance to respond. Once the scoping plan is accepted State agencies will implement codes and regulations. The proponents of the CLCPA are convinced that they have broad public support for these changes in personal choice and the inevitable higher prices.

This year’s CCIA legislation was intended to cover CLCPA implementation costs and the thought that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon apparently was too much to bear. Those costs are a fraction of the CLCPA costs. The proposed enabling strategy for residential home heating mandates that all new homes built after 2025 be all-electric and that when fossil appliances have to be replaced after 2030 that they be replaced by electric alternatives that the public will have to cover. All new light-duty vehicles sold in 2035 will be electric. In order to transition the electric grid Kevin Kilty points out “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.” New Yorkers need to wake up and ask for the costs of this legislation sooner rather than later.

Power Generation Advisory Panel Enabling Strategies Submitted to Climate Action Council

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

Power Generation Emissions

Although the presentations all follow the same format the details differ. One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050. A constant theme with this panel compared to others is a lack of critical information for stakeholders trying to understand their recommendations. The ultimate reason for the recommendations is for emission reductions and this presentation does not provide all the numbers whereas most of the presentations included the values for each year.

The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector. In the following graph I estimate that the 1990 emissions are 100 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 60 MMt.

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050. The slide provides the percentage reductions so that the emissions can be estimated. The projected total reductions emission reduction goals for this advisory panel are a 71% reduction from 1990 by 2030 and a reduction of 95% by 2050. However, the power generation sector has its own goals: 70% renewable energy by 2030 and 100% carbon-free electricity by 2040. No documentation is provided to substantiate the claim that 70% renewable energy is equivalent a 50% reduction from the 2018 levels.

The power generation sector was the third largest source of greenhouse gas (GHG) emissions in 2018. Direct combustion emissions accounted for 57% of the total, imported fossil fuel 28%, oil and gas methane leakage 15%. The inclusion of emissions by imported fossil fuels and leakage is mandated by law, ECL § 75-0101(13). These two categories represent an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption. However, these sectors are not included in internationally accepted emission inventory procedures. I am working on a post that addresses this issue specifically.

Power Generation Strategies

According to the meeting presentation, the advisory panel proposed fourteen enabling strategies:

1 Growth of Large-Scale Renewable Energy Generation

2 Clean Energy Siting & Community Acceptance

3 Distributed Generation / Distributed Energy Resources

4 Existing Storage Technology

5 Demand Side

6 Reliability for the future grid

7 Access and Affordability for All

8 Workforce Development

9 Market Solutions

10 Technology Solutions

11 Long Duration Storage Technology

12 Energy Delivery & Hosting Capacity

13 Gas Infrastructure, Transmission & Methane Leakage

14 Retirement of Fossil Fuel-Fired Facilities

The recommendations are available in a slide presentation. I am not going to critique each of these strategies individually because it would take far too long. Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues. Because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations. I will also compare the proposed strategies to the draft strategies.

In September 2020 I also posted on the membership of this panel. That post describes how this process was supposed to work. I also described the background of the panel members. I noted the members were mostly aligned with the ideological agenda of the Cuomo Administration rather than maintaining an affordable and reliable power generation system. Sadly, the events of the last six months or so exceeded my expectations. In order to make power generation recommendations it is necessary to understand how the power system works and how planning affects reliability and affordability. Many of the members did not want to understand and did not try to understand the technological challenges. Unfortunately, they were the loudest voices and their naïve insistence on speculative technologies has resulted in some risky enabling initiatives.

Discussion

One of the good things that this presentation did include were the category definitions. Each mitigation strategy describes the potential effect of the strategy on GHG reductions by 2030, cost and funding expectations, and ease of implementation in three categories: low, medium and high. The following tables define what they mean by low, medium and high. This panel and the Energy Efficiency & Housing panel were the only ones to include these definitions and I note that there are subtle differences between them. For example, the Power Generation panel defines the low mitigation strategy cost as <$250M total resource cost and most resources required for successful implementation are already on hand. The other panel uses the same definitions but expresses the value as “equivalent annualized cost”.

I appreciate the inclusion of these definitions. However, I don’t think some of the category definitions for the enabling initiatives are correct. In particular, Initiative #1, Growth of Large-Scale Renewable Energy Generation states that the cost and funding considerations are $, <$250 million total resource cost for NYSERDA’s existing Tier 1, Tier 4, and offshore wind programs. The only way those estimates can be correct is if they are referring only to the process for growing large-scale renewable generation.

The New York State Energy Research & Development Authority (NYSERDA) offshore wind website notes that the State’s five currently planned offshore wind projects total 4,300 MW. The US Energy Information Administration (EIA) regularly assesses the levelized costs of all power sources, and only a year ago calculated that the cost of offshore wind was $115.04/MWh. EIA claims a capacity factor of 45% which means that the 4,300 MW will generate 16,950,600 MWh. Using the EIA levelized cost of electricity, see below, with that amount of generation yields $1.9 billion for the 4,300 MW of offshore wind. Something else to keep in mind is that this projection does not include costs on the wholesale market, capacity market, or impacts on balancing and ancillary service markets which all add to the cost. The biggest concern is providing power when the wind is not blowing. It is hard to imagine how the authors of this slide managed to estimate that these costs would be less than $250 million unless they were only talking the process. Then the question becomes where the heck do these costs show up in the recommendations.

Reliability

In general, the greatest threat to grid reliability is the transition away from fossil-fired power plants that provide dispatchable electricity whenever needed to intermittent and diffuse generation from wind and solar. Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems associated with this transition. In this post I am only going to address two CLCPA aspects.

The final recommendations to the Climate Action Council at least emphasized the need to maintain reliability. Incredibly, the first presentation from the Climate Action Council on the advisory panels did not mention reliability. There are extensive electric system reliability requirements in place and despite numerous requests, no presentation on New York’s requirements was provided to this panel.

Moreover, enabling initiative #6, reliability for the future grid, misses the point. As shown in the following description the cost and ease of implementation refer to the process for maintaining reliability, not the difficulty of making the changes needed to make the system reliable. For example, in August 2019 there was a blackout in England. Initially triggered by a lightning strike followed by “Two almost simultaneous unexpected power losses” from an offshore wind farm and a gas-fired power plant resulted in a “cumulative level of power loss greater than the level required to be secured by the Security Standards” and the blackout ensued. My point is that as the system transitions to renewables I expect this kind of trial and error de-bugging of the system reliant on intermittent renewable energy. For example, the North Park Solar proposal calls for a facility with up to 450 MW of solar panels covering 2500 acres. What happens on a partly cloudy day when the incident solar radiation varies wildly? Could that trigger an unexpected power loss?

A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support services. Earlier this year I wrote that no one seemed to want to take the responsibility to figure out was is needed to provide that support.

Enabling initiative #9, Market solutions, is the only place in the recommendations where ancillary services is mentioned. Similar to the problem for the reliability initiative, this recommendation discusses the market mechanisms rather than the problem itself. The responsibility for the initiative is on the New York Independent System Operator (NYISO). The barriers to success note that this “Will require several forward-looking market designs and the implementation of each design must be structured in a way that sends the correct price signal at the appropriate time”. This panel unloads all the responsibilities onto the NYISO. Not only do they have to anticipate all the potential issues in an unprecedented system reliant on asynchronous generation but also have to create a market mechanism to get market participants to invest in that technology. This is another trial-and-error exercise where the rate-payers of the state are lab rats.

Feasibility

I have always maintained that the fundamental flaw of the CLCPA is that it assumed it was only a matter of political will to completely transform the existing electrical system to one dependent upon renewable energy. Clearly, it would be appropriate to define affordability and reliability metrics then do a comprehensive analysis to determine if the transition would threaten those metrics. The following tables list the ease of implementation descriptions for all 14 enabling strategies.

There are three easy to implement strategies: Reliability for the future grid, Workforce Development, and Gas Infrastructure, Transmission & Methane Leakage. These strategies are supposed to have been implemented many times and/or can build off an existing NYS program, rely on Proven and widely available technology, and the key stakeholders are strong supporters, there were no strong opponents. However, recall that the reliability strategy was more about the mechanics of assessing reliability than actually addressing the problem. It is ludicrous for this panel to claim reliability for a wind and solar dependent electric generation system will be “easy”.

Most of the strategies had a medium ease of implementation defined as: strategy is new to New York State but has been successfully implemented in other comparable states/countries, proven technology with known GHG impact, but still small-scale, and key stakeholders are neutral, or balanced mix of supporters and opponents. I think the biases of the panel members and their lack of technical backgrounds impact these ease of implementation estimates. Consider the medium label for existing storage technology. Despite all the fawning reports over Tesla’s utility-scale batteries, the press and this panel has not picked up on how they are being used. The Australian Hornsdale Power Reserve battery system is making money for the operators and saving consumers money by providing frequency control ancillary support services. It is not being used to provide meaningful energy storage for the system. As a result I argue that claiming that utility-scale energy storage has been successfully implemented is dubious at best.

There are three initiatives that even this panel had to conclude would be hard to implement: long duration storage technology, energy delivery & hosting capacity, and retirement of fossil fuel-fired facilities. I believe that both existing and long duration energy storage technologies should be difficult. A recent article by Kevin Kilty “Why is Energy so Difficult to Store? Why is Stored Energy so Difficult to Use?” described the generic problems with energy storage systems. He concluded that “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.” Long-duration storage is necessary so depending upon a technology that does not even exist in a pilot project is an incredible risk.

Energy delivery & hosting capacity refers to “planning and implementation processes to facilitate necessary energy delivery options for the renewable energy buildout”. Like all the other strategies by this panel it is presumed that there are no technical challenges to accomplish this. In fact, this reads like a wish list for the renewable energy developers on the panel.

Retirement of fossil fuel-fired facilities engendered a non-consensus recommendation with majority support: “temporary moratorium on new or repowered fossil fuel-fired facilities until the full recommendation is adopted”. The strategy description is to develop a plan and implement regulations to phase out fossil fuel-fired baseload and peaking generation resources as quickly as practicable while retaining system reliability by prioritizing efforts to lower emissions of co-pollutants in disadvantaged and environmental justice communities. The current cause célèbre amongst environmental justice activists are power plants in disadvantaged communities because they just have to be causing health problems due to ozone and inhalable particulates. The problem is that those are both secondary pollutants and form long after the precursor pollutants are emitted so any health effects are not due to neighborhood power plants. The mitigating solution to this non-problem: “The recommendations from the Power Generation Advisory Panel focus on enabling strategies to assist in the transition away from fossil fuels. These include strategies to more rapidly deploy renewable technologies, including flexible resources, addressing barriers to renewables deployment, transmission and distribution upgrades, developing and deploying technology innovations, encouraging effective market structures, and ensuring a just and equitable transition.” As near as I can interpret this, there is absolutely no inkling that there might be technological and physical barriers that could preclude any of these enabling strategies.

Affordability

The panel covers affordability with its own enabling initiative. I find it rich that the panel presumes that Federal Relief Funds should be used first. The problem is that similar efforts elsewhere have markedly increased costs. According to Germany’s Enegiewende program, the share of renewables in electricity generation should reach 45 percent by 2030 and 100% by half century. The costs have sky rocketed and now German electricity prices are three times higher than France. The Global Warming Policy Foundation has analyzed the cost of Great Britain’s net-zero programs concluding that astronomical cost burden risks are becoming a “toxic issue” for the government. If CLCPA proponents could point to a single jurisdiction with high renewable energy use that did not experience a marked increase in costs, then I would not believe this is an insurmountable problem.

Conclusion

Two things about this advisory panel. It is arguably the most import panel because achieving CLCPA will only be possible if zero-emission electric power is available. It was inarguably the worst run panel by far. John Rhodes “leadership“ was abysmal and by the time he retired the damage had been done. A leader would have steered discussions to achievable solutions that could maintain current levels of reliability and affordability. What happened is that the loudest voices in the room drove the recommendations and discussions. As David Zaruk, who writes at the Risk Monger blog, explains those voices are: “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”. Rather than trying to understand the technological challenges these idealogues made recommendations for processes that would enable what they believe only requires political will. “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong.”– Thomas Sowell