Climate Leadership and Community Protection Act Unpublished Letter to the Editor of the Syracuse Post Standard

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The subject of this post is an unpublished letter to the editor of the Syracuse Post Standard.

The CLCPA was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation but there is one massive flaw.  The lawmakers who enacted this law presumed that the transition of the state’s energy system could be implemented by political will so did not include feasibility conditions in the targets or schedules.  As a result, I believe the reliability and affordability of electricity will be affected.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in long posts on implementation of the CLCPA because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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 CLCPA is going to radically change New York’s energy use in order to reach net-zero greenhouse gas emissions by 2050.  Over the past year, the implementation process has started and I am convinced that most New Yorkers have no clue what is coming so I have been trying to get the local newspaper to print a letter to the editor.

Last fall I submitted a couple of letters specifically arguing that it should be a consideration when voting.  In early January I sent the following commentary, a longer letter to the editor, to the Syracuse Post Standard describing what is coming in an effort to get more people aware of the law.  In my cover letter I offered to discuss the law with the editorial board.  Around the same time, the newspaper sent out an email asking for reader input.  I responded to that too.  The answer in all cases was crickets.

Hyperlinked Submittal – The following is a hyperlinked version of my submittal

New York’s Climate Leadership and Community Protection Act (CLCPA) became effective this year and the implementation process has started. Political appointees on the Climate Action Council and seven advisory panels are currently developing a scoping plan that outlines strategies for attaining the statewide greenhouse gas emissions targets of a 40% reduction of 1990 emissions by 2030 and a zero-emission electric sector by 2040.  The Department of Environmental Conservation (DEC) implemented two regulations supporting the CLCPA implementation late last year.

Only now is it becoming clear what this will mean to the residents of New York but I believe most people have no idea what is coming.  If you are worried about energy affordability and reliability, I recommend that you pay attention in the next several months as the plans to electrify as much of the economy as possible using mostly solar and wind are presented.

DEC implemented a rule setting the 1990 baseline and established a value of greenhouse gas emissions.  Following the precedent set by the CLCPA, the rules follow methodologies established by the Intergovernmental Panel on Climate Change (IPCC) where convenient but veer away when doing so suits the agenda.  In particular, the law and these rules intend to eliminate the use of fossil fuels as soon as possible.  When you hear the phrase no new fossil fuel infrastructure that means you won’t be able to buy gasoline or diesel vehicles by 2035 or heat your homes and water or cook with natural gas, oil, or propane in the same time frame.

By the end of 2024, DEC will promulgate rules and regulations to ensure compliance with the CLCPA targets.  Great Britain has similar targets and has proposed bans on fossil fuel heating systems in 2033 thereby mandating electrifying heating.  There also is a recommendation that properties cannot be sold unless they meet minimum energy efficiency standards in 2028.  To ensure compliance New York will have to do something similar.  Having lived through a couple of multi-day electric blackouts I am very leery about having to depend upon electricity to heat my home.  Despite significant investments in insulation and upgraded windows, my house is still uncomfortable at times during the winter.  I don’t think an electric heat pump is going to be able to adequately heat my home.

You will be told that this will be cost effective because it reduces the negative costs of climate change as established by their value of carbon guidance.  You probably won’t hear that the purported social benefits are based on impacts projected out to 2300, the benefits will accrue almost entirely outside of New York, and that even those benefits are highly dependent upon the assumptions made.  In every instance the values chosen maximize the alleged benefits to reduce carbon emissions.

You might hear that the State has done a wonderful job investing the proceeds from the existing Regional Greenhouse Gas Initiative program that already taxes your electricity.  You won’t hear that New York has the highest administrative costs of any state in the program and you won’t hear that the overall costs per ton reduced exceed the value of carbon benefits.  I am positive you won’t be told that after New York makes all those reductions that the global temperature will be reduced by less than the average temperature between your head and your feet.

I recommend Bjorn Lomborg’s recent book “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet”.  He shows that we are committing to try to solve climate change with policies that he demonstrates will not make much of a difference but will cost a lot and not do much to change global warming.  Moreover, “Our extraordinary focus on climate also means we have less time, money and attention to spend on other problems” and lists a host of ways the time and money could be better spent.  All his lessons are relevant to New York.

I am sure everyone agrees that if we could ensure better weather that we would be willing to spend more on energy, accept some inconveniences, and agree to fewer choices for energy systems.  However, the CLCPA will not solve global warming if only because the increases in emissions in developing countries are far greater than reductions we can meet.  How much people are willing to pay to try to set an example is a personal choice but many people are already having trouble paying for energy so this law must make affordability a primary condition.  Despite the claims of the renewable energy developers there are serious issues using solar and wind during a multi-day, light wind period in New York’s winters.  Finally, New York’s record for greenhouse gas emission reductions is not cost-effective relative to their benefits standard.  This all means that New York might better invest money in adapting to extreme weather, improving energy efficiency, and researching alternatives to fossil fuels that could bring down the costs.

Conclusion

I am disappointed that the Syracuse Post Standard chose to not publish this.  I think New Yorkers should be aware of the potential impact of the CLCPA on affordability and reliability as I outlines in this commentary.   None of the advisory panel strategies have included potential costs but I have no doubts that the costs will be extraordinary.  Keep in mind that all this was written before the Texas Energy Debacle showed what can happen if reliability is not adequately addressed.  I wrote that I don’t think something similar could happen in New York but I also am worried that serious challenges must be overcome to make a reliable system sufficiently robust to meet a similar extreme weather event and that meets the CLCPA mandates.

I encourage New York readers to follow the CLCPA and get involved.

Announcing the Pragmatic Environmentalist of New York Facebook Page

In response to suggestions from people that I respect, I am going to publicize articles that are of general interest on my Pragmatic Environmentalist of New York blog.  People need to be made aware of the implications of New York energy and environmental policy.  This article announces this initiative and serves as a test of the methodology.

Disclaimer

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on environmental impacts.  Over that time, I have dealt with a wide range of environmental issues and researched many relevant topics to New York’s environmental and energy sectors.  The opinions expressed in my blog articles do not reflect the position of any of my previous employers or any other company I have been associated with, the comments are mine alone.

My blog describes environmental issues from a pragmatic viewpoint.  Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues.  Unfortunately, public perception is too often driven by scary one-sided stories that have to be rebutted by getting into details.  This blog will attempt to show the side of environmental issues that gets overlooked too often. My background as a scientist and my responsibilities to provide technical comments on new or revised regulations means that I tend to get bogged down in technical details that are, too be kind, pretty wonky.  I will not announce all the articles that I publish but will alert interested people on topics of general interest that do not delve into all the technical details.

Recent Posts of Interest

The following recent posts would have been announced on the Facebook page if it had been set up.  The Climate Leadership and Community Protection Act (CLCPA)

PEONY Organization

Posts on the Pragmatic Environmentalist of New York blog are classified into different categories as summarized below.  Clicking on the link in each category will take you to all relevant posts in that category.

Pragmatic Environmentalist of New York Principles

Pragmatic environmentalism balances environmental impact and public policy risks and costs.  I believe that pragmatic environmentalism is exemplified by these principles.

RGGI Posts

This page lists my posts on the Regional Greenhouse Gas Initiative (RGGI).   I have been involved in the RGGI program process since its inception and I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program.  Before retirement from a non-regulated generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance.  As a result, I have a niche understanding of the information necessary to critique RGGI.

New York Climate Leadership and Community Protection Act

In July 2019 Governor Cuomo signed the Climate Leadership and Community Protection Act which is described as the “most aggressive climate law in the United States”.   This is a huge effort and will affect every New Yorker but I don’t think many people are aware of its existence much less its potential impacts.  The following posts describe various aspects of the law.

CLCPA Overview

These posts generally describe the CLCPA and its benefits.

CLCPA Feasibility

This law does not provide for an analysis to determine if it can be implemented affordably and with no impact on reliability.  Suffice to say that the lack of a feasibility study before picking the emission reduction and renewable energy targets makes for a target rich environment.

CLCPA Costs

This page summarizes the results of my calculations of the observed costs of the environmental initiatives of New York Governor Andrew Cuomo in general and the Climate Leadership and Community Protection Act in particular.  I also provide links to estimates by others outside the Administration as I find them.

CLCPA Supporting Regulations

The CLCPA mandates regulations to support the implementation of the law.  This page provides links to my posts on those regulations.

CLCPA Scoping Plan Strategies

This page describes the implementation strategies proposed by the Climate Action Council advisory panels.

CLCPA Weather vs. Climate

The difference between weather and climate is constantly mistaken by Climate Leadership and Community Protection Act (CLCPA) advocates.  This page references my evaluations of climatic effects that turned out to be weather events and examples by other authors.

CLCPA Meeting Summaries

This page provides links to Climate Action Council and advisory panel meetings.

CLCPA Comments Submitted

This page provides links to the comments I submitted.

Accelerated Energy Growth and Community Benefit Act

This legislation provides expedited permitting for CLCPA renewable energy developments.

NYS Carbon Pricing Initiative Page

The New York Independent System Operator (NYISO) has been evaluating a carbon pricing plan for New York’s electricity market.  This page covers that initiative and other similar proposals.  My background with trading programs and the electric industry has prompted me to delve into the details of this plan.

New York Energy Policy

There is a movement underway to transform the New York State electric energy system because we have to do something about climate change.  I am motivated to prepare blog posts on this topic so that there is at least one voice of the unaffiliated public whose primary interest is keeping the electric energy system as resilient and affordable as it is currently.

New York State Environmental Policy

New York environmental policy is too often driven by ideology and not science.  These posts address example policies that are not a pragmatic balance of risks and benefits.

Global Warming

As a meteorologist I have the background, education and experience to have what I think is a learned opinion on the risk of global warming.  These posts address the science of global warming.

Transportation and Climate Page

This page lists posts on transportation initiatives related to climate including those published at Watts Up with That.

Personal Comment Submittals

This page lists posts on this blog that describe and archive my public submittals to various regulatory agencies.

 Air Quality

My niche experience is air quality meteorology.  These posts address particular topics in that realm.

Reforming the Energy Vision

New York energy policy is too often about style rather than substance.  Reforming the Energy Vision (REV) is the Cuomo label for clean and green energy policies.  In 2018 I started a blog to address specific REV topics but the fast-changing political label game has mixed these efforts up with the CLCPA.  This category link is to my other blog.

New York Green New Deal Page

On January 15, 2019 New York State Governor Andrew M. Cuomo did his State of the State Address that included his version of the Green New Deal environmental agenda.  Incredibly, in July 2019 the NYS Legislature promulgated an even more ambitious law, the Climate Leadership and Community Protection Act, that he signed into law.  As a result, these posts are not the drivers of NY energy policy that I thought they would be.  This page is no longer being updated.

National Grid Northeast 80 by 50 Pathway

With the passage of the Climate Leadership and Community Protection Act this blatant attempt by National Grid to curry favor with the Cuomo Administration and other politicians is so passé.  Imagine only proposing to get an 80% reduction by 2050 when the race to the bottom to be the most aggressive is now set at 85% with 15% offsets – the 100% target.  These posts describe this effort but it is no longer being updated because it so old school to only get an 80% reduction.

Conclusion

Stay tuned and if my articles are of interest please consider sharing them with others.