Category: Transportation and Climate

New York City Zero Emission Vehicle Fleet Legislation

This was also published at Watts Up with That

A recent post, New York City Goes Pedal to the Metal on Electric Vehicles, at Watts Up with That described new legislation that will require vehicles procured by the City to be zero emissions.  The author of the article, Charles Rotter, included a note at the top: “I can’t wait for Francis Menton or Roger Caiazza to weigh in on this.”  It is a rainy Saturday and I don’t have anything else to do so I will take a shot at it.

I have followed New York State’s Climate Leadership & Community Protection Act (Climate Act) since it was first proposed but have not followed the efforts in New York City closely.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The same goes for anything New York City is doing.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone

Benefits

I try to look at environmental policy pragmatically balancing benefits and costs.  The benefits used to rationalize the law are weak.  Rotter quoted the Statements made by two of the politicians responsible for the legislation that make benefits claims:

“New York City continues to set the standard for sustainability by becoming the largest city in the nation to require its fleet to be entirely made up of zero emission vehicles,” said Speaker Adrienne Adams. “The Council is proud to champion legislative efforts to address the environmental and health impacts of vehicle pollution, reduce our carbon footprint, and prepare our workforce for the repair and maintenance of electric vehicles. I thank Majority Leader Keith Powers for his leadership on this critical legislation, my Council colleagues for supporting policies that transition us to a more sustainable future, and Mayor Adams for signing the bill into law.”

“New York City continues to lead the country in creating a greener, more sustainable world,” said Majority Leader Keith Powers. “Today’s signing of Intro. 279 enacts a historic piece of legislation that will drive down our city’s carbon footprint and advance environmental justice. Starting in just two years, our city’s fleet of over 30,000 vehicles will lead the way towards a zero-emissions future. I am proud to have worked with numerous partners to have made today a reality.”

The majority of New York City and State politicians cater to the climate advocate constituency and these statements reflect that.  Adams ticks all the boxes in the narrative that reducing GHG emissions also reduces pollutants that will have environmental and health benefits, the existential threat of climate change will be reduced, and the transition will create jobs.  Even a cursory review shows how shallow those claims are.  The shift to “zero-emissions” ignores the reality that all energy production creates emissions somewhere.  In this case there may not be emissions in New York City, but the mining, processing, and manufacturing of the needed batteries necessary certainly creates emissions.  Jobs created by the “green” technologies are always mentioned but the jobs lost are rarely mentioned. 

Another characteristic of these politicians is innumeracy.  The city fleet has 30,000 vehicles.  I calculate that those vehicles are responsible for about 400,000 tons of CO2 emissions per year.  Driving down the “city’s carbon footprint” needs to be considered in the context of global emissions.  The Global Energy Monitor mission is “to develop and share information in support of the worldwide movement for clean energy”.  As part of their mission, they have prepared a spreadsheet with data on all coal-fired power plants in the world.  Table 1 is based on that data.  It lists capacity and projected annual CO2 emissions for three categories of power plants: operating, permitted but not yet under construction, and under construction.  Every hour the operating coal-fired power plants emit 1,245,158 tons of CO2.  That means that the CO2 reductions due converting the New York City owned fleet of vehicles will be subsumed by coal fired emissions elsewhere on the globe in 0.3 hours or 19 minutes.  This law will not have any discernable effect on global warming.

Costs

My concerns with New York State and New York City (NYC) “zero-emission” transition costs are related to reliability and affordability.  Noodling around on the NYC fleet management site I found this description:

New York City operates over 30,000 owned and leased vehicles, the largest municipal fleet in the United States. NYC maintains fleet units at 37 main repair locations and has over 400 in-house fueling and 400 separate electric charging locations. More than 2,000 staff work full-time in fleet repair and garage operations across over 50 fleet operating agencies and offices. In total, nearly $1 billion is spent annually on fleet repair, fueling, and procurement.

I found a page that includes a table that describes the fleet daily service report which lists the number of vehicles for each agency and what they are used for to give an idea of the importance of reliability.  The NYC fleet includes the police department and fire department vehicles which must provide reliable service.  I suspect that relying on electric-only fire equipment will be very risky because of the high energy demands needed to operate those trucks.  The last thing in the world you want to have happen is for a pumper truck to lose power when fighting a fire.  The vehicle fleet includes sanitation trucks which are also used to plow snow.  However, there is an issue: “city officials have declared they have yet to find an electric garbage truck powerful enough to plow snow. The sanitation department already tested electric trucks, and they couldn’t plow snow for more than four hours, as they ran out of battery. “

Digging deeper into the fleet management site, there is a sustainability page that claims that “New York City’s fleet is the greenest in the nation”. They already have some electric vehicles:

The City of New York operates over 2,260 on-road electric vehicles (EVs) and plug-in hybrids. Full EVs include over 250 Nissan Leafs and over 300 Chevy Bolts, among others. The City has over 600 additional off-road EV and solar units. Please see our presentation Let’s Talk about EVs to learn how to charge an EV and the differences between an EV and the conventional fuel vehicles you may be used to driving.

The sustainability page also notes:

DCAS is rapidly expanding its base of electric chargers to support its electric and plug-in hybrid vehicles. We have installed over 1,600 charging ports across over 1,025 charging stations, including over 180 fast-charging stations, at City garages and parking locations around the city. We have deployed over 80 solar carports that allow EVs to be completely independent from the electrical grid and fossil fuel energy. We have partnered with City schools to provide both solar chargers and EVs to support education programs and adopted other solar powered city equipment.

It appears to me that the vehicle fleet service department has been given the charge to look at a transition to lower emission vehicles and are proceeding on that path.

I have been following the transition to electric vehicles and have been struck by the higher cost of electric vehicles so I wondered about the costs of this law.  I checked the law itself and supporting documents to see if costs had been addressed.  The law is titled A Local Law to amend the administrative code of the city of New York, in relation to the purchase of zero emission vehicles by the city.  The description states:

This bill would require that all light- and medium-duty vehicles procured by the City after July 1, 2025 be zero emission vehicles such that all light- and medium-duty vehicles in the City’s fleet are zero emission vehicles by July 1, 2035. This bill would also require that all heavy-duty vehicles procured by the City after July 1, 2028 be zero emission vehicles, such that all heavy-duty vehicles in the City’s fleet are zero emission vehicles by July 1, 2038. Further, this bill would require that all motorcycles in the City’s fleet are zero emission vehicles by July 1, 2035. The requirements to procure zero emission vehicles are subject to certain exceptions, such as cost, availability, and lack of charging infrastructure.

The last sentence is a welcome reality slap – the procurement requirements are conditional upon costs among other things.  I thought the Fiscal Impact Statement would provide information about costs relative to this condition.  The following excerpt from that statement is a head scratcher:

I guess the current fiscal impact statement is a placeholder.  Presumably sometime before Fiscal Year 2029 the expenditures and source of funds will be determined.  Then the cost exception requirements to procure zero emission vehicles will be considered.

Conclusion

The New York City Department of Citywide Administrative Services fleet management department has a sustainability program in place that tests options for lower emissions and zero emissions vehicles.  Some of their tests are working and others are not.  The key point is that these are the folks responsible for keeping the vehicles necessary to protect the city and provide services and they are working on it.  Mind you I think trying to convert the NYC vehicle fleet to zero-emissions is a waste of time and effort that will likely do more harm than good.

Enter the politicians.  The legislation does include conditions upon deployment but it appears that the issue is already being addressed.  I would bet a lot of money that the fleet staff reacted to the bragging by the politicians who supported this legislation with exasperated sighs and eye-rolling.  As far as I can tell this legislation only provides street cred for politician target constituencies and does nothing but get in the way of the people who are trying to get things done. 

No Electric Car for Me Guest Post

Guest post by Mark Stevens

This is a guest post by Mark Stevens, a regular reader at this blog.  Mark is a retired science and technology teacher.  When he sent an email with this I asked if I could post it and he agreed.

Cut Greenhouse gasses!  Save The Planet!  A better vehicle!  Really?

 I didn’t know EVs (electric vehicles) are about 1000 lbs. heavier than their petroleum equivalents and therefore have higher brake wear (increased particulates), tire wear (increased nano particles), and require more charging energy.

 I didn’t know EVs’ batteries lose power in the cold and reduce their range, and the batteries need replacing after several years approaching half the cost of the vehicle.

I didn’t know the rare elements needed in EVs like lithium, cobalt, copper, nickel are mined in third world countries where child slave labor is used to mine the metals and the metals obtained are refined resulting in mass poisoning of the land and water and massive greenhouse gas emissions are emitted in  the refining.

 I didn’t know the grid doesn’t have the capacity to charge EVs on a massive scale which will lead to rolling blackouts like California, North Carolina and Texas when many families are charging at the same time.

 I didn’t know that electricity providers will boost rates significantly higher to charge EVs at home resulting in  cost-of-operation higher than a gasoline car.

I didn’t know the total greenhouse gas emissions in EV cars from obtaining rare earths to fabrication to end-of-life disposal is greater than that of conventional cars.

I didn’t know that if EVs were really viable they wouldn’t need thousands of dollars of taxpayer subsidies.

I didn’t know EV batteries can suddenly explode in an unstoppable fire that emits toxic gasses.  This results in ordinances requiring EVs to NOT park in garages.

I didn’t know the EVs’ components are not easily recyclable and end-of-life disposition is a major problem for landfills, recyclers and incinerators.

I didn’t know Connecticut’s fleet of electric busses were withdrawn due to several catastrophic fires.

I didn’t know a home charger costs thousands of dollars.

I didn’t know a 500 mile trip would require hours of recharging on the way.

I didn’t know I would have to detour and spend time finding a street charger.

I didn’t know low and middle-income Americans will find using and affording a new or used  electric car will be unaffordable.

I didn’t know the tax on your gasoline to keep our roads maintained will soon be replaced by a special tax on your electric vehicle registration as make-up.

 I’ll stay with my gasoline-powered car.

Green Car Journal Perspective:  What Happened to Bridge Technology?

Late last year the editor of the Green Car Journal contacted me after he came across my Pragmatic Environmental Principles while doing research on pragmatic environmentalism.  He said that he realized we share similar ideas and asked if I would like to share my perspective on GreenCarJournal.com.  This post provides documentation for my perspective.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  Pragmatic environmentalism is necessary to balance environmental impacts and public policy. This means that evidence-based environmental risks and benefits (both environmental and otherwise) of issues need to be considered. 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.

What Happened to Bridge Technology?

This section provides context and documentation to the quoted sections in the article. 

I usurped the concept of a bridge fuel to describe the need of technology that provides demonstrable air quality and CO2 reductions while a “zero-emissions” technology is developed.

Not so long ago, it was generally accepted that plug-in hybrid electric vehicles (PHEVs) and compressed natural gas (CNG) vehicles could be used as bridge technologies until ‘zero-emissions’ vehicles could perform like existing vehicles, at similar cost.  Unfortunately, politics in New York and elsewhere demand net-zero by 2050 with policies that preclude their use. 

I have spent a lot of time the last three years evaluating New York’s net-zero by 2050 target mandated by the Climate Leadership and Community Protection Act (Climate Act) from a pragmatic point of view. Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues. Most troubling in the quest for net zero is the lack of consideration for tradeoffs.          

I recently wrote that the Climate Act and the transition plan embodied in the Draft Scoping Plan is full of examples where the perceived risks of fossil fuels are comprehensively addressed but none of the risks of the proposed alternatives are addressed.  The most glaring Climate Act example is the requirement that the full life cycle and upstream emissions associated with fossil fuels must be considered.  The same consideration of the life-cycle issues with battery electric or hydrogen fuel-cell vehicles is not considered. 

In New York the mandated technology is ‘zero-emissions,’ either battery electric or hydrogen fuel cells.  PHEV and CNG vehicles have direct emissions and so will be banned.  The Climate Act fossil fuel accounting requirements inflate the global warming effects as compared to all other jurisdictions and mandate that upstream and life-cycle emissions also be considered.  On the other hand, the life-cycle emissions and impacts of the ‘zero-emissions’ technologies are ignored.

I submitted Climate Act Draft Scoping Plan comments on the electric vehicle transition schedule.  The analysis presumes an unprecedented adoption rate for light-duty electric vehicles. The biggest problem in the analysis is that the device costs for zero-emissions charging technology and the vehicles themselves is presumed to decrease significantly over time.  Home EV chargers and battery electric vehicles both are claimed to go down 18% between 2020 and 2030.  The overall cost decreases are so large that the total costs for the zero-emissions vehicles adoption is cheaper than using existing technology which I believe is a major reason that they think the transition will be so fast to a technology that is so inconvenient.

The Climate Act’s net-zero by 2050 transition is extraordinarily ambitious. The Scoping Plan that outlines the framework to implement this transition projects that in order to meet the net-zero schedule, over 30 percent of all light-duty vehicles sold will either be battery-electric vehicles (BEVs) or hydrogen fuel cell vehicles (HFCVs) in 2025, and 100 percent by 2035. For medium- and heavy-duty truck sales, the Scoping Plan projects that at least 10 percent sold will either be BEVs or FCEVs in 2025, and 64 percent by 2035.

It’s wishful thinking to presume that large percentages of people will choose BEVs and HFCVs, forgoing the flexibility of a personal car that has much greater range in all seasons, can be refueled quickly on long trips, and does not require expensive charging equipment at home.  PHEV technology eliminates range anxiety, refueling, and home equipment concerns. It also reduces fuel use and air pollution emissions significantly and uses a smaller battery pack than a BEV, which reduces the environmental impacts of rare earth mineral supplies and disposal that the Climate Act ignores.

There are two options in the Climate Act Scoping Plan for personal transportation: hydrogen fuel cells and battery electric vehicles.  Hydrogen fuel cell vehicles have two overcome two technological hurdles: the fuel cells themselves and providing the hydrogen necessary as fuel.  I have never bothered to research the feasibility of fuel cells because I think that a hydrogen economy is a fantasy.  There so many obvious issues with battery electric vehicles that just thinking that the State presumes that they can all be overcome because they say so, makes me ill.

When all the physical, cost, and logistical issues associated with hydrogen use are considered, it will not play a major role in the future. BEV technology doesn’t appeal to a majority of car owners because of nuisance constraints, but the technology could work. The same cannot be said for battery electric heavy-duty vehicles since range, refueling, and charging infrastructure constraints are deal breakers that prevent heavy-duty trucks from meeting the 2050 net-zero target. 

While there is no question that reduced levels of air pollution have benefits, I believe that there are thresholds to those impacts where further reductions have little beneficial value.  Nonetheless, air quality health benefits are touted as one of the primary benefits of the net-zero transition, especially related to disadvantaged communities.    One example of those impacts is related to the Hunts Point Food Distribution Center in South Bronx, New York that is the largest food distribution center in the country.  Diesel exhaust emissions are primarily inhalable particulates that are targeted as a primary air pollution health factor so eliminating diesel truck emissions is an activist priority.  Compressed natural gas trucks greatly reduce particulate emissions and lower the pollutants that create ozone.  However, instead of advocating for the CNG technology that has proven to work in heavy duty trucks, the activists want to use zero-emissions technology that might work sometime in the future.

There are serious inhalable particulate air pollution issues associated with diesel truck emissions at freight terminals in New York City. The Scoping Plan claims that replacing these trucks with zero-emission alternatives provides significant benefits. However, the plan’s zero-emissions aspirations ignore technological tradeoffs and the reality that CNG heavy-duty trucks are a viable alternative that would markedly reduce inhalable particulate emissions.  The problem with CNG is not technology since we know it works, but a problem with the development of fueling infrastructure and vehicle fleet turnover. It is not pragmatic to insist that heavy-duty trucks use unproven battery electric technology over other alternatives that can markedly reduce the air quality issues. 

The pragmatic response is obvious.

The use of PHEV and CNG vehicles for personal and freight transport offers the opportunity for significant air quality benefits, at a cheaper societal cost, with less impacts on personal choice, and sooner than the ‘zero-emissions’ alternatives. Failing to consider those benefits while insisting upon a riskier technological approach is not good social policy. Someday, there may be a better alternative, but in the meantime bridge technologies that provide most of the benefits are the more appropriate policy approach.

Conclusion

In the transportation sector, there are two choices: technology that gets significant emission reductions with the associated benefits, at a lower cost, has fewer implementation downsides, and has proven results or technology that has limitations in every respect but has “zero-emissions” if it can be deployed someday.  From a pragmatic standpoint the rational approach is use what makes an improvement, continue research and development for “zero-emissions” technology, and deploy that only when we know it will work as advertised.  Unfortunately, that option has been pulled off the table.  A friend describes the situation well: these morons are apparently fully at ease with the equivalent of jumping out of a perfectly good airplane without an upgraded parachute assuming that an even better parachute will be developed, proven technically and economically feasible and delivered to the imbecile that jumped out of the airplane in time to provide a soft landing.

New York Zero Emission Vehicle Mandate

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  On September 29, 2022 Governor Hochul directed the New York Department of Environmental Conservation to take major regulatory action that will require all new passenger cars, pickup trucks, and SUVs sold in New York State to be zero emissions by 2035.  As has been the case with all of the Administration’s global warming regulatory initiatives the pronouncement is not supported by any documentation.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

In 2019 greenhouse gas (GHG) emissions from the transportation sector accounted for 28.2% of total GHG emissions so it is necessary to reduce transportation sector emissions to meet the Climate Act targets.  However, I explained in my comments that the Draft Scoping Plan did a poor job evaluating how a zero-emissions mandate would be implemented and an even worse job projecting the potential costs.  I will highlight some of the points made in my comments and also put this new mandate in context.

Hochul’s Announcement

The following is a substantial portion of the press release announcing the mandate:

Governor Kathy Hochul today commemorated National Drive Electric Week by directing the State Department of Environmental Conservation to take major regulatory action that will require all new passenger cars, pickup trucks, and SUVs sold in New York State to be zero emissions by 2035. This is a crucial regulatory step to achieving significant greenhouse gas emission reductions from the transportation sector and is complemented by new and ongoing investments also announced today, including electric vehicle infrastructure progress, zero-emission vehicle incentives, and ensuring New York’s communities benefit from historic federal climate change investments.

“New York is a national climate leader and an economic powerhouse, and we’re using our strength to help spur innovation and implementation of zero-emission vehicles on a grand scale,” Governor Hochul said. “With sustained state and federal investments, our actions are incentivizing New Yorkers, local governments, and businesses to make the transition to electric vehicles. We’re driving New York’s transition to clean transportation forward, and today’s announcement will benefit our climate and the health of our communities for generations to come.”

Proposing draft State regulations is a crucial step to further electrify the transportation sector and help New York achieve its climate requirement of reducing greenhouse gases 85 percent by 2050, while also reducing air pollution, particularly in disadvantaged communities. The State Department of Environmental Conservation (DEC) is expediting this regulatory process to implement legislation Governor Hochul signed last year and turn those goals into progress in fully transitioning to new zero-emission cars and trucks. California’s action finalizing the Advanced Clean Cars II regulation last month unlocked New York’s ability to adopt the same regulation.

The regulation will build upon existing regulations enacted in New York in 2012 by requiring all new sales of passenger cars, pickup trucks, and SUVs to be zero-emission by 2035. It would require an increasing percentage of new light-duty vehicle sales to be zero-emission vehicles (ZEV) starting with 35 percent of sales in model year 2026, 68 percent of sales by 2030, and 100 percent of sales by 2035. New pollutant standards for model year 2026 through model year 2034 passenger cars, light-duty trucks, and medium-duty vehicles with internal combustion engines would also be required. The regulation provides manufacturers with flexibility in meeting the emission requirements and achieving a successful transition to cleaner vehicles.

Adoption of Advanced Clean Cars II is included among the recommendations in the Climate Action Council’s Draft Scoping Plan and will be instrumental in achieving the greenhouse gas emissions reductions required in the Climate Leadership and Community Protection Act. In addition, reducing emissions will provide significant air quality benefits to many of New York’s disadvantaged communities, predominantly home to low-income Black, Indigenous, and People of Color, and often adjacent to transit routes with heavy vehicle traffic. The regulation will help address disproportionate risks and health and pollution burdens affecting these communities.

Department of Environmental Conservation Commissioner and Climate Action Council Co-Chair Basil Seggos said, “Governor Hochul is demonstrating her sustained commitment to the successful implementation of the Climate Act and ensuring all New Yorkers benefit from the State’s actions to address climate change. DEC will continue to work under her direction to rapidly issue this regulation and reach another milestone in the transition from fossil fuels so that more people, businesses, and governments will have the ZEV options to meet their needs and help improve the health of their communities.”

The directed regulatory action announced today builds on New York’s ongoing efforts to reduce emissions of greenhouse gases, including the adoption of the Advanced Clean Trucks regulation in December 2021. That regulation will drive an increase in the number of medium- and heavy-duty ZEV models available as purchase options for vehicle purchasers and fleets. In addition, several transit agencies including the Niagara Frontier Transportation Authority, the Rochester-Genesee Regional Transportation Authority, and the Metropolitan Transit Authority are leading by example with second wave deployments of electric buses. DEC, New York State Energy Research and Development Authority (NYSERDA), New York Power Authority (NYPA), and DOT (Department of Transportation) are assisting these authorities with these efforts.

Draft Scoping Plan Transportation Comments

I submitted a couple of comments on electric vehicles.  The emphasis in the first comment was my finding that the Integration Analysis is simply making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  I provided numerous recommendations for additional documentation in these comments so that New Yorkers can understand what will be expected and how much it will cost.

As far as I can tell, the electric vehicle costs are based entirely on new vehicle sales. There is no acknowledgement that the used car market will likely change because of the cost of battery replacement.  Sellers will likely get less relative to new cars in the battery electric vehicle market.  Buyers may get a relative deal but will lose in the end when the batteries have to be replaced.  This is a particular concern for low and middle-income citizens who cannot afford new vehicles.

There is no bigger disconnect between the zero-emission vehicle (ZEV) proposed strategy and reality than the ZEV charging infrastructure requirements.  The biggest problem is that millions of cars will have to rely on chargers that cannot be dedicated for the owner’s personal use because the owners park on the street or in a parking lot.  In order to provide a credible ZEV strategy, the final Scoping Plan has to describe a plan how this could possibly work.  It is not enough to simply say it will work.

I also submitted a comment addressing electric vehicle costs.  the Integration Analysis vehicle cost projections rely on a single vehicle type for light-duty vehicles.  As a result, the projections are not particularly useful for many vehicle owners.  In order to accurately project the costs for this mandate the types of vehicles used has to be updated. 

Discussion

There is a paragraph in the press release that needs to be addressed:

The regulation will build upon existing regulations enacted in New York in 2012 by requiring all new sales of passenger cars, pickup trucks, and SUVs to be zero-emission by 2035. It would require an increasing percentage of new light-duty vehicle sales to be zero-emission vehicles (ZEV) starting with 35 percent of sales in model year 2026, 68 percent of sales by 2030, and 100 percent of sales by 2035. New pollutant standards for model year 2026 through model year 2034 passenger cars, light-duty trucks, and medium-duty vehicles with internal combustion engines would also be required. The regulation provides manufacturers with flexibility in meeting the emission requirements and achieving a successful transition to cleaner vehicles.

In 2026 the State will require 35% of all new vehicle sales to be zero-emission vehicles.  As of May 1, 2022 there were a little over 62,000 electric cars registered in New York out of the over 11 million vehicles registered.  The Integration Analysis projections for battery electric vehicles in 2026 range from 7.8% in the reference case to 24.3% in the most optimistic mitigation scenarios.  One of my criticisms of the Draft Scoping Plan is that the increase in projected sales is not supported by any recommendations for implementation. 

I have documented many electric vehicles issues but it is by no means an exhaustive list of the reasons I will never purchase an electric vehicle.  The State apparently believes that all that is necessary is a proclamation and all the reservations of all the people who are perfectly happy with internal combustion engines will be overcome.

Hochul’s proclamation fails to address the low and middle-income consumer concerns expressed by Robert Bryce in testimony before the House Select Committee on the Climate Crisis:

EVs … impose … societal costs that are likely to exacerbate inequality and lead to more energy poverty,” Bryce continued. “Those costs include taxpayer-funded subsidies given to EV buyers, publicly funded charging stations, and the grid upgrades that will be needed to support the electrification of light and heavy-duty vehicles. Those costs will impose a significant cost burden on low and middle-income consumers, even though those consumers are unlikely to purchase EVs.

Bryce also raised other issues in his testimony that are ignored in the grandstanding announcement:  

Electrifying parts of our transportation system may result in incremental reductions in greenhouse gas emissions, 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.

Finally, the ultimate rationale for this inane policy is to do something about climate change.  The reality is that New York emissions are inconsequential so this is nothing more than politically expedient climate virtue signaling.  New York’s GHG emissions are less than one half a percent of total global emissions and, on average, global GHG emissions have been increasing by more than one half a percent per year.  Anything we do will be wiped out be emissions elsewhere in a year.  Furthermore, the State has never published an estimate of the effect of New York emission reductions on global warming itself.  I estimate that the change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions. 

Conclusion

In the press release Hochul claimed that “New York is a national climate leader and an economic powerhouse, and we’re using our strength to help spur innovation and implementation of zero-emission vehicles on a grand scale”.  The State’s obsession with being a climate leader is pointless.  Worse there is no recognition that the pursuit of zero emissions has unintended consequences and will likely cause more harm than good.  The lack of a public discussion of pragmatic considerations for the net-zero transition will ultimately seriously affect New York.

Initial Impression of Climate Action Council Response to Public Comments on Transportation

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  The last two meetings of the Climate Action Council have offered some insights into the plans to address those comments.  I am not encouraged by what I have seen so far.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. Since the close of the public comment period in early July staff has been updating the Integration Analyses and working through the comments to provide the Council with summaries for their review.

In this article, I will describe the response to the Transportation sector comments relative to the comments I submitted on this sector.  I submitted two comments on electric vehicles.  I noted that the Integration Analysis is making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  The other comment addressed electric vehicle costs.  I also submitted a comment on high-speed intercity passenger rail transportation that is relevant to the September 13, 2022 Climate Action Council Presentation that will be the focus of this article.

Transportation Comments Response

The discussion of Transportation Summary Themes at the September 13, 2022 Climate Action Council meeting included “Several commenters suggested investments in rail infrastructure, to connect cities and move freight”. 

The staff recommendations stated that few changes in response to public comments were needed.  Relative to the railroad theme they noted that: “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability.”

I submitted a comment on high-speed intercity passenger rail transportation that is ignored in this response.  The Federal Railroad Administration (FRA), in cooperation with the New York State Department of Transportation (NYSDOT) completed the Empire Corridor Environmental Impact Statement (EIS) in 2014 to “evaluate proposed system improvements to intercity passenger rail services along the 463-mile Empire Corridor, connecting Pennsylvania (Penn) Station in New York City with Niagara Falls Station in Niagara Falls, New York.” This is the primary reference for Draft Scoping Plan Scenario 4 high speed intercity passenger rail transportation upgrades.

I evaluated the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 compared to Scenario 4 due to rail passenger improvements.  Note that this basically proposed the development of a dedicated high-speed rail corridor between Buffalo and Albany.  The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion.  I estimated that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a vehicle mile reduction of 64.7 million miles. 

Discussion

There are multiple issues associated with the presentation response to comments.  At the previous meeting the State acknowledged that they had not worked their way through the comments submitted as attachments.  My comment was submitted as an attachment so it is possible that it has not even been reviewed yet.  In my opinion, the only way to make detailed comments is through an attachment so I think many of the substantive comments may not have been evaluated yet.

It is not clear whether this presentation was only meant to be an overview of the comments received.  Alternatively, it could represent the entirety of the discussion of the comments for each of the sectors (Transportation, Agriculture and Forestry, Land Use, Local Government, and Waste) discussed. My specific comment was not mentioned and it is not clear if this was because they have not reviewed it yet or whether it was inconvenient for them to respond.  If this is supposed to be the final word on the comments for each of these sectors then it is clear that the stakeholder public comment process is just window dressing and that no meaningful revisions will be incorporated.

At one point the Council promised to provide all the comments for public review.  Of course, the odds that the comments will be provided in format that enables it to be evaluated easily is another thing.  I believe all the comments should be available by topic in a searchable formatted document.

I believe my specific comment has to be addressed on two levels.  On the first level, I identified a problem with their numbers.  Shouldn’t they have to respond to that error?  While it might not rise to the level where an explicit Climate Action Council decision is needed, I do think the Council has to decide what level of high-speed intercity passenger rail transportation improvements they are recommending. The response to this topic at this meeting “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability” is just a bunch of words devoid of meaningful comment.

I also noticed a bias in the comment descriptions.  For example, “Generally, there was strong support for electrification policies in the draft plan” compared to “Some commenters expressed concern over the costs of electrification, particularly in rural communities and for larger vehicles” inappropriately indicates the rates the level of support based on numbers.  The value of a comment is the quality of the argument not the number of people who submitted the argument.  The statement “Several detailed comments supported the development of renewable and/or low-carbon fuels, while many commenters expressed opposition, describing such fuels as a ‘false solution’ “ is particularly problematic because it suggests that no matter how strong the technical argument, if enough ideologues using slogans oppose it that the Council is going to side with the slogans. 

Conclusion

I am not surprised that my comments were ignored.  However I am terrified that the Council may ignore the comments submitted by the New York Independent System Operator and the New York State Reliability Council.  There was no mention of any need to reconcile the Integration Analysis with the recent NYISO 2021-2040 System & Resource Outlook report.  The projections are significantly different and the citizens of New York deserve to have them reconciled clearly and transparently.  It is entirely inappropriate for the state to be committed to go down a transformational energy policy path based on the work of unelected bureaucrats who are not responsible for keeping the lights on without incorporating the input of the state’s experts who are responsible.

Regulatory Assistance Project Electric Vehicle Roadmap

The Regulatory Assistance Project (RAP) is an” independent, non-partisan, non-governmental organization dedicated to accelerating the transition to a clean, reliable, and efficient energy future”.  This post addresses their “Roadmap for Electric Transportation”.

I have run into RAP policy recommendations before.  Staff are “former utility and environmental regulators, industry executives, system operators, and other policymakers and officials with extensive experience in the power sector”.  After seeing this I wondered who supports their work and could find nothing on their web page.  Mark Krebs looked into RAP and concluded that RAP is effective and well funded but could not find any specifics who funds their work.  He suspects and I agree that “RAP is now being funded by the usual climate fear mongers, such as the Pew Charitable Trust, the Hewlett Foundation, etc.”

The intent of the roadmap is to provide legislators a “complete and useful resource for legislators interested in accelerating electric vehicle deployment”. RAP has developed a policy guide, “as well as a set of model legislative options with annotations noting their implications, a fact sheet and presentation slides”.  In other words, it is a slick lobbying effort.

The roadmap’s introduction prompted me to write this essay.  The introduction states:

“Electrification of the transportation sector (cars, trucks, buses, taxis, ports, etc.) provides an opportunity for states to save citizens money, increase local jobs and business, address national security concerns, improve public health and combat climate change. Real-world experience and studies show that these benefits are achievable, but proactive legislative action and state planning are needed to realize their full magnitude. Without an early and comprehensive approach, potential benefits will be lost.”

In particular, I had to scratch my head how electric vehicles (EV) would provide those benefits.  I address each benefit claim below.

Save Citizens Money

It is a matter of faith that electric vehicles will save consumers money.  The RAP Policy Guide states:

Consumers buy electric vehicles for a variety of reasons, ranging from environmental consciousness to enjoyment of the product. The costs of new EVs are higher than comparable gasoline vehicles, but the cost differential is dropping. EV owners currently save money after purchase because EVs are cheaper to operate and maintain than gasoline vehicles.  Maintenance costs of an EV are lower than for traditional vehicles due to fewer moving parts. Fueling costs are cheaper too; on a national average, it costs less than half as much to travel the same distance in an EV as in a conventional vehicle.

I don’t want to spend a lot of time doing a quantitative analysis of potential cost savings but will make some comments.  There is the obligatory claim that EVs are more expensive now but the costs are coming down and when they do boy oh boy then everyone will want one.  In the meantime, if people would just consider that maintenance and fuel costs are cheaper, then people would buy them.  So, on one hand consumers are supposed to total costs to guide their decision to buy but not all the costs.  What about the batteries?  The life of the battery affects the overall cost of the EV.  There are two factors that affect the life of the battery – calendar life and the number of charging cycles.  Temperature, rate of charge and discharge, depth of discharge, etc. affects the life of the battery.    Consumers like me either buy a new car and drive into the ground or buy used.  In either case I would have battery life anxiety given that a typical Li-ion battery lasts for 300-500 charging-discharging cycles.   One other cost detail is that users have to install a battery charging system.  A 110 volt charging system only costs $500 to $1,000 but takes 18 hours to charge to drive 100 miles.  A 240 volt charging system costs $2,000 to $5,000 and takes 4 hours to charge to drive 100 miles.

Increase Local Jobs and Business

The first contradiction is that the claim electric vehicles require less maintenance also means that there will be fewer maintenance jobs.  In addition, the RAP Policy Guide states “In Minnesota, a study found that installing 150 EV chargers would generate $14.2 million in economic activity, including $4.6 million in labor income”.  The reference for that claim says “The University of Minnesota Extension study indicates that installing just 75 50-kW and 75 150-kW DCFCs in Greater Minnesota would generate $14.2 million in economic activity.  This includes $4.6 million in labor income.  Communities and businesses that host charging stations may also see economic benefits as EV drivers eat or shop while their vehicles charge.”  However, there is no reference for the study to determine if this claim is justified.  The direct cost to construct 75 50-kW and 75 150-kW fast-charging electric vehicle chargers listed is $9.2 million.  Without the original reference to check the assumptions I will assume that each charger equals $9.2 million divided by 150 or $61,333 each.  The report claims that 50 people will be employed at a cost of $3.3 million.  I have no clue how to apportion that because I have no idea how many people would take how long to install a charger but we can add the labor cost to estimate that each charger will cost $83,333.  Somehow the study claims that spending will lead to indirect and induced output of $5 million.

I don’t know what you call grey literature that references grey literature that quotes an unreferenced study but suffice to say it is not peer reviewed science.  All this example and the other points made in the policy guide show is that government spending creates jobs but ignores the broken window fallacy – money spent on EV fast charges, for example, is “money that cannot be spent on food, clothing, health care, or other industries. The stimulus felt in one sector of the economy comes at a direct – but hidden – cost to other sectors”.

Address National Security Concerns

Just when you thought the claims could not get anymore ignorant the national security benefit is described:

In 2017, the United States imported about 19% of the petroleum it consumed. Because transportation accounts for nearly three-fourths of total U.S. petroleum consumption, using more energy-efficient vehicles like hybrid and plug-in electric vehicles can have a direct impact. When EVs plug in, they are mostly powered by a domestic mix of energy sources, including natural gas, coal, nuclear, hydropower, wind and solar. This is in stark contrast to gasoline-fueled vehicles, which depend solely on oil — which is subject to a range of global price and availability risks.

This studiously ignores the changes caused by fracking which have changed the import/export dynamic because in 2018 the US only imported 11% (or 8% less than in 2017) of the petroleum it consumed and I am sure that the 2019 imports will be even lower.  There also is another national security issue – not enough of the rare earth minerals necessary for EV batteries are produced in the US.  It is estimated that there’s about 63 kg of lithium in a 70 kWh Tesla Model S battery pack, which weighs over 1,000 lbs (~453 kg).  When asked if he worries about lithium supply, Tesla CTO JB Straubel once said that he worries more about cobalt, which is used in the cathode of Tesla’s battery cells. The resource is more problematic since the bulk of it overall supply has historically come from the conflict-prone Congo.  Clearly, if you look at the big picture national security concerns will be an issue if we try to electrify transportation compared to where we stand now with petroleum.

Improve Public Health

The fact is that ambient air quality levels have been coming down in the United States for years.  There still are ambient air quality issues and a switch to electric vehicles will help alleviate those health problems.  However, there will be diminished returns for future reductions simply because the concentrations are already so low.  In fact, the marginal improvements in the United States have to be weighed against health impacts elsewhere.

The public health improvements claimed by EV advocates immorally ignore the environmental and health impacts of rare-earth mineral mining elsewhere.  In particular, cobalt is problematic.  Unlike most metals, which are not toxic when they’re pulled from the ground as metal ores, cobalt is “uniquely terrible,” according to Gleb Yushin, chief technical officer and founder of battery materials company Sila Nanotechnologies.  “One of the biggest challenges with cobalt is that it’s located in one country,” he adds. You can literally just dig up the land and find cobalt, so there’s a very strong motivation to dig it up and sell it, and a a result there’s a lot of motivation for unsafe and unethical behaviour.” The Congo is home to ‘artisanal mines’, where cobalt is extracted from the ground by hand, often using child labour, without protective equipment”.

Combat Climate Change

Advocates for greenhouse gas reductions regularly pick and choose which numbers to include and which ones to exclude.  Until the electric grid operates only without fossil fuels, the CO2 emitted from the tailpipe is simply moved to an electric generating unit stack somewhere.  I would love to see a true life-cycle analysis of the 100% renewable energy system vs. the fossil-fueled energy system.  I suspect that the real observable environmental impacts of the renewable system with the enormous areas required to provide power as opposed to the fossil-fueled system of today are greater.

More importantly, transportation greenhouse gas emissions in, for example, New York are such a small fraction of global emissions any reduction will not provide any tangible benefits. In the New York Transportation Analysis of Carbon Dioxide Emissions and Potential “Savings” table I present the effects of completely eliminating the total NY transportation emissions of 73.98 million metric tons of CO2 equivalent in 2016.  The table shows that the transportation emissions are 0.23% of the total global emissions and that we could expect the global temperature in 2010 will only be 0.0023 degrees C if those emissions are eliminated.  These numbers don’t mean much but can be related to the facts that temperatures decrease as you go higher in elevation or temperatures increase as you go further south in latitude.  Specifically, temperature generally decreases three degrees Fahrenheit for every 1,000 foot increase in elevation above sea level and temperature changes three degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level.  In this instance, completely eliminating New York transportation emissions would be the same as a nine inch change in elevation or two tenths of a mile change in latitude.

Conclusion

There is another aspect of the EV policy that weakens the benefits arguments.  In A reality check on electric cars Bill Lynch and Dr. Jay Lehr crunched some numbers and show that the benefits of electric cars are based on weak numbers.  They also show that the goal of a longer range EV is unlikely simply because the weight of the additional batteries needed offsets the mileage gained.  The bottom line is that the prospects for improved EV performance are not as rosy as proponents suggest.

To summarize, the benefits claimed in this study are all either feel good virtue signals or demonstrably inaccurate.  There could be public health impacts but given current ambient levels of pollution they will be smaller than imagined in the descriptions of this report.  There will be climate change “benefits” but they are only feel-good measures because the impacts could never be measured.  Cost savings projections are based more on expected cost reductions and ignore the additional costs of installing a charging system.  The claims made for local jobs and business cannot be verified and ignore reductions that would necessarily occur in the existing vehicle service job market.  The claims for national security ignore the current status of petroleum imports and exports.  More importantly, they immorally ignore the very real horrific environmental and societal impacts of cobalt mining in the Congo as well as the fact that relying on that country for a critical component necessary for electrifying transportation would substantively increase national security concerns.

The RAP is a front organization for climate fear mongers.  This slick package of lobbying materials is based on shallow and inaccurate claimed benefits.  Sadly, I expect that it will find a ready audience for those convinced that we have to do something and unwilling to check the basis of the arguments.