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I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered. This is a summary of articles that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  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. The opinions expressed in this article 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.

Video

In a new short film written for Net Zero Watch, Dr John Constable reminds us that human wealth in the broadest sense, from the smallest gadget to a tolerant and diverse society, is an improbable state of physics that results from work done by energy.

Video description of a new motion picture entitled Climate: The Movie funded by the CO2 Coalition, Heartland Institute, and CFACT.

Let’s Discuss the Facts Now About New York’s Energy Future

I highly recommend this description of the New York Jobs new social media campaign, “Energy Red Flag for NY” intended to raise public awareness of the opportunities, challenges and costs of implementing New York’s ambitious efforts to decarbonize the state’s economy. Working closely with The Business Council of New York State, New York Jobs Now’s goal is to provide data and analysis to help educate the public on the impact of these ambitious climate goals. Our reasoning is very clear and we write this op-ed with an eye towards clearly stating our goals and reasoning behind this campaign.

The summary concludes:

Responding to climate change, and implementing New York’s CLCPA, can provide immediate and long-term benefits for New Yorkers, but will also be complex, expensive and disruptive. The implementation decisions we make will determine how well we balance costs and benefits. New Yorkers should be demanding more complete, more accessible information on major state climate change programs – how much they cost, how they are being paid for, what they are achieving, and how New Yorkers are benefiting.

Hatred of Fossil Fuels

Francis Menton asks “What is it about fossil fuels and the people who produce them that brings forth such uncontrolled hatred, anger, and vengefulness in a very large segment of the population?”  After pointing all the value of concentrated and affordable energy he points out that those who advocate to ban fossil fuels continue to use them.  He suggests:

Here’s my proposal for the next phase of this game. The fossil fuel producers, either individually or through trade associations, should pick a state, logically a relatively small one (Vermont might be a good place to start), and go to the legislature with this proposition: Ban us! Make the sale or use of fossil fuels in your state illegal, starting at some early date, like for example tomorrow. We will then withdraw. And your citizens will then find out whether they prefer life with fossil fuels, or without them.

In other words, stop being such pansies. It’s time to call their bluff.

My only disagreement with his proposal is that I would start smaller with a virtue-signaling college town.  My candidate for calling the bluff is Ithaca, NY.

On the other hand, Maine was considering legislation that would prohibit natural gas companies from charging ratepayers for the construction and expansion of gas service mains and gas service lines beginning Feb. 1, 2025 (see Maine Debates Democrat Bill to Limit New Natural Gas Customers).  Jim Willis notes that the language of the bill has been modified to account for reality. 

Note that the usual suspects are clamoring for similar natural gas limitations in New York.  They hope to sneak it through as part of the budget because if it was considered openly the public would catch on and demand a reality slap.

New Jersey Referendum on Fossil-Fired Power Plants

A state Senate committee on Monday advanced a bill that would authorize a public referendum on amending the state’s Constitution to ban construction of new power plants that burn natural gas or other fossil fuels.  But the measure was changed to allow the construction of such plants if they are to be primarily used as emergency backup power sources.  This addresses the fact that wind and solar resources have their lowest availabilities when needed most.

Offshore Wind

I have been meaning to do a post on offshore wind issues.  David Wojick has done some good work lately.

• Offshore wind violates the Clean Air and Clean Water Acts
• Proposal to Use Different Foundations  One of my concerns is that the monopiles proposed for the monster turbines require disruptive pile driving that I think will adversely affect fisheries.  Wojick describes a less disruptive method.

One of the “features” of the wind and solar deployment is the use of “community benefit agreements” aka bribes.  Robert Bradley notes that Ocean City, MD refused offshore wind developer payola.

Heat Pumps

Ed Reid describes the ultimate risk of heat pumps – what happens when there is a blackout.

Parker Gallant notes that heat pumps increase electric usage a lot:

 A contact of mine here in Ontario had recently informed me he had a heat pump installed to replace his furnace and told me his electricity usage had quadrupled* since having the heat pump installed!  Quiring him about the total costs of installation and the potential rebate he informed me the total, including conversion of his service from 100 amp to 200 amp as well as a new hydro line cost almost $21K and his grant rebate will be $7,100 so his net costs will be almost $14K!**  At a current approximate cost of 18 cents/kWh we should suspect that will add somewhere between $1,200 to $2,000 per year to his electricity bill or perhaps about what he was previously paying for a natural gas supply! 

Fossil Fuels Make Us Sick

Blair King writing at the A Chemist in Langley blog has been a continuing inspiration to me because of his pragmatic approach.  In this post he addresses claims by the Canadian Association of Physicians for the Environment that air pollution from fossil fuels has severe health impacts.  They claim that  “air pollution from the burning of fossil fuels is one of the leading causes of premature mortality in Canada” but King shows “the citation used does not support that claim.”  The second claim to be examined is “the suggestion that fossil fuel pollution is responsible for one in seven premature deaths in Canada”.  He demonstrates that the claim is “so obviously wrong as to be incredibly puzzling and clearly represents a failure in the peer review process”. 

A slightly different version of this article also was published at Watts Up With That.

An article about response plans for pandemics by Joe Nocera writing at the Free Press described the plans by the scientist credited for eradicating smallpox for combatting an epidemic.  I was struck by the parallels between the differences between his recommendations and the lockdown plan response to Covid and the Climate Leadership & Community Protection Act (Climate Act plans to transition the electric system to net-zero greenhouse gas emissions.

I have followed the Climate Act  since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act proved to so difficult that many of the goals for 2023 were not achieved.  Many aspects of the transition are falling behind, and the magnitude of the necessary costs is coming into focus.

D. A. Henderson

The Free Press has a weekly series of articles, The Prophets, about “fascinating people from the past who predicted our current moment and make our world more understandable today.”  Joe Nocera’s article “spotlights D.A. Henderson, the epidemiologist who warned that pandemic lockdowns won’t stop a disease but could instead lead to a public health disaster.”  It is a very interesting article and I recommend it highly.  He writes:

In 2006, ten years before his death at the age of 87, the legendary epidemiologist D.A. Henderson laid out a plan for how public health officials should respond to a major influenza pandemic. It was published in a small journal that focused mainly on bioterrorism—and was quickly forgotten.

As it turns out, that paper, titled “Disease Mitigation Measures in the Control of Pandemic Influenza,” was Henderson’s prescient bequest to the future. If we had followed his advice, our country—indeed, our world—could have avoided its disastrous response to Covid.

Nocera describes Henderson’s background.  After graduation from medical school, he took a job at the U.S. Communicable Disease Center—the original name for the Centers for Disease Control and Prevention, or CDC.  In 1960 as the head of the CDC’s new disease surveillance department smallpox was “high on his list of concerns—and for good reason. Ancient, airborne, and highly contagious, smallpox was estimated to have caused around 300 million deaths in the twentieth century alone.”  At that time smallpox was under control in the United States but he was worried about the possibility that an infected person could come and start an outbreak.  “When the World Health Organization announced a program aimed at eradicating smallpox, Henderson’s superiors at the CDC transferred him to the WHO in 1966 to take charge of what many scientists believed was a futile mission.”

There was an effective vaccine for smallpox but many thought that it wasn’t possible to vaccinate enough people to eradicate the disease.  Henderson’s plan was to place doctors and volunteers in all the places where the disease was still rampant and respond to breakouts as quickly as possible.  Quarantines and better vaccination technology enabled people to rapidly vaccinate everyone associated with a local breakout of the disease.  Henderson was the driving force to implement the plan across the world.  Nocera states:

In 1980, after two years without a single recorded case of smallpox, the World Health Organization declared it eradicated. Science writer Richard Preston, who wrote the introduction to Henderson’s book on the effort, described this feat as “arguably the greatest lifesaving achievement in the history of medicine.”

Pandemic Response

During G. W. Bush’s Administration, a program to develop a plan for a pandemic was put in place:

This was prompted by the book he brought on vacation in 2005, The Great Influenza, a terrifying account of the 1918 flu pandemic estimated to have killed 50 million people worldwide. Bush had already been caught flat-footed on 9/11. He did not want the government to be unprepared in the case of a killer virus. So he ordered that a plan be devised for responding to such a deadly microbe. “Look,” the president said, “this happens every hundred years. We need a national strategy.”

Nocera explains the response developed:

When a team of government scientists completed the plan two years later, among its central tenets was that schools and other institutions should be closed, and that there should be “reduced contact among adults in the community and the workplace.” This meant lockdowns. This was exactly the opposite of the wisdom about pandemics Henderson had acquired during his long career. He tried to tell them that, but his words fell on deaf ears.

The lockdown plan was based on a computer model advocated by Robert Glass, a senior scientist at Sandia National Laboratories in New Mexico:

Robert Glass found that when he entered different variables on how to stop a respiratory virus from spreading, the most effective way was to close schools—along with other parts of society as necessary. Glass managed to get this model to the two government scientists leading the team developing Bush’s pandemic plan, Dr. Carter Mecher and Dr. Richard Hatchett, who quickly embraced it.

Though none of them were epidemiologists, Mecher, Hatchett, and Glass were convinced that computer modeling would transform epidemiology. In The Premonition, Glass reflected on old-school scientists like Henderson with a kind of pity. “I asked myself, ‘Why didn’t these epidemiologists figure it out?’ ” he told Lewis. “They didn’t figure it out because they didn’t have the tools.” Tools like computer models.

At this point I was struck by the similarity between these modelers and the academic energy system modelers.  In particular, the arrogance that their models are the be all and end all tool to address the problem at hand and the condescension towards experts in the field.     

Nocera notes that Henderson tried to respond:

Henderson, on the other hand, believed that basing pandemic mitigation strategies on hypothetical models—models that themselves were based on hypothetical assumptions—could lead policymakers deeply astray. He said that people behaved in unpredictable ways that models could not capture.

Before the plan was finalized Henderson and other epidemiologists met with the modeling team.  The meeting did not go well with the epidemiologists all “berating the Bush team for failing to back up their draconian shutdown proposals with real-world evidence”.

But Mecher and Hatchett stuck by their model, and that was reflected in the pandemic plan, which was published in 2007. Henderson never stopped believing that the path the Bush administration chose was potentially disastrous.

The paper Henderson and his three younger colleagues wrote in 2006, after Henderson’s meeting with Bush’s team, was their last-ditch effort to stop the lockdown plans of the modelers. In retrospect, it was more than a mere journal article. It was a warning about what public health should and shouldn’t do during an outbreak of a highly contagious respiratory illness. It was also a manifesto about the purposes, and limits, of public health.

As he and his co-authors wrote in the 2006 paper:

What computer models cannot incorporate is the effects that various mitigation strategies might have on the behavior of the population and the consequent course of the epidemic. There is simply too little experience to predict how a 21st century population would respond, for example, to the closure of all schools for periods of many weeks to months.

We now know exactly how school closures affected the nation. The answer is very badly.

Nocera describes the negative consequences.  For example, the performance of students during the lockdown was disastrous and will have long-term effects.  If the lockdown had been effective at stopping the spread of the virus there would at least be a mitigating factor.  Nocera quotes Michael Osterholm, the prominent University of Minnesota epidemiologist, , “Look at what happened in China. They locked down for years, and when they finally relaxed that effort, they had a million deaths in two weeks.”

Parallels to the Net-Zero Energy System Transition

D. A. Henderson was a hands-on epidemiologist.  His mentor taught him the value of “shoe-leather epidemiology” which is shorthand “for the activities of an epidemiologist who left his office to personally investigate epidemics—collecting data and interviewing patients and officials”.  He also demonstrated hands on leadership in the fight to eradicate smallpox.  My point his position was developed based on personal experience.

My primary concern is the New York Climate Leadership & Community Protection Act net-zero transition.  As part of that transition the Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  Throughout the CAC deliberations of the draft scoping plan the State never refuted the claims by academic energy modelers that no new technologies would be needed for the transition and that there were no reliability issues. There have been two modeling approaches for the transition plan.  The entities responsible for electric system reliability rely on bottom-up models based on decades of experience with the all the components of the electric system.  On the other hand, the basis of the Scoping Plan is modeling by academics that is a top-down approach.  I am convinced that the top-down modeling to date overlooks too many critical aspects of the electric system to be credible.  That the state has not reconciled the differences between the New York Independent System Operator electric system projections and the analyses performed by the New York State Energy Research & Development Authority is a prescription for the same disastrous outcome as the pandemic response.

Conclusion

I have enough modeling experience to opine on their use.  Observations always trump model projections.  The reliance on models like the Global Climate Models used to claim that there is an existential threat from climate change can never be properly verified by comparison to observations.  That must always be kept in mind but it has been totally ignore in the New York process.  In addition, the future energy system has to be modeled.  The net-zero transition energy modeling is in two camps.  The academic top-down approach can be verified but the results are unimpressive.  Even the bottom-up models used by the entities responsible for electric system reliability have issues but there is a constant improvement based on refinements to address observations.

This article clearly shows that the Covid response should have relied on the epidemiologists whose observations suggested a different approach more akin to what Sweden did.  “Sweden’s death rate wound up being one of the lowest in the world—4 percent during 2020 and 2021. The U.S. excess death rate in the same period was 19 percent.”  I fear that ignoring the experience of responsible energy experts and relying on theoretical energy system modeling will have similarly disastrous impacts. 

Finally, note that the United States plan for the next pandemic has to be changed.  I can only hope that the advice of D. A. Henderson will be heeded this time.

For the first two months of the year the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) have been working on the  New York Cap-and-Invest (NYCI) Program stakeholder engagement process.  Although I have not posted on this process since I discussed the cost projections, I have been evaluating the pre-proposal outline of issues.  This post summarizes the comments I submitted.

I have followed the Climate Leadership & Community Protection Act (Climate Act)  since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.  Many aspects of the transition are falling behind, and the magnitude of the necessary costs is coming into focus.

Cap-and-Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program.  The program works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate Leadership & Community Protection Act (Climate Act).”  In addition to the declining cap, it is supposed to limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries. The stakeholder engagement process is supposed to refine the proposal over the next several months, DEC will and NYSERDA will propose regulations by summer, and the final rules are supposed to be in place by the end of the year.

Late last year DEC and NYSERDA released the pre-proposal outline of issues that included a long list of topics.  The Agencies said that they are “seeking and appreciate any feedback provided on these pre-proposal program leanings to inform final decisions in the State’s stakeholder-driven process to develop these programs.”  The Pre-Proposal Outline topic list follows:

• The Mandatory Greenhouse Gas Reporting       Program (forthcoming 6 NYCRR Part 253)
  • Types of GHG Emission Sources 
    • Minor Modifications      
    • Major Modifications      
  • Threshold Categories     
  • Data Collection 
  • Verification       
• The Cap-and-lnvest Program             
  • Obligated Sectors and Entities    
  • Demonstrating Compliance        
    • Compliance Periods       
    • Allowance Retirement Obligations        
  • Establishing a GHG Emissions Cap and Allowance Budget          
    • Setting the 2025 GHG Emissions Cap   
    • GHG Emissions Cap Trajectory             
    • Establishing Annual Allowance Budgets        
    • Implementation of Non-Obligated Adjustment   
    • Banking Adjustments     
  • Emissions-lntensive and Trade-Exposed Industries         
    • Identification of EITEs    
    • Emissions Intensity        
    • Trade Exposure 
    • Threshold for EITE Designation       
    • EITE Emissions Allowances             
    • Application and Annual Reporting
    • Consignment of EITE Allowances        
  • Increasing Affordability via Potential Electric Utility Consignment
  • Program Stability Measures and Cost Containment     
    • Price Floor        
    • Cost Containment Reserve (CCR)    
    • Emissions Containment Reserve (ECR)   
    • Price Ceiling      
    • Allowance Banking        
  • NYCI Program Considerations to Ensure No Disproportionate Impacts in Disadvantaged Communities  
    • No Offsets in NYCI          
    • Other Potential Regulatory Mechanisms     
    • Complementary Programs and Requirements         
  • Auction Logistics and Mechanics             
    • Implementation of Auctions             
    • Registration Requirements             
    • Auction Format
    • Simplified Bidding Option             
    • Publication of Results    
    • Initial Auction Period     
  • Market Integrity and Market Manipulation Prevention            
    • Prohibition of Collusion 
    • Auction Purchase Limits
    • Holding Limits  
    • Minimum Hold Times    
    • Associations      
    • Market Monitoring        

Responding to each of these items is an enormous effort and the agencies requested comments by March 1.  Providing substantive comments is very difficult because of a lack of documentation.  There were three second-stage engagement webinars in late January and the session recording and a slide deck is available for each which is the primary source of information.   The agencies promised to provide more documentation but a spreadsheet with some of the data used in the presentations was not available in a usable format until February 29.  The documentation provided does not include narrative descriptions of the analyses.

This perfunctory stakeholder process is consistent with all previous Climate Act stakeholder processes.  The Climate Action Council’s Scoping Plan has been described as a  “true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.”  Similarly, the modeling analyses for the NYCI proposal use an avalanche of technical jargon and impressive sounding phrases to suggest credibility and discourage questions.  They do not provide adequate information for detailed review. 

One of the key questions to be addressed is the limits on emissions set by the allowance auctions.  The modeling analysis must determine the expected emissions starting in 2025 to set the auction limits.  As far as I can tell the analyses used for NYCI projections are updates of the Integration Analysis for the Scoping Plan completed in early 2022.  A lot has changed since that time as inflation, supply chain, and other issues have increased prices and delayed implementation, but it is not clear if those problems were used to modify the analysis.  The Integration Analysis projections have never been reconciled with electric system projections by the New York Independent System Operator.  There has been no acknowledgement of the comments made on the Integration Analysis much less any attempt to incorporate issues raised.  My point is that I do not believe that there is any reason to bother providing detailed comments because past history indicates they will not be considered. 

Core Principles of Cap-and-Invest Program

Instead of wasting my timeaddressing specific technical issues, the comments I submitted only addressed general issues.  I focused my comments on the NYCI principles.  According to the NYCI website, Governor Hochul laid out five core principles for the Cap-and-Invest Program:

Affordability – Governor Hochul’s Consumer Climate Action Account will deliver at least 30 percent in future Cap-and-Invest proceeds to New Yorkers every year to mitigate consumer costs.

Funding a sustainable future – the Climate Investment Account established in the FY24 Budget will direct two-thirds of future Cap-and-Invest proceeds to support the transition to a less carbon-intensive economy.

Climate leadership – The program will be designed with the capacity to link with other current or future programs to further catalyze a nationwide movement towards carbon pricing, which can lower the price of the transition overall.

Creating jobs and preserving competitiveness – The program will launch new investment in industries that will create tens of thousands of good paying, family sustaining jobs of the future that can lift up entire communities.

Investing in disadvantaged communities – Cap-and-Invest will prioritize the frontline disadvantaged communities in our state that for far too long have suffered from pollution and environmental injustice.

The remainder of this article describes my comments on these principles and one overarching concern.

New York Auction Proceed Investment Effectiveness

There is an overarching issue with NYCI planning.  I believe that supporting ambitious clean energy investments is more difficult than acknowledged.  In my comments on the 2024 New York State Energy Research & Development Authority (NYSERDA) Regional Greenhouse Gas Initiative (RGGI) Operating Plan Amendment I explained that I had reviewed the historical investment results of RGGI auction proceeds and found that  RGGI has not been very effective at making emission reductions.  This is the template for NYCI, and the results are not encouraging.  According to Table 2 in Semi-Annual Status Report through December 31, 2022, the cumulative annual net greenhouse gas emission committed savings are 1,725,544 tons through the end of 2022.  That is 9.5% of the observed reduction of 16,196,531 tons since the three-year baseline before the start of RGGI in 2009. I conclude that the primary reason for the observed electric sector emission reductions in New York was due to fuel switching due to low natural gas prices and not RGGI investments. 

These observations are relevant for the future of electric sector emission reductions required for NYCI. In the electric sector, fuel switching is no longer an option in New York.  Coal is no longer used and oil emissions from NYCI affected sources are as low as they are going to get without retirement of oil-fired sources.  The average CO2 emissions reduction per year from RGGI investments has been 95,716 tons since 2013.  New York Part 242 CO2 Budget Trading Program specifies an annual reduction of RGGI allowances of 880,493 per year starting in 2022 and continuing to 2030.  That reduction is nearly ten times more than the reductions from RGGI auction proceed investments.  The Climate Act is going to require even more emission reductions.  Electric generating unit owners and operators have no options available for additional emission reductions other than reducing their operating times.  It is incumbent upon NYCI to invest auction revenues to effectively incentivize and subsidize carbon-free generation and reduce energy use so that the affected sources can reduce operations and not jeopardize system reliability.  The same issues are present for all other energy sectors.  There are no low-hanging options for emission reductions in New York.  If the sources are unable to reduce operations safely, then the Climate Act targets will be jeopardized.

My RGGI Operating Plan Amendment comments determined the cost effectiveness of RGGI investments for reducing emissions.  I found that the cumulative annual net greenhouse gas emission committed savings are 1,923.951 tons and that cumulative total investments are $945,900,000.  That equates to $492 per ton removed.  The 2023 Update to the NYS Value of Carbon Guidance lists the social cost of carbon dioxide, at a 2% discount rate, as $120 per short ton and $391 at a 1% discount rate.  This indicates that the investments are not producing emission reductions at a rate that is less than the societal benefits which suggests a fundamental problem with the NYSERDA investment strategies.  It also indicates that providing sufficient funds for NYCI emission reductions will be a challenge.

In my comments related to this issue I compared the allowance trajectory needed to meet the Climate Act mandates with the proposed allowance prices.  I found that the proposed allowance prices and allowance reduction trajectories are incompatible with the observed RGGI investment results such that the mandates will not be met

Affordability

The Hochul Administration has never clearly admitted the expected costs of the Climate Act net-zero transition.  I believe this is deliberate because the costs are politically toxic.  The first principle “Craft a program to deliver money back to New Yorkers to ensure energy affordability” is an attempt to claim the costs are under control.

My comments raised the point that there is an important tradeoff ignored in this principle. A fundamental component of a greenhouse gas emissions market control program is raising energy prices to incentivize the adoption of zero-emissions technologies.  If costs do not increase, then the public does not have any reason to invest in the more expensive zero-emissions technologies necessary to reduce emissions.

Another issue with any carbon cost scheme is that it is regressive affecting those least able to afford to pay more for energy the most.  I commented that delivering money back to New Yorkers should prioritize low- and middle-income consumers least able to afford regressive energy price increases with investments in programs that reduce their energy use.  This should cut their energy costs and will reduce emissions.

Funding a Sustainable Future

Another bit of missing documentation concerns the funding necessary to make the emission reductions necessary to meet the Climate Act mandates.  The primary Climate Act emission reduction strategy is to displace fossil fuel energy use by building wind and solar while electrifying buildings and transportation.  This principle acknowledges that this needs to be addressed: “Support ambitious clean energy investment”.

My comments emphasized the need for investment in zero-emissions technologies that can displace greenhouse gas emitting technologies.  NYCI allowance allocations must be consistent with Climate Act mandates.  No documentation of a feasibility analysis of the costs and deployment schedule for the proposed control strategies has been mentioned, much less provided.  Ideally, the Integration Analysis projections should be compared to the observed results so that the analysis can be updated.  In my Scoping Plan comments I evaluated bits and pieces but could only nibble around the edges.  Importantly I found issues even at that level that were never acknowledged,

Climate Leadership

The political slogan to “Catalyze other states to join New York and allows linkage to other jurisdictions” has little value.  I do not believe that it is possible to link to other jurisdictions as long as New York GHG emission accounting is different.  Incompatible features with the states of California and Washington and the Province of Quebec include the use of Global Warming Potential based on a 20-year period, the inclusion of upstream and downstream emissions, and the use of offsets.  My comments said that the State must make its accounting compatible or abandon this principle.

Creating Jobs and Preserving Competitiveness

One of the favored Hochul constituencies is labor so the “Protect existing jobs and support new and existing industries in New York” principles was included.  My comments argued that results in Europe suggest that the idea that transitioning away from fossil fuels and maintaining existing Emissions-Intensive and Trade-Exposedindustries is impossible. Robert Bryce explains:

The headline on a February 9 Bloomberg article concisely sums up Europe’s unfolding disaster: “Germany’s days as an industrial superpower are coming to an end.” The article says, “Manufacturing output in Europe’s biggest economy has been trending downward since 2017, and the decline is accelerating as competitiveness erodes.”  All across Europe, industrial capacity is shrinking. Last month, Tata Steel announced it would close its last two blast furnaces in Britain by the end of this year, a move that will result “in the loss of up to 2,800 jobs at its Port Talbot steelworks in Wales.”

These slides and the ongoing destruction of European heavy industry bring to mind the trenchant lines that John Constable of Britain’s Renewable Energy Foundation delivers in our new five-part docuseries, Juice: Power, Politics & The Grid.  Constable, who is also the energy editor at the Global Warming Policy Foundation, delivers a stark warning., he says, “I tell decision-makers in the United States to study the European example very, very carefully. I mean, you have no excuse for not looking at Europe and learning. We’ve tested this for you.”

I do not believe it is possible to create more jobs than lost due to the increased costs inherent in a net-zero transition.  My comments stated that this principle cannot be achieved unless there are triggers to pause implementation when established differences in energy costs are exceeded.

Investing in Disadvantaged Communities

I do not think that the general public understands that the Climate Act includes a strong emphasis on climate justice “to ensure that frontline and otherwise underserved communities benefit from the state’s historic transition to cleaner, greener sources of energy, reduced pollution and cleaner air, and economic opportunities”.  The relevant principle “Ensure 35%+ of investments benefit Disadvantaged Communities” is a direct response the Climate Act requirement to “invest or direct resources in a manner designed to ensure that disadvantaged communities receive at least 35 percent, with the goal of at least 40 percent, of overall benefits of spending.”

New York’s climate justice community organizers have the misplaced belief that peaking power plants in New York City are “perhaps the most egregious energy-related example of what environmental injustice means today”  and are demanding that they be shut down as soon as possible.  However, in the “Role of Cap-and-Invest” webinar the following slide describes the sources that create inhalable air pollution burdens in New York.  It points out that:

• Individually controlled (permitted) stationary sources yield a minority of the air pollution emissions in New York.
• In 2020, electric generation units represented 8.5% of non-wood fuel combustion PM25 emissions in NY, and other permitted sources represented approximately 3.5%.
• Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources.

My comments noted that NYCI should focus on Disadvantaged Community investments that address the emissions from the buildings and transportation sectors that the NYCI analysis shows are the primary contributors to air quality impacts in those communities. 

The same activists have also latched on to outlier analyses that claim that market-based programs lead to disproportionate impacts in disadvantaged communities and are lobbying for market restrictions.   Emission trading programs are an effective solution for emissions like greenhouse gases that have regional or global impacts but are not designed to address local impacts of specific sources.  The Pre-Proposal Outline described the regulatory programs that address local issues.  My comments argued that those programs should be used to address local issues and NYCI should not be modified to try to address co-pollutant emissions with local impacts.

Discussion

One of the characteristics of the proposed net-zero Climate Act transition is over-reliance on the presumption that control strategies that have worked elsewhere will work in this application.  NYCI is a prime example.  However, past performance does not guarantee future success.  This is especially true if fundamental design components change.  Previous successful Environmental Protection Agency allowance caps have been based on feasibility whereas the Climate Act caps are aspirational political limits that have not been tested for practicability.  Options of limits on trading and banking allowances have been proposed that are incompatible to any emissions trading program.  An overarching issue is that control options for SO2 and NOx control are different than for GHG which has unacknowledged implications. 

My submittal included comments on the proposed additional limits on the distribution of allowances intended to address real and imagined issues with past programs.  I did not describe them here because there are too technical.  My comments noted that all these patches overly complicate the program and may or may not have the desired effect while risking unintended consequences.

Conclusion

Hochul’s NYCI principles are political slogans destined to fail.  Claiming affordability is possible is unlikely because NYCI is going to markedly increase prices.  Politicians have glommed on to the auction proceeds and dictated how they should be distributed without consideration of the need to fund effective GHG emission reduction programs.  The goal to link with other current or future programs to further catalyze a nationwide movement towards carbon pricing is impossible with New York’s current GHG emission accounting requirements.  Creating jobs and preserving competitiveness ignores the observed effects of net-zero in Europe.  It is appropriate to invest in disadvantaged communities, but no proof has been offered that those least able to afford increased energy prices will not be adversely impacted even with this principle.

I believe that the political calculus driving NYCI implementation is perverting the effectiveness of this market-based program to the point that it will not work.  I do not think that New York’s leadership understands how best to make climate policy work.  Last year I described the book Making Climate Policy Work.  The authors recommend clear thinking and strategy as opposed to “Efforts spent tilting at ephemeral, magical policy solutions waste scarce resources that should instead be invested in things that work.”  The goal of their book is to explain how market-oriented climate policies have fallen far short and how they might be modified so that they work.  NYCI is just such a magical policy solution that has been modified so it will not work.  I believe NYCI will flounder on the shoals of reality.

I recently had a letter to the editor of the Albany Times Union published asking readers how much they would be willing to pay for the New York Cap-and-Invest (NYCI) Program.  There is a word limit on submittals so this post provides supporting information for that letter.

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 380 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  When political fantasies meet reality, reality always wins.

Published Letter to the Editor

I could not find a link to the letter available to non-subscribers but did get this assortment of opinion pieces from a friend.  The letter is in there somewhere.  The following is the text:

The article “State’s Cap and Invest program unveiled,” Dec. 22, explained that it is intended to fund the transition to zero-emissions energy alternatives. The Hochul administration claims that the costs of inaction are more than the costs of action, but this is just a soundbite slogan. Most benefits are to society, so they do not directly offset the costs of electrification for consumers.

The question New Yorkers want to know is: How much will this cost me? Wind and solar costs increased sharply in 2023 due to changes in commercial conditions driven by inflation, interest rates and supply chain disruptions. Cap-and-invest will add even more costs. Last year, Washington state started a similar program. At the beginning of 2023, gasoline prices in Washington were 72 cents higher than the national average. By October, prices were $1.25 higher. The cost differential relative to the national average increased 88 percent because of the cost of their cap- and-invest program. A similar spike in gas prices will occur here. New York’s program covers all energy sectors, so all energy costs will necessarily increase.

New York greenhouse gas emissions are less than one-half of one percent of global emissions, and global emissions have been increasing by more than one-half of one percent per year since 1990. Therefore, anything New York does will be supplanted by emissions elsewhere in less than a year. That doesn’t mean we should not do something, but it does mean the state should document expected future costs to consumers.

Questions

Before the letter was published, I was asked to respond to questions.  The first requested confirmation of the numbers included.  The second asked about my claim that New York emissions are less than half a percent of global emissions.  This section responds to those questions.

My first claim was that “The cost differential relative to the national average increased 88% because of the cost of their cap-and-invest program.” I responded:

The Gas Buddy website includes a historical gas price graph that I used to estimate the effect on gasoline prices there.  In the following graph I plotted the average gas price in Washington in blue, USA average in red, and the Albany, NY average in green.  The blue arrow points to January 2023 when the Washington cap-and-invest program started and gasoline prices in the state increased relative to the national average.  At the beginning of 2023 gasoline prices in Washington were $0.76 higher than the national average. By October prices peaked $1.38 higher. The cost differential relative to the national average increased 83% because of the cost of their cap-and-invest program. 

My second claim was that “New York greenhouse gas emissions are less than one half of one percent of global emissions, and global emissions have been increasing by more than one half of one percent per year since 1990.” I responded:

I used information from my post Climate Act Emission Reductions in Context dated January 20, 2022 that documented how New York GHG relate to global emission increases.  In response to your questions I updated the analysis.  I found CO2 and GHG emissions data for the world’s countries and consolidated the data in the attached spreadsheet.  There is interannual variation, but the five-year annual average has always been greater than 0.79% until the COVID year of 2020.  The Statewide GHG emissions inventory came out in December but the comparable GWP-100 data that I used from Open Data NY through 2021 are not available.  The analysis relies on last year’s data.  New York’s share of global GHG emissions is 0.42% in 2019 so this means that global annual increases in GHG emissions are greater than New York’s total contribution to global emissions.

Additional information was provided in my post Washington State Gasoline Prices Are a Precursor to New York’s Future.   That post showed that there is an obvious link between Washington’s new cap and trade program and gasoline prices.  I found that the cost of Washington gasoline has risen more relative to the price increases elsewhere so that now Washington has the highest prices in the nation.  The first two auctions for the Washington cap-and-invest program sold 14,770,222 allowances and raised $780,829,117 averaging $52.87 per allowance.  According to the US Energy Information Administration 17.86 lbs of CO2 are emitted per gallon of finished motor gasoline which means that 112 gallons burned equals one ton.  That works out to $0.47 a gallon needed to cover the cost of allowances necessary to purchase the allowances and that is a unique Washington cost adder.

Discussion

The Energy Policy Institute at the University of Chicago did a poll in early 2023 poll with “the Associated Press–NORC Center for Public Affairs Research” explored Americans’ attitudes on climate change, their views on key climate and energy policies, and how they feel about electric vehicles and the policies to encourage them.  The following chart from that report shows that 38% would be willing to pay an additional $1 a month for a fee to combat change and only 21% would be willing to pay $100 a month.  Based on my analyses I think the total all-in cost for a household to comply with proposed carbon fee is going to be a lot closer to $100 than $1 a month.

Conclusion

My next post is going to describe a recent webinar, “Preliminary Scenario Analyses” (slides and recording) that is part of this year’s New York Cap-and-Invest (NYCI) Program stakeholder engagement process.  The webinar offered the first glimpse of potential costs for NYCI and I will compare some of the expected costs with the poll results described above.

There is no question in my mind that most New Yorkers have no clue how much this will cost.  I also believe that the Hochul Administration is keeping the costs hidden as much as possible because they know that support for the program would evaporate.  I appreciate the Albany Times-Union publishing my letter as part of my quixotic quest to stop implementation before it is too late.

On January 23, 2024 the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) hosted the first webinar of this year’s New York Cap-and-Invest (NYCI) Program stakeholder engagement process.  This post presents my initial impressions of the first webinar in a series of three. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 380 articles about New York’s net-zero transition. 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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.  Many aspects of the transition are falling behind and the magnitude of the necessary costs is coming into focus.  When political fantasies meet reality, reality always wins.

Cap-and-Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide Cap-and-Invest Program.  It is supposed to establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries. Cap-and-Invest will ensure the state meets the greenhouse gas emission reduction requirements set forth in the Climate Leadership & Community Protection Act (Climate Act).

The reality is different particularly because environmental activists want to remove certain components that have made similar programs work in the past.  Further background information is available at my carbon pricing initiative page.

NYCI Implementation

The NYCI website describes the implementation plan:

This process will solicit crucial feedback from individuals and stakeholder groups to build out an equitable program that balances interests while ensuring the State meets its greenhouse gas emission reduction objectives. New York’s Cap-and-Invest Program will draw from the experience of similar and successful programs across the country and the world that have yielded sizeable emissions reductions while catalyzing the clean energy economy.

In the First Stage of Pre-Proposal Outreach DEC, and NYSERDA hosted a series of webinars in June 2023. DEC and NYSERDA have now entered into the Second Stage of Pre-Proposal Outreach and will continue to host workshops to gather feedback on the program as we develop regulations to implement the Cap-and-Invest Program. See the Events page for more information on upcoming webinars and recordings of past webinars.

In this stage of the pre-proposal outreach DEC and NYSERDA are seeking feedback on a outline of questions and descriptions for NYCI implementation.  They want feedback by March 1 and plan to have the regulation in place by the end of 2024.   The first webinar described the role of NYCI. Subsequent webinars will review the pre-proposal outline and describe an analysis of expectations for allowance prices and emissions trajectories.  I will address those webinars here as well.

Webinar Overview

The entire webinar was scripted.  Each presenter read their remarks and it even appeared that the responses to questions were vetted.  For example, in the overview Doreen Harris, President of NYSERDA read the Guiding Principles for NYCI.  The narrative is that under Governor Hochul’s direction, New York’s cap & invest program will incorporate these guiding principles:

• Affordability. Craft a program to deliver money back to New Yorkers to ensure energy affordability
• Climate Leadership: Catalyze other states to join New York, and allows linkage to other jurisdictions
• Creating Jobs and Preserving Competitiveness: Protect existing jobs and support new and existing industries in New York
• Investing in Disadvantaged Communities: Ensure 35%+ of investments benefit Disadvantaged Communities
• Funding a Sustainable Future: Support ambitious clean energy investment

She mentioned that two thirds of the revenues collected will be used to support the transition but that they would be looking for suggestions for investments.

Jonathan Binder from DEC gave a high-level overview of NYCI.  He explained that the “Climate Action Council’s final Scoping Plan recommends – and Governor Hochul’s 2023 State of the State Address and the FY 2024 State Budget advanced – an economywide Cap-and-lnvest Program.”  He noted that DEC and NYSERDA have been developing the plan to implement NYCI.

The following slide describes the emission reduction requirements.  Note that between 2021 and 2030 NYS GHG emissions will have to decrease from 368 million metric tonnes (MMT) to somewhere under 246 MMT.  This represents a reduction of 33% but there was no mention of feasibility.  It was mentioned that the plan is to get on the trajectory to meet the 2030 target.

Ona Papageorgiou continued the overview description.  The following slide shows how NYCI is supposed to fit in with other programs, investments, and regulations.  She also described the role of NYCI following the narrative script.  First, there was the obligatory comment that “New Yorkers are feeling the effects of climate change.”  In yet another misunderstanding between weather and climate the script said “In 2023 alone we experienced air choked with wildfire smoke, flooding in NYC and the Hudson Valley, extreme snowstorms in Buffalo, and more.”  No mention was made how NYCI could possibly affect those weather events given that New York’s emissions are less than half a percent of global emissions.

The script made the point that “Cap-and-invest and similar programs are internationally accepted as a core component of a credible decarbonization strategy.”  I agree that this approach is widely used.  The script went on to state that the Climate Action Council’s Scoping Plan recommended cap-and-invest as the most cost-effective means of achieving decarbonization. For the record, that was taken as an article of faith and not proven.

The following two statements in the script hint at the ramifications of the plan.  It claims that “Cap-and-invest ensures New York will minimize costs by reducing emissions first in sectors where it is cheapest to do so.”  That is the theory so I will not disagree.  The second statement includes my highlights:

NYCI pairs a disincentive for continued use of fossil fuels with robust funding to support the energy transition. It is an essential complement to existing investments and regulations intended to reduce emissions and drive a clean energy transition.

Therein lies the ramification for New Yorkers.  The disincentive for continued use of fossil fuels is to make it expensive enough that users will switch to other technologies or use less.  For anyone who does not have the option for another technology or who cannot meaningfully use less fossil fuel the NYCI result is a regressive tax on energy use.

The narrative script claimed that “cap-and-invest and similar pricing mechanisms are a well-tested mechanism for addressing climate change.”  New York has been a big proponent of the Regional Greenhouse Gas Initiative (RGGI) and the script claims that RGGI achieved 50% reduction in CO2 emissions.  That statement is simply wrong.  I blog about the details of the RGGI program.  I have found that although CO2 emissions in the RGGI region are down around 50% since the start of the program, RGGI funded control programs have only been responsible for 6.7% of the observed reductions.  When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $927 per ton of CO2 reduced.  Both of these findings should be of concern, but they are not even acknowledged.

Vlad Gutman-Britten (NYSERDA) read the script for the “Cap-and-Invest Program: How it Works” section of the webinar.  He explained:

• Large-scale GHG emitters and distributors of heating and transportation fuels will be required to purchase allowances for the emissions associated with their activities.
• NYCI will incentivize businesses and other entities to transition to lower- carbon alternatives.
• Proceeds will support:
  • Consumer Climate Action Account that will deliver at least 30 percent in future Cap-and-Invest proceeds to New Yorkers every year to mitigate consumer costs.
  • Industrial Small Business Climate Action Account that will deliver up percent in proceeds to support energy affordability for small businesses.
• Climate Investment Account that will direct two-thirds of future Cap-and-Invest proceeds to support the transition to a less carbon-intensive economy.

A series of slides were presented that described how cap-and-invest programs are supposed to work.  The first slide showed example marginal abatement costs across a curve.  In this slide it shows that there are choices that will result in lower emissions (green wedge).  Those choices are made “based on upfront costs, costs over time to operate, and other factors.” Example: an LED lightbulb costs more up front but reduces electricity costs over time.  Even though this an illustrative example there is no expectation that there are enough of these options to get to the Climate Act target limits.

A cap-and-invest program is supposed to modify the costs of control strategies.  The following slide explains the general approach.  Note that it explicitly says these programs include trading and banking.  There is a vocal minority of ideologues who think that trading and banking is inappropriate.  For example, Assemblywoman Kelles has introduced A08469 that “establishes an economy-wide cap and invest program to support greenhouse gas emissions reductions in the state “ that includes the requirement  that it “must be implemented with input from impacted communities to avoid the harms we have seen from other pollution pricing mechanisms that have relied on ‘trading’ the right to pollute disadvantaged communities”.  It is encouraging that the webinar confronted this mis-conception head on.

The next slide in this series explained that when a cap-and-invest program is implemented investment decisions change.  The added cost of the allowances makes “Investment in pollution reductions become cost effective because it’s cheaper to cut those emissions than purchase allowances (yellow wedge)”.  In my opinion, however, the incremental costs of the allowance price necessary to make those investments cost-effective is higher than what is politically acceptable.  I guessed that that in order to make the emission reductions needed investments between $15.5 and $46.4 billion per year will be required.  I don’t think that range is politically palatable.  The slide also pointed out that proceed investments can be used to reduce emissions so that decision-makers will have “even more of an incentive to choose to invest in decarbonization (orange wedge).”

The next slide addressed flexibility mechanisms that are included to address unforeseen circumstances.  They are proposing to include price stability features included in RGGI: a price floor, emissions containment reserve, and a cost containment reserve.  They explain that they are:

“intended to make the system resilient to unexpected changes—sharp and unanticipated emission reductions (e.g., the transition away from coal) or energy shocks (e.g., as witnessed during COVID-19).”  The slide emphasizes the price ceiling explaining that “If clean energy technology faces substantial barriers (supply chain issues, inadequate workforce, unavailable mitigation options, etc.)” that without some restrictions that costs could explode.  The proposed solution is “a price ceiling where unlimited compliance instruments are issued at a predetermined price.”  This limits emission reductions temporarily until the market catches up.  These allowance are explicitly created just for this compliance requirement.  That ensures that facilities will not shut down because they don’t have sufficient allowances.  Among the many unresolved issues is what that means to the Climate Act targets.  If they have exceed the limit but kept the lights on and did not induce an artificial energy shortage that is a good thing.  But the climate activists will have a fit.

The next slide addresses a fundamental issue of a single jurisdiction GHG emissions reduction program intended to address a global problem.  When New York acts alone its programs can cause “leakage” i.e., “shifting activity out of New York and to other locations with higher emissions.”   New York industry is already among the most efficient in the country which makes further improvements more costly and reduces the potential total reductions.  The NYCI pre-proposal recommends “providing no-cost allowances to industry at risk of leakage in amounts that decline every year”.  This sounds fine in theory but in practice I suspect it will not be very effective.

Hillel Hammer (NYSERDA) read the script for the “Current Emissions” section of the webinar.  This session set the stage for the Preliminary Analysis Overview webinar later in the week.  That analysis is supposed to cover emissions and costs.  Environmental Justice advocates have created a story that peaking power plants in New York City are “perhaps the most egregious energy-related example of what environmental injustice means today”  and are demanding that they be shut down as soon as possible,   The single-minded focus on the evils of these facilities extends to demands that NYCI not increase emissions within disadvantaged communities (DACs) near the power plants.  According to the script inhalable particulate (PM2.5) emissions are primarily from other sources.  The following slide shows that “Individually controlled (permitted) stationary sources, including electric generation units, large industrial sources, and large commercial and institutional sources represented approximately 4% of the total.”

The next slide describes the sources that create inhalable air pollution burdens in New York.  It points out that:

• Individually controlled (permitted) stationary sources yield a minority of the air pollution emissions in New York.
• In 2020, electric generation units represented 8.5% of non-wood fuel combustion PM25 emissions in NY, and other permitted sources represented approximately 3.5%.
• Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources.

The message is that addressing permitted stationary sources does not address the bulk of the problem in DACs.

The next slide addressed electricity sector emissions.  It states that:

• Existing policies will go a long way to addressing sources of emissions in the electric sector.
• RGGI, the Clean Energy Standard, and other programs will substantially reduce the use of fossil fuels for our electricity needs.
• The Peaker Rule will ultimately retire the most polluting plants in New York. 35 peaking units representing 955 MW have already retired and an additional 265 MW are expected to retire in 2025.
• NYCI cannot be designed to compel the closure of individual generators, and pricing may not reduce the use of peaking facilities.

The final item bluntly points out that NYCI is the wrong tool to use to try to shut down the peaking power plants.  During the presentations and in the pre-proposal outline the DEC has suggested that their preferred approach is to limit emissions from sources in DACs using permit conditions in other programs.  I agree with DEC on this line of reasoning.  Trying to control a local air quality problem with a GHG emissions program designed to address global impacts is absurd.  However, logic and reason are not the primary drivers of the environmental justice advocates.  They rely on emotion.  It will be interesting to see if they accept these arguments or demand something different.

The next slide addressed transportation emissions:

•              Advanced Clean Cars II and Advanced Clean Trucks will drive substantial uptake of zero emission vehicles across all classes.

•              Commitments to all-electric school buses will support change for those vehicles that directly burden children.

•              Investments like the Clean Transportation Prizes target market transformation in the most impactful geographies.

•              NYCI would provide essential revenue and price signal to ensure achievement of existing policies in addition to advancing greater ambition.

In this slide and the previous one, the transformation claims in the bar charts are based on the Integration Analysis.  Based on my evaluation of the draft Scoping Plan analyses that used the Integration Analysis I am skeptical of the emission reductions expected.

The final slide associated with the emission reduction policies claims that “NYCI will accelerate New York’s emission reduction policies and programs that advance building decarbonization”.  This is where the claims deserve more attention.  It says that “NYCI will put electricity on a more level playing field with fossil fuels, helping support building efficiency and electrification”.  That occurs when the cost of carbon added by NYCI makes fossil fuels more expensive and reduces the present cost advantage of fossil fuels relative to electricity.  It claims that “In particular, NYCI will support adoption of heat pumps, especially replacing heating oil.”  However, everything I have seen suggests that heat pumps are already cost competitive with heating oil furnaces but that they are nowhere close for natural gas furnaces.  The final bullet point says that “NYCI will create a new investment mechanism for building transition.”  Presumably that means that revenues from the auction will subsidize building electrification.

The other section of this slide states that “NYCI will also help deploy zero emission vehicles faster than with current policies alone”:

• This is especially the case for medium and heavy-duty vehicles and non-road engines, where existing regulations are less stringent than for light duty. Diesel engines are also especially impactful in many Disadvantaged Communities.
• NYCI will even the playing field for clean transportation, and the revenue will create financial support also for hard-to-electrify vehicles, supporting not only focused investment in electrifying these impactful sources, but also growth of hydrogen fuel cell vehicles used in long- haul heavy-duty and non-road applications.

While the theory suggests, and the results may show some benefits, I do not think there will be meaningful impacts.  This is another situation where the demand is inelastic, and the alternatives have so many downsides that it would take an enormously expensive carbon cost to justify meaningful conversions.

There was a session on “Delivering Equitable Benefits” but I am not going to discuss them much here.  One point made does deserve mention “The Climate Act requires that DEC’s NYCI regulation not result in net increases in co-pollutant emissions or disproportionately burden disadvantaged communities”.  The DEC and NYSDERDA analysis need to prove that is the case.

Conclusion

I was worried because environmental activists want to remove certain components that have made similar trading programs work in the past.  The DEC and NYSERDA proposal confronts that line of reasoning in order to preserve the expectations that NYCI will work the same as other programs.

There is an enormous effort necessary to get this program in place and operational by the end of the year.  I don’t think it is possible and I suspect that there are insufficient resources at the state agencies to make it even close.  Unfortunately, the likely outcome is a poorly designed and implemented program.  Worse it could end up causing more problems and adding costs.  Stay tuned.

Sometimes I just don’t have time to put together an article about specific posts I have read about the net-zero transition and climate change that I think are relevant.  This is a summary of posts that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described are related to it. 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. The opinions expressed in this article 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.

New Year’s Prediction

I predict the following definition of unexpectedly will be used to describe a spike in the cost of energy prices in New York.  Unexpectedly: adv. Frequently used by people who don’t know what they are doing, to describe unpleasant events or situations they have created.

Spain Renewables

An article at the Institute for Energy Research titled “Spain Increases its Renewable Share but Soon May Need to Replace its Windmills”  highlights the aggressive renewable energy transition for Spain.  Their plan has aggressive plans to implement wind and solar, includes manufacturing for almost the entire supply chain for wind turbines, and has a “green” hydrogen goal.  Some noteworthy takeaways:

• “Spain’s new government goal to double wind capacity means it would need to almost triple wind installations from current annual rates.?  At the same time, “over one third of the existing turbines must be replace within five years.”  In my opinion, the goal is unlikely.
• “The wind industry in Europe, including Spain, is facing billion-euro losses, mainly due to competition from China, which has been developing its clean energy resources for decades and offers lower prices due to cheap coal power and government subsidization.”  New York renewable manufacturing cannot escape the same competition problem.
• The draft climate strategy sets a 2030 target of 11 gigawatts for electrolyzers, which would be used to make green hydrogen, up from 4 gigawatts.  I would like to find a place where I could bet that will never happen.

Francis Menton and I both have wondered which jurisdiction’s net-zero transition plan will implode first.  Based on this article, I would say Spain is coming up fast to the leaders.

Wind turbine threats to birds and bats

A company in Australia uses dogs to count the victims of wind turbines in southern Australia. 

The numbers are troubling. Each turbine yields four to six bird carcasses per year, part of an overall death toll from wind turbines that likely tops 10,000 annually for the whole of Australia (not including carcasses carried away by scavengers). Such deaths are in the hundreds of thousands in North America. Far worse are the numbers of dead bats: The dogs find between six and 20 of these per turbine annually, with tens of thousands believed to die each year in Australia. In North America, the number is close to a million.

It is interesting that “Ecologists have noticed that small bat species in particular are most likely to get struck by the blades when wind speeds are relatively low, around 4.5 to 11 miles per hour.”  This means that the impacts to bats could be reduced by reducing operations during light winds when bats are present.  Because they hibernate the turbines would still be available during those periods in the winter and in the summer the days are shorter so most of the time the turbines could be operating.  I have not heard anyone suggest this commonsense mitigation technique or any other one in New York.

An Egregious Failure of Scientific Integrity

Roger Pielke Jr. notes that NOAA’s “billion dollar disasters” report this week:

On Tuesday, the U.S. National Oceanic and Atmospheric Administration (NOAA) will release with great fanfare the year-end update of its “billion dollar disaster” tally. If past is prologue, NOAA will vigorously promote the dataset in collaboration with environmental NGOs, reporters on the climate beat will uncritically parrot and amplify NOAA’s claims, and before long, the dataset will find itself cited in the peer-reviewed literature, identified by the U.S. government as a key indicator of human-caused climate change, and perhaps even cited by the U.S. president in support of the claim that all U.S. disaster costs are attributable to climate change.

In his post he shares a new preprint of a paper that he submitted to the new Nature journal, npj Natural Hazards. My paper, which was invited by the journal’s editors, is titled, Scientific Integrity and U.S. “Billion Dollar Disasters.”  Pielke is not impressed with the disasters data set:

The NOAA billion dollar disaster dataset comprehensively falls short of NOAA’s guidelines for scientific integrity. The shortfalls documented here are neither small nor subtle. They represent a significant departure from NOAA’s long-term history of scientific integrity and excellence, which has saved countless lives and facilitated the nation’s economy. A course correction is in order.

He concludes that despite all the problems, it will eventually get sorted out because “science and policy are both self-correcting”.  I do not disagree that the absurdity of the “existential threat of climate change that we are seeing before our eyes” narrative will ultimately fall apart.  The question is whether it will fall apart before we go so far down the road of a disastrous energy policy that people freeze to death in the dark.

Press Release – Empire Wind 2 Offshore Wind Project Reset

Empire Wind is being developed through a 50-50 joint venture between Equinor and bp. Empire Wind 1 and 2, have a potential capacity of more than 2 GW (816 + 1,260 MW).   However, the developers announced on January 3 that they were going to terminate the Offshore Wind Renewable Energy Certificate (OREC) Agreement for the Empire Wind 2 project. 

This agreement reflects changed economic circumstances on an industry-wide scale and repositions an already mature project to continue development in anticipation of new offtake opportunities. The decision recognizes commercial conditions driven by inflation, interest rates and supply chain disruptions that prevented Empire Wind 2’s existing OREC agreement from being viable.  

Equinor and bp believe offshore wind can be an important part of the energy mix and are committed to maintaining substantial contributions to the state and local economy.  

“Commercial viability is fundamental for ambitious projects of this size and scale. The Empire Wind 2 decision provides the opportunity to reset and develop a stronger and more robust project going forward,” said Molly Morris, president of Equinor Renewables Americas. “We will continue to closely engage our many community partners across the state. As evidenced by the progress at the South Brooklyn Marine Terminal, our offshore wind activity is ready to generate union jobs and significant economic activity in New York.” 

Long story short, they saw an opportunity to get more money from New Yorkers and leapt at the chance.  Now the question is whether the Hochul Administration’s will reassess the cost impacts to New Yorkers.  Sorry, I had a memory lapse – they have never provided consumer cost estimates so why would they start now.

This is another summary of updates I made to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates and I also have highlighted a few recent articles that don’t fit my needs on those pages.

I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I maintain them both.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

I ran across an intriguing video that sums up the future of New York’s energy future under the Climate Leadership and Community Protection Act and linked to it in my page for lessons to be learned from others.  Andrew Bolt describes the effects of green energy policies on Australia.  He makes that point that “willful ignorance” on climate change is making people “poorer and weaker”.  New York is not as far along as Australia on our transition but the same thing is going to happen here.   

I updated theClimate Claims page that addresses the alleged threat of a climate driven existential threat with links to a two part series by Kip Hansen “Reprise — Why I Don’t Deny: Confessions of a Climate Skeptic”.  Hansen updated his original five-year old articles after a conversation with a colleague who’s only understanding of the issue came from main stream media.  The articles update the originals with newer information.  In the first part, he describes the temperature and explains that the temperatures have been increasing since 1650 – 1700.  That is important because that is 150 to 200 years before the start of increased GHG emissions associated with the industrial revolution.  He explains that he agrees that global warming is happening and  human activity causes [some of] it.] but he does not agree with the assertion that CO₂ and other anthropogenic emissions  are “the dominant cause of the observed warming since the mid-20th century.”  He says that he disagrees with the attribution and the effect size.

In the second article Hansen provides his reasoning for this position.  He shows that sea-level rise that is also attributed to anthropogenic warming follows the temperature record.  It has been rising since 1700 when it bottomed out at the end of the Little Ice Age.  He also presents data on snow and ice cover that behave similarly.  He concludes that:

The IPCC and the Climate Science community have, so far, failed to rule out the CO₂ driven global warming hypothesis —  nothing more.    They have, however, shown in their historical reconstructions that the main bodies of evidence their hypothesis relies on — surface air temperature, sea level rise, snow and ice cover —  all started changing long before CO₂ concentrations could possibly had any appreciable effect.

I also added a link to Judith Curry’s latest presentation on climate uncertainty and risk.  She gave a 20-minute presentation at the ICCC Conference and the blog post summarizes the main points.  She does a great job explaining “what we know, versus what we don’t and cannot know” and how that should but does not affect climate policy.  It all comes back to how climate risk is characterized and she argues that is not being done will today. 

I updated my renewable energy feasibility page with this zoning requirements link.  Kevon Martis has prepared wind and solar zoning talks that have the pro-renewable groups spun up because they effectively provide information to keep local control of wind and solar siting.  Robert Bradley writes about a hit piece describing him of sowing fear and misinformation about renewable energy.  When asked by people wanting help, Martis gives a 40-60 minute wind or solar zoning talk, answers questions and then goes home. The links to the two talks are here and here. 

The Climate Act and all its components repeatedly claim that that weather events are getting worse as the justification for the net-zero transition.  I provide examples of problems with those claims at the Climate Change Impacts page.  The Climate Fact Sheet: January 2023 Edition addresses media claims in January 2023 that all run counter to the popular narrative.  

I added a link on my Electric Vehicle Issues page “Are electric vehicle charging stations really worth taxpayer money?”.  Steve Goreham looks into the costs of electric vehicle charging stations and concludes that it’s unlikely that charging fees can cover the capital and operating costs of public chargers or make money for investors.  Ultimately, he predicts that public charging stations will eventually owned by the electric utilities paid for by higher electricity prices and hidden subsidy costs to consumers.

Finally, I have added a page with links to relevant videos.  The following videos are included:

Climate Science

• Unsettled Climate Science:  Link is to a post that includes videos of a discussion between Jordan Peterson and Steven Koonin, on-line material, and a couple of debates.
• Climate Change: What do scientists say? Prager University presentation by Richard Lindzen

New York Net-Zero Transition

• Andrew Bolt describes the effects of green energy policies on Australia.  He makes that point that “willful ignorance” on climate change is making people “poorer and weaker”.  New York is not as far along as Australia on our transition but the same thing is going to happen here.   
• The Federation of Polish Sportsmen hosted a presentation about the Climate Act on February 16, 2023 that is a good overview of New York specific issues.

Implementation Issues

• Mark Mills: The energy transition delusion: inescapable mineral realities shows that the amount of mining necessary to provide the raw materials needed for the net-zero transition is so large that the transition is impossible.
• Li-Ion battery fires: Paul Christensen, Professor of Pure and Applied Electrochemistry at Newcastle University in the United Kingdom gave a presentation at PV magazine’s Insight Australia event in 2021 that describes the risks  of thermal runaway fires in li-ion batteries. His videos of thermal runaway tests are terrifying.   
• Problems with hydrogen: Link to a post with a video and description of contents

Climate Change Issues

• Ronald Stein interview with The Epoch Times
• Climate Science What does it say Lindzen
• Tom Nelson interview with Javier Vinós on the search for natural climate change.
• Why there is no ‘climate crisis’  debunks the hysterical claims of an existential threat
• The Bias in Science Jordan Peterson interview of Richard Lindzen
• The models are OK the predictions are wrong.  Jordan Peterson interview of Judith Curry

Originally published at Climate Etc.

Russel Schussler and Roger Caiazza

Electric generation plans need to be well crafted and carefully considered. Because of concerns around  climate change many politicians have become galvanized to hastily enact legislation to target  net-zero anthropogenic greenhouse gas emissions by 2050.  The authors argue that the more seriously you take climate change, the more important it becomes that you have a good plan for electric generation in the near and midterm planning arena.  Taking foolish actions in the near to mid-range time periods will not help with CO2 reductions or climate change and may be far worse than doing nothing.  Maybe we all could compromise and find a less grand something that has more likely benefits with far fewer threats to reliability, affordability, and overall environmental impacts.

The authors have both been writing about the proposed net-zero transition by 2050 for years.  Schussler (aka the Planning Engineer) has been writing about the challenges of “green energy” since 2014 at the Judith Curry’s Climate Etc. blog.  Caiazza has focused on New York energy and environmental issues at Pragmatic Environmentalist of New York blog since 2017.  Since the original proposal for New York’s Climate Leadership and Community Protection Act (Climate Act) in 2019, he has written over 280 articles about that plan to transition to net zero by 2050.

Traditional Generation Planning

Utilities used to look at 30-year time periods in developing their generation expansion plans.  This was not because they believed anyone could forecast what might happen 30 years into the future, but rather because of the recognition of the futility of such efforts. Decisions were made about the next ten years or so, but the later years tested the flexibility of the plans.  Because power plants have a long life, many different scenarios were studied in the additional 20 years or so after the plant addition.  Commercial technologies were supported by more dependable cost and performance estimates than what could be obtained for newer technologies, but it was recognized that all parameters could change across any technologies.  Scenarios would vary fuel prices and availability, potential environmental requirements, as well as other varying system requirements. Back then, no one had the hubris to say this is what the system would, or should look like 20 or 30 years from now.  Planners sought to make decisions that would be flexible enough to work well across a variety of future potential scenarios. The hope was for this plan to work with and adapt to the emerging future. 

Some jurisdictions have made commitments to completely transform their electric generating systems in less than 30 years.  Rather than intending to be flexible in the mid to long term, these plans are often overly prescriptive. This post addresses the potential consequences and suggests a less risky approach.

New York Climate Act

New York’s Climate Act is a good example of prescriptive net-zero legislation.  Implementation to meet the following inflexible targets has begun:

• Reduce GHG emissions to 60 percent of 1990 emissions levels by 2030;
• Zero GHG emissions from electricity production by 2040; and
• Reduce GHG emissions to less than 15 percent of 1990 emissions levels by 2050, with offsets to reduce net emissions to zero.

New York passed the Climate Act in 2019 effective 1/1/2020.  The legislation established a Climate Action Council to prepare the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040.  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  The Final Scoping Plan was completed at the end of 2022.  In 2023 the New York State Department of Environmental Conservation and the Legislature are supposed to promulgate the necessary regulations and legislation to fulfill the recommendations in the Scoping Plan. 

There are deep flaws in the New York implementation process.  The Scoping Plan is just an outline list of control strategies that NYSERDA claims will reduce emissions as needed and provide reliable electricity.  NYSERDA, New York State Independent System Operator (NYISO), and New York State Reliability Council (NYSRC) have not done a consolidated feasibility analysis that addresses the fundamental question: will it work?  There are significant differences between the Final Scoping Plan and NYISO 2021-2040 System & Resource Outlook.  The following figure from the Resource Outlook summarizes the key findings that are applicable to any net-zero by 2050 initiative.  Our biggest concern is that both resource projections rely on untested technology.  The Resource Outlook notes:

By 2040, all existing fossil generators are assumed to be retired to achieve the Climate Act target for a zero-emission grid and are replaced by Dispatchable Emission-Free Resources (DEFRs). These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors).

What are the characteristics of Good Plans versus Bad plans

In this section we consider the characteristic and provide commentary in italics relative to the New York Scoping Plan.

Bad plans assume that critical elements of the future are all known.  Bad plans are narrowly constructed to a specified future. They risk not allowing the flexibility to adapt when things turn out differently than was planned.  Good plans look at their impacts or current decisions across a wide variety of potential futures.  Good plans provide flexibility and nimbleness for when future conditions change. 

The NY Climate Act electrifies as much as possible to decarbonize and presumes all the elements necessary to accomplish the transition are known.  The critical element of future expected load must be well known to determine generation resource requirements.  Future net-zero load is a function of increased electricity for heating, cooking, water, and electric vehicles at the same time there is increased emphasis on energy efficiency and conservation.  Projections in this instance are anything but well known.

Good plans understand that the power supply system and power grid are very complicated systems requiring careful design, construction, and operation.  Great consideration is given to the architecture of the system and how it will work.  A poor plan leaves the power system and grid as an unplanned afterthought.  It specifies some goals and ingredients but ignores the greater system.

The basis of the Climate Act electric grid transition plan is the wind, water, and solar (WWS) approach championed by Stanford University Professor Mark Jacobson.  The approach had outsized influence on the members of the Climate Action Council but there are issues with this work.  Advocates of this particular transition approach have overstated its findings, it does not put appropriate emphasis on the high load and low renewable resource problem, and understates the challenges of a quick transition to a zero-emissions electrical grid.

Bad plans are one-size fits all.  They employ a presumption of what is best and fail to take in the particular specific considerations that can vary across time and place.  Good plans recognize that what works in one area, may be less appropriate in another. Good plans seek to capitalize on differing advantages wherever and whenever they may occur.

The New York electrical grid is pretty much two different grids.  There is a traditional grid Upstate but there are unique problems in New York City.  Experience has shown that sufficient in-city generation must be available to account for the loss of a transmission line into the New York City load pocket or blackouts can occur.  The Scoping Plan does not adequately address these differences in their on-size fits all plan.

Good generation plans recognize how people prefer to use electricity.  If behavior needs to be changed, they are sensitive to the capabilities and limits of incentives.  Depending on the generation mix the value of electricity will likely vary considerably across hours, days, months, and seasons.  Good plans will seek to provide value.  Bad plans tend not to differentiate between when and how energy might be supplied.  Plans crafted based on just average use and average costs will likely not have good results.  Traditionally generation planning recognized baseload, intermediate and peaking needs. While many seem to forget these distinctions when comparing alternatives, their importance has not diminished. 

The New York plan presumes that net-zero transition to net-zero required changes to personal energy choice preferences will be universally accepted.  The behavioral changes required by the Scoping Plan are massive (e.g., type of vehicles, heating your home, and cooking your food). Furthermore, there may be limits on the timing of electric usage.  Modeling assumptions on the effects of these changes to personal habits are important for planning but also very uncertain if people do not make the changes expected.   It is highly unlikely that load shifting and energy conservation will prevent a markedly higher electric load peak in winter mornings.  The Scoping Plan compounds these issues because it does not adequately address the baseload, intermediate and peaking requirements naively arguing that “smart” planning will mitigate issues associated with them.

Good plans look at major environmental impacts across the production and lifetime of a resource.  Bad plans tend to look only at marginal impacts when the facilities are operating.  Tremendous resources and costs are incurred just getting a generating resource in place. Generally, the longer that resource can operate, the better its average environmental impact might be.  Good plans should consider the realistic lifetime of potential resource.  Many “green” resources projected to last 30 years fall far shy of 20 years.  Conventional resources typically are capable of lasting many years beyond the thirty-year study life. 

The Climate Act takes this concern to a higher level.  Many life-cycle environmental impacts of fossil generating resources are considered.  None of the life-cycle environmental impacts of wind, solar, and  energy storage are considered.  The Integration Analysis assumes that all wind, solar, and energy storage resources keep operating from the present until 2050.  Furthermore, the Climate Action Council has tried to appease climate justice advocates who fervently believe that the risks of fossil-fired generating resources are so great that existing resources must be shut down as soon as possible.  Their concern is at odds with consideration of environmental impacts across the production and lifetime of all resources.

Good plans rely on proven technology that can fulfill the specific requirements.  For example, providing power for periods of peak load is required for reliable power when it is needed most.  Peak loads are typically associated with the hottest and coldest periods of the year when electricity is used for cooling and heating.  Typically, those periods occur less than 5% of the time so a technology should be as low cost as possible to keep the price of electricity down during peak loads.  A good plan would make the sensible decision to keep an old fossil fired plant around to help the system meet peak loads.  Fossil-fired steam boiler electric generating units are a proven technology that can be used to meet this need.

For many years New York City peak load requirements were met with simple-cycle gas turbines installed in the early 1970’s.  However, those units were old, inefficient, and had unacceptably high emission rates so, after a multi-year process of reliability planning the State has instituted a regulation to phase them out.  After the regulation was promulgated the Environmental Justice (EJ) community glommed on to the issue of peaking power plants: “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today”.  Even though the poorly controlled peaking turbines are being phased out, the issue remains a point of contention.  Now the EJ organizations are demanding that all fossil-fired power plants in New York City be shut down including the remaining steam boilers even though they meet all emission limits and do not contribute to the alleged health benefits in disadvantaged communities near the facilities.  The proposed solution to use renewable energy and energy storage replaces proven technology with one that has not been proven on the scale necessary to keep the lights on in New York City.

Bad plans presume that a new technology can fulfill specific needs.  A necessary component of any future system is dependable emergency capacity.  For example, a system might need emergency capacity once every five years due to extreme weather either causing very high loads, an unexpected long-term outage of existing resources, or because of an extended drought of wind and solar resources.  A bad plan proposes a new technology for this emergency requirement. In order to provide capacity in a zero-emissions electric system a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) has been suggested to keep the lights on during periods of extended low wind and solar resource availability.   In Wyoming, PacifiCorp’s 2021 integrated resource plan (IRP) includes a resource labelled as “non-emitting peaker plants” that is unexplained but appears to be the same as DEFR. The New York Independent System Operator (NYISO)  2021-2040 System Resource Outlook states:

DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.

 In both instances no specific technology has been specified.  The New York Scoping Plan DEFR placeholder is producing and storing “green” hydrogen for use when needed.   

This is the fatal flaw of the New York Scoping Plan.  The NYISO 2021-2040 System & Resource Outlook states that “To achieve an emission-free grid, Dispatchable Emission-Free Resources (DEFRs) must be developed and deployed”.  This magical resource does not exist!  The Scoping Plan uses “Green” hydrogen as a placeholder for the technology and predicts that it will be used on average around 3% of the time.   The fantasy of the Scoping Plan is that developing the infrastructure to produce hydrogen, store it, and then produce electricity in hydrogen fuel cells can provide affordable and reliable energy to keep the lights on.  The costs will be astronomical for a resource used so little presuming that the technological issues can be overcome.

What are the ingredients of a compromise plan?

As mentioned above good plansrecognize how people prefer to use electricity.  Electricity usage across a region rarely drops to zero, but at times demand peaks for limited periods of time.  It may make sense to build high fixed cost, low variable cost resources (Nuclear, Coal and Combined Cycle) to meet the baseload needs of system.  If the plant can run all the time with low variable cost the higher investment cost can be justified.  It does not make sense to put in such facilities to serve load levels that only occur rarely. For this component of the load it makes more sense to put in low cost infrastructure that might have higher marginal costs.  Between these two conditions there are loads levels that may be present for a few hours a day.  To meet these loads, it is usually better to put in plants with moderate costs and moderate marginal costs.  This is the thinking behind traditional utility planning which looked at peaking, intermediate and baseload needs in terms of generation fitted for those specific characteristics. There is one other type of generation, intermittent.  Intermittent typically was low-cost generation that although it could not be counted on, it could be used to back off generation using higher priced fuels.  In looking at the ingredients below it will helpful to consider where they may be most appropriate. 

Wind, Solar and Batteries can work to displace fossil fuel generation.  With backup from batteries the energy provided can be made to have more value.  Unexpected and innovative changes in the capabilities of batteries could be a game changer, but it is too soon to count on timing in this arena.  The narrative that these “zero-emissions” resources have zero downsides is false.  The construction of wind and solar takes a lot of resources; their construction has a lot of environmental consequences; and fabrication uses a lot of energy that will be difficult to displace away from fossil fuels (making steel for example). 

Nuclear power works well to meet baseload needs.  It also works supports the transmission system providing needed electrical characteristics commonly called Essential Reliability Services.   Nuclear plants can be planned and operated to provide some ramping and load following capabilities.  Nuclear offers the best opportunity to reduce dependence upon fossil fuels for electric generation because it is the only proven technology with no emissions that can be scaled up in the immediate future.

Hydro expansion is very unlikely.  Environmental considerations make it unlikely that additional locations for hydro generation could be developed.  Similarly, there are limited opportunities for additional pumped storage, but there may be some areas where such might be pursued.  Finally, geothermal plants when feasible are a good resource, but opportunities for exploiting this resource are limited.

Natural Gas combustion turbines and combined cycle are best suited to fill in the gaps when reliable and functional generation additions are needed. As more environmentally desirable units become capable of doing the job, eventually new construction should be halted and  existing units phased out as they age.  Keep in mind the US through fracking reduced CO2 more effectively than Germany did with their massive expenditures on “clean” resources.

Existing Resources such as coal- and oil-fired boilers should not be ignored for future plans.  It is extremely unlikely that new plants burning those fuels will be built in the US in the foreseeable future.  Clean coal was on the table a few years back, but highly visible failures coupled with environmental concerns have closed this door for a while.  The cost differential between oil and natural gas as well as the efficiency relative to a combined cycle combustion turbine precludes construction of oil-fired boilers.  However, the existing fleet of these plants could be kept around for limited peaking power needs, emergency power, and long-term temporary system needs.

Other potential ingredients to a future plan include technologies currently on the drawing board.  Examples include tidal energy, biofuels, fusion, big HVDC ties and so on.  These new technologies will have to prove themselves before they are employed as anchoring technologies in good plans.  Most new technologies will not prove themselves in the next 10 to 20 years if history is a guide.  But some might.  While we can’t dependably plan on unproven technology, we must be ready to jump on anything valuable that works.  Such technology will likely be available and workable in niche applications many years before they can be deployed more broadly in long term plans.

Smart Grids have also been touted as a component of future electric systems.  This is a favorite approach of visionary academics, to concerns about observed and emerging grid problems.  In the New York net-zero transition planning process many issues were dismissed with a call for “Smart Grids” as if that would magically solve everything.  Modern grids are “smart” but as  with any “smart” technology there are all kinds of applications that could be adopted, so of course it is not a panacea for future grid plans.

Energy Efficiency is another favorite future grid resource for the naïve.  When concerns about peak loads and the necessary infrastructure are raised, the response is to double down on energy efficiency and energy conservation programs to flatten the peak loads.  Of course, if the goal is to decarbonize by electrifying everything, then the load will have to increase to cover building heating, cooking, and hot water.  Add in battery electric vehicles and this approach can only hope to reduce the peak but it will never eliminate the need for a peaking power generation resource.

A Good Enough Plan

Assuming the plan is a compromise between net zero and a working power system, the biggest step would be to commit to getting as much nuclear power as possible into the mix as soon as possible.  This best supports the grid and reduces CO2.  We need to figure out how to get plants built more efficiently and quickly. Adding nuclear must be the centerpiece and driver for meeting emerging generation needs.  Under reasonable regulations, it is the only zero-emissions technology that can be scaled up and provide reliable and dispatchable power.

 The continued massive ramp up of wind and solar does not make sense currently.  There are major reliability concerns which would emerge with the introduction of high level of intermittent asynchronous wind and solar power.  Such programs distract from the needed focus upon nuclear programs.  As technology improves and better resource choice emerges, large scale existing wind and solar that requires some sort of dispatchable emissions-free resource are likely to become dinosaurs.

At this time, it appears that plans for the addition of fossil-fired plants would center around the gaps where new nuclear power can not be made available or meeting peak demand levels not met by current resource plans.  Natural gas plants will be a good compromise.  Lower cost combustion turbines will have long term value to aid with ramping, meeting peaking needs and providing emergency power.  Higher cost more efficient combined cycle plant will make sense the longer the delay for nuclear development.  They can serve variable load levels that occur regularly but vary considerably day to day.

The potential for additional hydro is low, but any ability to effectively exploit remaining opportunities should be considered.  Additionally, some areas may offer the potential for the addition of  pumped storage hydro or geothermal power  Hopefully battery technology will improve and its ability to support energy needs and the grid can be expanded and amplified.

The authors have recognized for years that the economics, even without all the environmental and regulatory considerations, will not support building a new steam boiler plant in the US.  Gas is just too cheap in the US compared to coal or oil.  New coal is a non-starter given the need for elaborate and expensive pollution controls.  However, this does not mean it makes sense to retire functioning coal, gas, and oil plants. In many cases they will be the best emergency back resource available across the board considering economics, environmental impact, and reliability. 

There is another economics aspect of our good enough plan that needs to be stressed.  The plan does not require the development and deployment of the magical dispatchable emissions-free resource that is a necessary component in a electric system that relies on wind, solar, and energy storage.  Eliminating the cost of a brand-new resource to fulfill a very limited role will make this approach cheaper than any net-zero alternative.

There is a segment of society that is invested in the need to do “something” about climate change by mitigating emissions.  A good enough plan would support R&D on clean technologies for future generation, energy storage, and transmission system support.  Currently, these clean technologies are simply not ready to provide reliable and affordable energy.  The developing world will not use zero-emission technologies until they can provide electricity cheaper than existing resources so this R&D is necessary for a global solution.   In addition, if the full life-cycle impacts of those technologies are considered, then they are not nearly as “clean” as commonly portrayed.

Conclusion

The proposed good enough plan provides direction but is not overly constraining. It’s hard to know the future, but it’s a safe bet that any plan will not anticipate some critical twists that will emerge down the road. This plan would lay a strong foundation.   A major shift to the nuclear plants that are the obvious best choice for baseload power, supplemented with natural gas units, and retention of on the ground facilities should be the framework of a good enough plan.  Good enough plans are also flexible so integration of newer technologies when and as warranted is a reasonable attainable path without major downsides. This good enough plan may get you to net zero before the more ambitious ones.  It is likely to have less carbon emissions than the more aggressive plans over time.  It certainly will be more reliable and affordable.