New York Accelerated Renewable Energy Growth and Community Benefit Act

On February 21, 2020 New York governor Andrew Cuomo proposed a 30-day budget amendment that will “streamline the process for environmentally responsible and cost-effective siting of large-scale renewable energy projects across the state”. The proposed legislation, if adopted, will create a new Office of Renewable Energy Permitting to streamline the consenting process for large-scale projects across New York.  This post addresses this latest hypocritical over-reach of the Cuomo Administration.

Permitting Process

New York’s Environmental Conservation Law requires NY regulatory agencies to consider environmental impacts equally with social and economic factors when making permitting decisions and that they must balance those factors when making a decision to approve an action.  New York has different rules for different sized projects.  For any electric generating facility greater than 25 MW in capacity the permitting requirements are specified in Article 10.  The Power NY Act of 2011 established the process for siting generating facilities in Article 10.  That law established a multi-agency siting board and was supposed to streamline the permitting process.  Unfortunately, its requirements are so strict that it is still unwieldy and cumbersome.

As on February 25, 2020 there are 49 projects in the active Article 10 queue.  There are 16 wind facilities proposed with 899 turbines generating 3,117 MW.  There are 25 solar projects proposed for 3,914 MW of capacity and 4 solar projects with storage proposed for 740 MW of capacity covering at least 11,324 acres.  There also are three gas-fired projects and one waste energy project.  Since the new requirements were established only five projects have been approved with two completed in 3.2 years, two completed in 3.5 years and one in 4.5 years.

The governor’s office said the state’s existing process for energy-generating sites was designed for plants that used fossil fuels and created before new clean-energy standards were put in place.  The existing Article 10 process is cumbersome but the insinuation that only fossil fuel facilities have significant enough environmental, social and economic impacts to warrant a complete review of the potential impacts is a stretch in my opinion.

Cuomo’s Environmental Impact Hypocrisy

There is no better illustration of the Cuomo’s administration hypocrisy than the decision to block the Finger Lakes LPG project.  On July 12, 2018, New York State Department of Environmental Conservation (NYSDEC) Commissioner Basil Seggos issued a decision for a proposal to construct and operate a new underground liquefied petroleum gas (LPG) storage facility for the storage and distribution of propane in the town of Reading in the Finger Lakes region of New York.  The decision denied the permit applications for the proposed project on the grounds the facility would have a significant adverse impact on community character in the local area and the Finger Lakes region.  In my post on that decision I pointed out that the community character rationale was based on the State Environmental Quality Review Act section: “impacts to noise and aesthetic resources as revealed on the current record are essential components in the evaluation of impacts on community character in the context of this proposed project”.

So how did the Finger Lakes LPG project affect community character? The project proposed modifications during the application process to reduce the scale and environmental impacts of the project in response to local stakeholder concerns.  The modifications eliminated the proposal to store liquid butane at the facility and reduced the underground propane storage capacity from 2.1 million barrels to 1.5 million barrels; eliminated the project’s rail and truck loading facilities so all deliveries of liquefied petroleum gas would be by pipeline; eliminated one of the brine ponds; and, for lack of a better term offered bribes as they proposed to “provide resources ranging from financial resources to technical resources (mining data) to support community initiatives for the preservation and improvement of water quality in the area, including Seneca Lake”.  The unacceptable aesthetic community character of final proposed plan of the Finger Lake LPG Storage project was a brine pond, a compressor station, and a support building.  The unacceptable noise community character of the project was two electric 75 horse power pumps to pump product from the tanks into the pipeline to the electronically driven injection pumps despite the likely use of insulated walls and advanced fan technology to dampen sound.

It is unclear how an Administration that claimed that Finger Lake LPG Storage project’s minimal aesthetic and noise projected impacts affected community character so badly that the project could not be permitted but can somehow claim that industrial wind and solar project don’t also affect community character.  As noted, there are at least 899 wind turbines and solar panels covering at least 11,324 acres in the existing permitting queue.  Consider, for example, the aesthetic impact of the Ball Hill Windpark.  This facility has been approved (note that it was note permitted under Article 10) to install 29 wind turbines generating around 100 MW with 13 miles of access roads, 5.7 miles of above-ground utility lines, a substation, a switchyard and an operations and maintenance building.  According to the 2018 Proposed Modifications Summary of Environmental Impacts wind turbines will be visible in 33.9% of the area within the 5-mile viewshed.  According to the 2008 Environmental Assessment Form the smaller turbines originally proposed would be visible from greater than 5 miles from a parcel of land which is “dedicated to and available to the public for the use, enjoyment and appreciation of natural or man-made scenic qualities” and “an overlook or parcel of land dedicated to public observation, enjoyment and appreciation of natural or man-made scenic qualities”, and a “site or structure listed on the National or State Registers of Historic Places” and between ½ and 3 miles to a State Wildlife Management Area.

 Environmental Protection

Cuomo is quoted as saying: “Climate change is the existential challenge of our time, and New York State has risen to the occasion by enacting the strongest laws in the nation to protect and preserve our environment” It is utter hypocrisy to claim to protect and preserve our environment while simultaneously proposing to circumvent the permitting process that “Requires environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws”.

As far as I can tell the State Administrative Procedure Act (SAPA) and the State Environmental Quality Review Act (SEQRA) requirements for environmental reviews do not apply to the Climate Leadership and Community Protection Act (CLCPA).  One of the requirements of an air quality assessment for a new fossil-fired electric generating unit is to consider the cumulative impact of all local emitting sources as well as the new source itself.  While I think that while an individual industrial wind facility or solar facility may not have a significant environmental impact the cumulative impact of all the facilities required by the CLCPA to provide enough power to meet the reliability needs of the state could have significant environmental impacts.  I don’t think it is fair to ask each renewable energy developer to consider cumulative impacts but I also don’t think that cumulative impacts can be ignored.

The obvious solution would be for the state to evaluate cumulative impacts.  Note, however, that the first step for such an analysis would be to determine how many wind turbines and solar panels would be required and where they would be located.  The CLCPA is just starting the process to prepare a scoping plan that will document the state’s plan to implement the law.  First problem is that scoping plan won’t be available for a couple of years.  In the meantime, I have prepared my own estimate of the renewable resources necessary to meet this legislation.  In order to meet the mandate that all electricity will be generated by non-emitting sources in 2040 and provide enough power to cover the needs of an example winter peak period I estimate that New York will require 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind.  If the on-shore wind turbines are rated at 4.8 MW that mean that over 3,845 on-shore wind turbines.  Using numbers from one of the solar permit applications, I estimate that 176 square miles will be needed to meet the 16,117 MW of utility scale solar estimate.  The bottom line is that while an individual industrial wind facility or solar facility may not have a significant environmental impact the cumulative impact of 176 square miles of utility-scale solar panels and at least, 3,845 on-shore wind turbines certainly could have negative environmental impacts.

Conclusion

The Niagara County Legislature recently passed four resolutions directed squarely at an amendment to revise the Article 10 rules.  The amended rules only said that if there were minor changes to the proposed facility it did not require the entire application process to be opened up again.  In other words, it was a relatively innocuous change as opposed to the Governor’s plan to entirely ignore the Article 10 process.  Niagara County and other Upstate New York municipalities are already upset that Article 10 has taken away control of local siting decisions.  This proposal to remove the checks and balances included in Article 10 will not be appreciated.

The CLCPA is all style and no substance.  There is no plan to convert all energy sectors away from fossil fuels only a mandate to do it.  If there is no plan then there are no costs, no quantified benefits, and no starting point to balance environmental impacts with social and economic factors for the state as a whole.  The Article 10 permitting process requires that kind of assessment on the local level.  Cuomo’s proposal to remove that check would mean that anyone, anywhere in New York State that could possibly be affected by anything related to the ambitious plan to convert the New York energy to carbon-free resources will have no recourse.  I suspect that when the folks who whined their way to get the Finger Lakes LPG project cancelled are going to be more than a little upset when industrial wind and solar facilities blanket their community.

Rare Snow Storms Today are Blatantly Obvious, Not

This post describes another evaluation of anecdotal evidence that is portrayed as evidence of global warming.  Previously I looked at a NPR radio segment in Great Lakes Vineyard Confronts Climate Change and examined a claim by a senior official at the Department of Environmental Conservation in Hay Harvest Climate Trend?.  This post addresses the frequency of snow storms in my home town.

Thread Posts

On the Facebook page “If you grew up” for my Oneonta, NY hometown group someone posted a conversation starter about the Old Farmer’s Almanac forecast for this winter.  This is the post that got me started:

“The winters we had when we are young are gone. It’s rare when we get a major storm. Amazing how much it has changed in 50 years – but people still deny the blatantly obvious.”

I responded to the first post with:

“If you look at the data rather than rely on anecdotal information and your memory (when I was a kid the snow came up to my waist all the time), then you will find that no one is ignoring the blatantly obvious. See for example: reference and reference

That prompted this response:

“The source you cite is suspect at best. Reference

I responded to that with this:

“My advice is to not trust anybody on any aspect of the global warming problem or purported solution.  Check out the numbers and data yourself.  The posts I referenced showed where they got their data and their data show that there is no “blatantly obvious” snowfall trend. Despite the “suspect” web site I stand by that position.”

That prompted this response:

“You are welcome to your opinions and to selectively choose which data you want to use, but opinions are just that. Some people also firmly believe that vaccines are horrible based on one dubious study that has been disproved, others believe the world is flat. The issue is that the climate is changing faster than it normally would due to man’s activity – some areas are getting dryer, others wetter, overall the temperature is rising but in some areas it will get colder. To dismiss the vast majority (@97%) of trained scientists and the blatantly obvious evidence in favor of the very loud deniers doesn’t make the 3%’s points valid. Reference

My response:

“I said check the numbers and data yourself.  In this instance all I am saying is that don’t confuse weather and climate.  Just because it some observed weather phenomenon is different does not necessarily mean it is related to global warming.

When you combine saying that climate is changing faster than normal due to man’s activity with the suggestion that disagreeing dismisses the vast majority of trained scientists, it is misleading based on my check of the claim and survey.  I think trying to determine the rate of climate change and figure out how much of the observed climate change is due to mankind is too difficult to be conclusive.  I have not found any survey that asked the policy relevant question about the rate of change and man’s actitivity.  Instead they basically asked whether there was a greenhouse effect.

I also said don’t trust anyone.  Search on 97% climate scientist myth and then search to find the other side of the story then decide for yourself.  Trying to do a similar comparison for the rate of climate change and contribution of mankind is more difficult so I don’t think you can do something similar easily.  Although I think I can offer a trained scientist opinion don’t trust me even though I have two degrees in meteorology, certification as a consulting meteorologist and over 40 years experience.”

Approach

First, let’s define weather and climate.  According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”

The Northeast Regional Climate Center data sets provide processed values for temperature and precipitation for many observing sites in New York.  If global warming is affecting the winter storm climatology then there should be trends in either or both the daily snowfall or snowfall accumulation data.  In a previous analysis of weather vs. climate perception I analyzed data from Ithaca, NY which is just about 90 miles away from Oneonta. Because it was readily available and I think representative of snowstorms in Oneonta, I just used the data from that site for daily snowfall and snowfall depth.  I also said trust no one so if anyone wants the data I can provide that for your own analysis.

I did a simple analysis of the daily snowfall and snowfall accumulation.  In both cases, I fit a linear regression model to describe the relationship between the daily values and time for the months November, December, January, February, and March. I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses because it enables the user to choose the best relationship from 27 different linear regression equations.  I determine which linear regression model provides the best fit and then use that model to describe the data. If the calculated probability value (P-value) is less than 0.05, there is a statistically significant relationship at the 95.0% confidence level and I defined the test result as significant.

Results

The purpose of this analysis was to determine if the frequency of major snowstorms in Central New York has changed due to climate change.  In this analysis I looked at climatic changes over the period of record from Ithaca and calculated the trend over the entire period for daily snowfall amounts and daily snowfall depth.  The Ithaca, NY Daily Snowfall Depth December 1899 through March 2019 figure shows quite a bit of variation.  Although there is a statistically significant increase in daily snow depth over this period the trend is only one inch per century.    Given the variation across the graph I do not consider this to be meaningful.  TheIthaca, NY Daily Snowfall (Inches) figure similarly shows so much variation that claiming any kind of trend is dicey but there also is a statistically significant increase in daily snow fall.  These data show that there is no trend towards fewer storms.

So why is there an impression that it is rare that Oneonta no longer gets major storms?  In the Ithaca, NY Extreme Daily Snow Depth and Snowfall (inches)table note that if the winters when you were young were around 1960 there were a couple of years when the snow depth was over 24” out of six in over 100 years.  Similarly, if your youth was in 1971 and 1972 there were two storms with snow over 16” out of the eight storms in over 100 years.  No question that would give the impression that the winters were different in your youth.

Another important point to keep in mind is that you could change the results by picking a different starting point for the analysis.  I also suspect that you could get different results by screening the data differently.  The choices I made were the simplest.  One you start tweaking input assumptions you can be rightfully accused of statistical manipulation.

Conclusion

These data illustrate the point I tried to make in the Facebook posts.  In my experience, whenever I have looked at the data behind a climate change related claim it was more complicated, more uncertain, and often contradictory to the claim made.   It is also difficult to separate whether the observed phenomenon is just weather variability or climate trend.

This post does not prove that there isn’t climate change, that mankind is not having an effect on climate, or that it isn’t appropriate to do something. If this were just a simple scientific disagreement it could be shrugged off as inconsequential.  Unfortunately, in New York State this kind of anecdotal evidence has been used to justify last summer’s Climate Leadership and Community Protection Act (CLCPA) which has been described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act. Look at those references to get a feel for what is in store for New York.

I have spent a lot of time trying to figure out what this law could mean.  For example, my latest estimate for the cost for the energy storage batteries needed when winds are light at night during the winter is $176.3 billion through 2050.  The United Kingdom has similar legislation in place and it was recently announced that their plan would require conversion of all gas central heating to electric.  I expect no less here.  As a result when I see anecdotal information used to justify these costly programs I have to respond.

Hay Harvest Climate Trend?

At a recent meeting I ran into Lois New who, before she retired, was the Director of the New York Department of Environmental Conservation’s Office of Climate Change.  I have known her for years and we worked together during RGGI stakeholder meetings. During our conversation she mentioned that her neighboring farmers were seeing the effects of climate change because they were having more trouble getting hay in before winter.  I said I thought it was more likely weather, she disagreed, and that ended the conversation.  This post looks at data to see if there is, in fact, a climatic trend for worse weather for haying.

First, let’s define weather and climate.  According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”

New York State policy is all in that there is an imminent and inevitable climate change catastrophe that can only be averted if we do something.  In this case New York’s version of doing something is the Climate Leadership and Community Protection Act (CLCPA) which was enacted last summer.  It is described as “the most ambitious and comprehensive climate and clean energy legislation in the country”.  When Governor Cuomo signed the bill he said:

“The environment and climate change are the most critically important policy priorities we face.  They literally will determine the future – or the lack thereof. Even in today’s chaos of political pandering and hyperbole there are still facts, data and evidence – and climate change is an undeniable scientific fact.”

In order to rationalize these statements Governor Cuomo has a long history of attributing any observed unusual or extreme weather to climate change’s effects being seen today.

Paul Homewood at the Not a Lot of People Know That web page authored a couple of recent articles slamming NY Governor Cuomo for a couple of examples. The first article points out that his statement that “we did not use to have hurricanes, we did not have super storms, we did not have tornadoes” is dead wrong.  The second article entitled “Cuomo’s Fake Claims About Extreme Rainfall” noted that Cuomo implied in an MSNBC interview (referenced in the blog post) that extreme rainfall was getting much worse in NY State.  However, Homewood showed that “there is absolutely no evidence of that at all” at the long running Ithaca station or a New York City station.

As a member of the Governor’s inner climate circle Ms. New must have been a part of the public relations campaign justifying the CLCPA.  Her claim that farmers cannot complete harvesting hay because of climate change is entirely consistent.  This post will look at the facts, data, and evidence that there is a climate effect on haying.   Homewood referenced a link to precipitation data at http://climod2.nrcc.cornell.edu/ which is what I needed to do this analysis.

Approach

According to Mother Earth News in a Guide to Growing, Harvesting and Baling Hay “there are three steps involved in turning a green crop into what can rightfully be called hay:

      1. Cutting (followed by partial drying.)
      2. Windrowing (followed by further drying.)
      3. Baling hay or stacking hay.”

For our purposes the key is that freshly cut hay has to be dried because if hay is tied into tight bales when it still contains moisture it will go through a curing process that creates heat which can lead to self-combustion.  Therefore, farmers do not want to bale their cut crop until the moisture is less than 20%.  To do that the cut grass is allowed to dry for up to several days, then raked into rows and allowed to dry out most of the moisture.  Once dry then the hay can be baled.

The Northeast Regional Climate Center data sets provide processed values for temperature and precipitation for many observing sites in New York.  I chose to look at two stations with long records: Ithaca (1894-2019) and Mohonk House (1896-2019 with 1899 missing).  I downloaded the daily maximum, minimum, and average temperatures, precipitation amount, snowfall amount, snow depth and growing degree days.  A growing degree is the difference between average temperature in deg F and 50.  For example, if the average daily temperature is 60 deg F then there are ten daily growing degree days for that date.

I assumed that in order to harvest hay that the farmer would need to have at least four days when there was no precipitation greater than 0.05”.  Whenever that threshold was reached or exceeded the Harvest-Day parameter was set to one.  The total number of days that met this criterion in each month was summed along with the number of growing degree days per month for the growing season that I set as May through October.

I did a simple analysis of the two data sets.  I calculated the growing degrees and number of harvest days for each month in the growing season that I defined as May 1 to October 31.  I summed these values for the whole growing season.  I also summed values for the fall hay harvest season that I defined as August and September.  I fit a linear regression model to describe the relationship between growing degree days and hay harvest days by year for the whole growing season and just August and September. I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses because it enables the user to choose the best relationship from 27 different linear regression equations.  I determine which linear regression model provides the best fit and then use that model to describe the data. If the calculated probability value (P-value) is less than 0.05, there is a statistically significant relationship at the 95.0% confidence level and I defined the test result as significant. In addition, I calculated simple statistics to describe the two data sets.

Results

The purpose of this analysis is to evaluate the claim that farmers are having more trouble getting their hay harvested because of climate change.  If that were in fact the case then we would primarily expect to see a trend in decreasing hay harvest days and to a lesser extent a decrease in the number of growing degree days.  The linear regression statistical results for two sites over the entire growing season and August and September were evaluated.  Overall eight tests were done with the following results:

Mohonk Growing Season hay-harvesting days

      • Insignificant reduction in the number of hay-harvesting days over the growing season

Mohonk Growing Season growing degree days

      • Significant increase in the number of growing degree days over the growing season

Mohonk August and September hay-harvesting days

      • Significant increase in the number of hay-harvesting days in August and September

Mohonk August and September growing degree days

      • Significant increase in the number of growing degree days in August and September

Ithaca Growing Season hay-harvest days

      • Significant reduction in number of hay-harvesting days over the growing season

Ithaca Growing Season growing degree days

      • Significant reduction in growing degree days over the growing season

Ithaca August and September hay-harvest days

      • Insignificant reduction in number of hay-harvesting days in August and September

Ithaca August and September growing degree days

      • Significant reduction in growing degree days in August and September

Of the eight tests: three were consistent with the hypothesis that getting hay harvested is getting more difficult because hay-harvesting days and growing degree days decreased, three were inconsistent with the hypothesis because hay-harvesting days and growing degree days increased, and two tests were statistically insignificant.  Note that if growing degree days are going down that is an indication that temperatures are cooling and not warming.

Another way to look at the climate change impact is to statistically evaluate the data.  The Ithaca Hay Season Climatological Normal and Last 30 Year Dataand the Mohonk House Hay Season Climatological Normal and Last 30 Year Data tables include climatological normal data, the last 30 years of data, and summary statistics.

I believe that one way to check climate change claim effects is to check the 30-year average from the beginning of the period of record with the 30-year average at the end of the period of record.  I also believe that there are multi-year weather cycles of differing lengths and if that is the case then arbitrarily picking these two periods may not be representative.  Therefore, consider this comparison with caution. At Mohonk House the growing season hay harvesting days decreased by two days but the August and September days increase by three days.  The Ithaca growing season hay harvesting days decrease by five days but the August and September days stayed the same.

Importantly, these data also indicate that there is a lot of inter-annual variation in hay harvesting days.  The standard deviation of the August and September data at Ithaca was 6, the minimum was 2 and the maximum was 28. At Mohonk House the standard deviation was 8, the minimum was 0 and the maximum was 43.  The difference between the first 30-years and the last 30-years is less than the standard deviation variation.  Therefore, I don’t think it is reasonable for anyone to claim that they can discern a climatic trend.

So why is there an impression that hay harvesting is getting worse?  A quick review of the last 30 years of data indicates to me that this impression is consistent with weather variations.  At Mohonk House in 2014 and 2015 there were a couple of years that were great for hay harvesting with half the days (31) in August and September suitable.  Jump forward to the last two years and there were only 11 and 12 days suitable.  In that short time frame of reference an alarming trend is evident.  However, also recall that the average number of hay harvesting days is 18 and with a standard deviation of 8.  So even though  2018 and 2019 data suggest there may be a problem, the data are within one standard deviation of the mean which means that they are well within natural variation observed since 1896.

Conclusion

The points that I want readers to remember are that climate numerical analysis results are likely ambiguous, picking a climatic trend out of weather records is not simple, and, most importantly, any statistically significant trends are likely smaller than the observed inter-annual variation.   As a result, anecdotal claims of observed changes of weather parameters due to climate change are likely biased and unsubstantiated.

This data analysis shows ambiguous results.  It suggests that there is conflicting support for a climate-change induced problem with hay harvesting in August and September.  Mohonk House data indicate a statistically significant trend in more days suitable for harvesting hay whereas Ithaca data indicate a trend towards less days suitable for harvesting hay but the trend is insignificant.  At both stations there is a negative statistically significant trend in the number of growing degree days.  Depending upon your intent, statistics can “prove” an argument that there is a problem or there isn’t a problem.

In order to do a comprehensive analysis to settle the question would take a lot of work.  Before doing any more analysis work, the evaluation data used should be confirmed as appropriate.  In order to represent the New York region adequately, stations across New York and the region would all have to be analyzed similarly.  It might also be appropriate to look at each month when haying is done.

I think the comparison of possible trends against inter-annual variation is illuminating.  If there is a climate change signal the difference between the first thirty years of the records with the last thirty years should show changes.  What differences that do exist are smaller than the observed variations.  All changes are less than one standard deviation from the mean.  I believe that this is a consistent problem for lines of the so-called evidence for climate change impacts observed in New York.

Based on this analysis I believe that anecdotal claims of observed changes of problems with hay weather parameters due to climate change are likely biased and unsupported by the data.  The variations noted and ascribed to climate change are in fact due to weather.

I also think that similar analyses of other claims would provide similar results.  The Governor’s claim “Even in today’s chaos of political pandering and hyperbole there are still facts, data and evidence – and climate change is an undeniable scientific fact” and his tendency to blame any unusual weather on climate change are not supported by this analysis.  In my opinion, careful evaluation of data and evidence for most of his claims would find similarly ambiguous and less certain results.

NYS Green New Deal Announcement Summary

Governor Cuomo recently announced the New York State Green New Deal a “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”. I think that the Governor and advocates for this agenda need to explain how this will work, how much it will cost and how much it will affect global warming before we are committed to this path.

This summary of the program is one of a series of posts on the New York State Green New Deal. Cuomo billed this as part of his 2019 Justice Agenda: “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”. There were 12 proposals in part 4 “Launching the Green New Deal” of this agenda. I reference my summary posts on each below and include my indented and italicized comments.

Components of the Green New Deal

Mandate 100 Percent Clean Power by 2040 – This will mandate that all electricity will be “carbon free by 2040.

In 1977 there was a blackout in New York City and the New York System Independent Operator now has a rule that requires 80% of generation to be provided in-City. In 2017 the daily energy needed for the peak hour period was 219,078 mWh. Because renewable energy is diffuse the area needed for that much renewable power is likely unavailable within the City. This could be a fatal flaw in this mandate and the State must develop a plan to confront this reality.

New York’s Path to Carbon Neutrality – The heads of relevant state agencies and other workforce, environmental justice, and clean energy experts will develop a plan to make New York carbon neutral.

The path re-establishes a Climate Action Council and mandates a plan to meet the goals. Presumably they will use existing programs as a template. If the New York Green New Deal were to rely on the “successful” RGGI program for the reductions proposed the State is looking at a cost of $35.2 billion.

A Multibillion Dollar Investment in the Clean Tech Economy that will Reduce Greenhouse Gas Emissions – There will be $1.5 billion in competitive awards to support 20 large-scale solar, wind, and energy storage projects across upstate New York.

The competitive awards announced in January 2019 total $1.5 billion and are supposed to provide more than 2 million tons of carbon reductions. Assuming that they really meant carbon dioxide for the 2 million tons that means 750 dollars per ton reduction cost. In 2015 NYS electric sector CO2 emissions were 32 million tons. If the New York Green New Deal were to rely on the NYSERDA competitive award process for those reductions the State is looking at a cost of $24 billion.

Expand NY Green Bank and Catalyze at Least $1 Billion in Private Capital – The NY Green Bank is a $1 billion investment fund designed to accelerate clean energy deployment and they will expand its charter.

In order to reach the 100% clean power goal by 2040 the plan doubles distributed solar deployment to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023. If the Green Bank were to finance the deployment of 3,000 MW at the rate observed with their existing investments they would need over $2 billion. In 2015 NYS electric generation sector emissions were 32,000 tons. If the Green Bank was to finance the replacement of solar at the rate observed they would need over $41 billion.

 Chart a Path to Making New York’s Statewide Building Stock Carbon Neutral – There are plans for more energy efficiency investments.

New York State is the fourth most energy efficient state in the country now which is no small part due to investments already made which presumably improved the most efficiency at the lowest rate available. Given that the cost-effectiveness of future projects will be less the 20% further reduction goal is ambitious.

Direct State Agencies and Authorities to Pursue Strategies to Decarbonize their Investment Funds and Ramp Up Investment in Clean Energy – Commence a process to review and evaluate the feasibility and appropriateness of divesting from fossil fuels for agencies and authorities.

I think the most important investment strategy for the $240 billion dollars in New York funds should be economic rather than signaling virtue. The rationale for this mandate to divest is clear: divestment is not an investment strategy, or a way of putting direct economic pressure on energy companies. It is a political statement.

Increase Carbon Sequestration and Meet the U.S. Climate Alliance Natural and Working Lands Challenge – This will establish a carbon sequestration goal for our natural and working lands.

Based on results to date it is not clear how cost-effective these programs will be. However, the program that facilitates carbon sequestration in soil is a “no regrets” solution.

Create a Carbon-to-Value Innovation Agenda and Establish the CarbonWorks Foundry – This will create a Carbon-to-Value Innovation Agenda as a blueprint for the future of carbon-to-value technology as well as carbon capture, utilization and storage in New York.

The concept is to turn carbon dioxide into fuel and wasteful chemicals. While I am not a chemical engineer the idea that the waste products can be turned into a fuel without a whole lot of energy going back into the system seems a bit far-fetched. On the other hand the concept of using CO2 instead of sequestering it underground is appealing.

Deliver Climate Justice for Underserved Communities – The Green New Deal will help historically underserved communities prepare for a clean energy future and adapt to climate change by codifying the Environmental Justice and Just Transition Working Group into law and incorporating it into the planning process for the Green New Deal’s transition.

While no one argues that underserved communities should not be treated better, I am concerned that the direct costs of these programs will out-weigh any directed benefits. In my opinion the primary goal of the task force should be to keep electric energy affordable but it is not clear that is the first priority of this component of the plan.

Create a Fund to Help Communities Impacted by the Transition Dirty Power – This will provide funding to help communities that are directly affected by the transition away from conventional energy industries and toward the new clean energy economy

In my opinion this is an example of the political pandering of the Green New deal. If some block of voters is going to be disadvantaged then simply buy them off.

Develop Clean Tech Workforce and Protect Labor Rights – The Green New Deal will continue to require prevailing wage, and the State’s offshore wind projects will be supported by a requirement for a Project Labor Agreement.

In my opinion this is an example of the political pandering of the Green New deal. If some block of voters may benefit from this pork barrel spending then make sure they know there is pork available.

Make New York the National Hub for Offshore Wind and Deploy 9,000 Megawatts by 2035 -The Green New Deal will accelerate offshore wind progress in three specific areas: port infrastructure, workforce development, and transmission infrastructure.

According to the NREL’s 2017 Cost of Wind Energy Review, the levelized cost of energy of off-shore wind is over two and a half times more expensive ($124 per MWh vs $47 per MWh) than on shore wind. For the 9,000 MW of offshore wind mandated the estimated cost would be $6.3 billion.

 Conclusion

A recent opinion piece in the New York Times notes that relying entirely renewable power systems is much more expensive and still not practical than a system that incorporates nuclear, geo-thermal and fossil-plants. The research paper notes:

Whichever path is taken, we find strong agreement in the literature that reaching near-zero emissions is much more challenging—and requires a different set of low-carbon resources—than comparatively modest emissions reductions (e.g., CO2 reductions of 50%–70%). This is chiefly because more modest goals can readily employ natural gas-fired power plants as firm resources.

However the opinion piece claims that Cuomo’s Green New Deal did not mandate an all-renewables system. I agree that the plan accepts existing nuclear power but I do not believe there is any indication that existing fossil fueled power would be replaced by anything but renewables aside from a platitude that mentions carbon sequestration. The Cuomo administration has consistently delayed or disapproved fossil fuel infrastructure so I believe it is appropriate to assume that the 51,473,000 MWhr of electric energy produced by coal, oil and natural gas in 2017 would be replaced entirely by renewables in the Green New Deal.

This is the challenge that Climate Action Council must address. How will that electrical energy be replaced, how much will that cost and what effect will that have on the environment.

NY Green Deal: Make Building Stock Carbon Neutral

This is one of a series of posts on Governor Andrew M. Cuomo’s New York State Green New Deal. As part of his 2019 Justice Agenda he included a “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”.

Not surprisingly there are no details other than the announcement, no mention of potential costs, and no explanation how all this will affect any of the many impacts that he claims are caused by climate change. There is a proposal to provide the plan to make New York carbon neutral and I will blog on those plans as they become available. In the meantime this post discusses the plan announcement for a path to make New York buildings carbon neutral as part of the New York Green New Deal.

In the following sections I list the text from the announcement and my indented and italicized comments follow.

Chart a Path to Making New York’s Statewide Building Stock Carbon Neutral

Buildings – and the fossil fuels traditionally used to heat and cool them – are a significant source of energy-related carbon pollution. As such, Governor Cuomo has made the improvement of energy efficiency in buildings a major priority. The Governor’s New Efficiency: New York agenda, released on Earth Day 2018, contains a comprehensive portfolio of proposals and strategies to meet an ambitious new target of reducing on-site energy consumption by 185 trillion BTUs by 2025. In addition, Governor Cuomo launched RetrofitNY in 2016 to stimulate the development of an energy efficiency industry that can tackle the challenge of deep building retrofits that will enhance building performance, reduce energy usage, and improve the quality of life for low- and moderate-income New Yorkers.

The Green New Deal announcement lays out some specific goals. In order to be credible those goals should be quantified. For example, what is the starting point for on-site energy consumption? An initial guess could use the NYSERDA Patterns and Trends documents table 3-3a nys primarary consumption of energy by sector and assume that residential and commercial sectors represent “on-site energy consumption”. In 2016 residential sector energy consumption was 558 TBtu and commercial sector energy consumption was 379 TBtu for a total of 937 TBtu so a 185 TBtu reduction represents a 20% lower value.

In my opinion energy efficiency is a classic energy example of the Pareto principle or the 80:20 ratio which states that 80% of the effects come from 20% of the causes. For energy efficiency it means that you can get 80% of the available reductions at 20% of the cost of doing all the reductions. Consider the anecdote of insulating your home. Adding insulation in the attic gets you a big benefit and is relatively cheap. Adding insulation to the walls gets you less of a benefit but is more expensive. Replacing the windows and doors with more efficient ones is a big expense but doesn’t get that much of a reduction. Those are the easy energy efficiency projects and anything else is going to cost a lot and not get much of an improvement.

  Wallet Hub analyzed state energy efficiency (https://wallethub.com/edu/most-and-least-energy-efficient-states/7354/). Their conclusions are highlighted below[1]:

To identify the most energy-efficient states, WalletHub analyzed data for 48 states based on two key dimensions, including “home-energy efficiency” and “car-energy efficiency.” We obtained the former by calculating the ratio between the total residential energy consumption and annual degree days. For the latter, we divided the annual vehicle miles driven by gallons of gasoline consumed. Each dimension was weighted proportionally to reflect national consumption patterns.

In order to obtain the final ranking, we attributed a score between 0 and 100 to correspond with the value of each dimension. We then calculated the weighted sum of the scores and used the overall score to rank the states. Together, the points attributed to the two major categories add up to 100 points.

Home-Energy Efficiency – Total Points: 55

Home-Energy Efficiency = Total Residential Energy Consumption per Capita / Degree-Days

Car-Energy Efficiency – Total Points: 45

Car-Energy Efficiency = Annual Vehicle Miles Driven / Gallons of Gasoline Consumed

The Wallethub rankings are listed in Table 1 2015 energy efficiency RGGI state rankings. New York ranked number one. This suggests to me that New York has already implemented most of the easy low hanging fruit of the available energy efficiency opportunities.

 Because buildings are one of the most significant sources of greenhouse gas emissions, Governor Cuomo is announcing a comprehensive strategy as part of the Green New Deal to move New York’s building stock to carbon neutrality. The agenda includes:

Advancing legislative changes to support energy efficiency including establishing appliance efficiency standards, strengthening building energy codes, requiring annual building energy benchmarking, disclosing energy efficiency in home sales, and expanding the ability of state facilities to utilize performance contracting.

All these requirements add to the regulatory burden for doing business in New York and it is not clear how much value for carbon reduction they will get.

Directing the Public Service Commission to ensure that New York’s electric and gas utilities achieve more in scale, innovation, and cost effectiveness to achieve the state’s 2025 energy efficiency target, especially through their energy efficiency activities and clean heating and cooling programs, and that a substantial portion of new energy efficiency activity benefits low- and moderate-income New Yorkers.

All these efforts disguise costs. The Public Service Commission will require that these programs be included in rate case submittals and the costs will be passed on to the customers. There is no unaffiliated voice for keeping consumer costs low vis-à-vis climate goals and myriad special interests involved in rate cases to fund these programs. Moreover the utilities have no reason to question these costs because it is a pass through.

Directing State agencies to ensure that their facilities lead by example through energy master planning, net zero carbon construction, LED retrofits, annual benchmarking, and by meeting their electricity needs through clean and renewable sources of energy, specifically including the exploration of clean energy solutions at State Parks and at State facilities within the Adirondack Park to dramatically reduce emissions, create jobs, and increase resiliency.

We will have to wait to see what this means.

Developing a Net Zero Roadmap to articulate policies and programs that will enable longer-term market transformation to a statewide carbon neutral building stock.

We will have to wait to see what this means.

Together, these bold actions will establish New York as a global leader on environmentally sustainable buildings while catalyzing major economic development opportunities and helping to create good jobs.

It is not clear to me what benefits accrue to the citizens if New York is a global leader on environmentally sustainable buildings.

[1] Wallethub reports that “Data used to create these rankings were obtained from the U.S. Census Bureau, the National Climatic Data Center, the U.S. Energy Information Administration and the Federal Highway Administration.”

New York Green Deal: Strategies to Decarbonize Agency Investment Funds

This is one of a series of posts on Governor Andrew M. Cuomo’s New York State Green New Deal. As part of his 2019 Justice Agenda he included a “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”.

Not surprisingly there are no details other than the announcement, no mention of potential costs, and no explanation how all this will affect any of the many impacts that he claims are caused by climate change. There is a proposal to provide the plan to make New York carbon neutral and I will blog on those plans as they become available. In the meantime this post discusses the language used to describe the mandate for New York agencies and authorities to study strategies to decarbonize their investment funds and invest in clean energy as part of the New York Green New Deal.

In the following sections I list the text from the announcement and my indented and italicized comments follow.

Direct State Agencies and Authorities to Pursue Strategies to Decarbonize their Investment Funds and Ramp Up Investment in Clean Energy

In 2018, Governor Cuomo called on the New York Common Fund, which manages over $200 billion in retirement assets for more than one million New Yorkers, to adopt a serious and responsible plan for decarbonizing its portfolio. Over the past year, the Governor has worked with the Office of the Comptroller to establish an advisory panel of experts to develop a decarbonization roadmap and guide the Common Fund toward investment opportunities that combat climate change.

I am guessing but I think that the plan to decarbonize the portfolio of the State agencies is publicly intended to publicize and signal the reality of climate change and change the economics of the fossil energy industry. It seems to me that rather than publicizing the issue for the unaware people in New York it is really intended to cater to the environmental activists who want to signal the virtue of New York State. The economics of the fossil industry will unlikely be affected: “Sin stocks”, such as tobacco shares, get a small discount because many investors will not touch them. But the main effect of this is that those who buy the stocks earn better returns. There is plenty of low-cost, environmentally insensitive capital available for energy companies that need it.”

 I am not going to bother doing a detailed comparison of the long-term financial viability of investment opportunities that combat climate change relative to the fossil assets but it seems to me that I have heard about more renewable company failures than fossil company failures. Given that renewables appear to be dependent upon subsidies suggests to me that their long term investment prospects are not that good. Investing in those stocks is yet another subsidy.

As part of the Green New Deal, Governor Cuomo is taking the next step, by directing State authorities, public benefit corporations, and the State Insurance Fund, which collectively hold approximately $40 billion in investments, to commence a process to review and evaluate the feasibility and appropriateness of divesting from fossil fuels. To scale up investment in renewable energy, green infrastructure, and climate solutions, agencies and authorities will also work to educate plan administrators and investment consultants regarding investment opportunities in the clean energy sector.

I think the most important investment strategy for the $240 billion dollars in New York funds should be economic rather than a signaling virtue. The rationale for this mandate to divest is clear: divestment is not an investment strategy, or a way of putting direct economic pressure on energy companies. It is a political statement.

Murphy Commentary in Syracuse Post Standard: Earth has a Fever – Public Policy has the Cure

On September 23, 2018, the Syracuse Post Standard published a guest commentary entitled “Earth has a Fever – Public Policy has the Cure” by Cornelius B. Murphy, Jr. SUNY Senior Fellow for Environmental and Sustainable Systems. As is typical in Dr. Murphy’s commentaries a list of disasters is trotted out, the climate crisis of global warming is blamed for them, and the sermon ends with a call to “improve the future of our planet”. I disagree with his arguments and his proposed policies.

Unfortunately, Dr. Murphy’s list of disasters are, in fact, only peripherally related to climate change and I am not in the mood to dissect each of his claims because “the amount of energy necessary to refute BS is an order of magnitude bigger than to produce it”, Brandolini’s BS asymmetry principle. Consider only the Cyanobacteria outbreaks in 55 lakes in New York State he claims are due to warm water column temperatures and nutrients. His attribution is correct but his emphasis is wrong. If there are limited nutrients it does not matter how warm the water is you will not get eutrophic algae blooms that lead to Cyanobacteria outbreaks.

I think that Dr. Murphy should read Roger Pielke Jr’s book on The Rightful Place of Science: Disasters and Climate Change to appreciate the actual problems associated with climate change. Dr. Pielke is reviled because he shows how the consensus of climate science does not support the climate crisis Dr. Murphy invokes as the reason to act now. As Ben Pile’s review of the updated version of the book notes “In other words, climate change may well be a problem, but the data sets consistently show that economic and technological development mitigate the worst problems that climate has always caused.”

 

Dr. Murphy says that Climate disruption is a social issue and that the “The least advantaged among us will suffer the most with limited access to air conditioners and cooling centers”. I agree that energy poverty problem is a social issue. I am sure that we disagree on the cure however. While Dr. Murphy would have us try to moderate extreme weather I believe that there is no evidence that the policies he espouses will prevent it. If anything we might be able reduce future frequency and severity but society is not where near resilient to existing weather so it makes sense to emphasize adaptation over mitigation.

 

My biggest concern is that the current New York State Energy Plan promotes the use of fossil-free technology that is so expensive that the least advantaged among us will have limited access to the energy they need for cooling and heating because they will be unable to afford it. Ben Pile explains:

Moreover, campaigners’ conviction that anthropogenic climate change is bringing disaster upon us overlooks the extent to which economic and social development has enabled us to cope better with extreme weather events. As Pielke explains, ‘societal change is underappreciated, overlooked, and part of that is politics’. ‘The climate-change issue’, Pielke continues, ‘has taken all the oxygen out of the room for vulnerability, resilience, natural climate variability, indeed pretty much everything else that matters. It is absolutely the case that overall being richer as communities, as nations, is associated with more resilience, less vulnerability to natural disasters, particularly when it comes to loss of life… The climate issue has become so all-encompassing that it’s hard to get these other perspectives into the dialogue.’