Air Pollution and Health Impact Projections

The recently released Fossil Fuel End Game report claims that peaking power plants should be replaced with wind, solar and distributed battery storage because it would save money and lives.  However, the basis for that claim ultimately comes down to the belief that there is no acceptable level of air pollution.  This post explains why I think that is absurd and explains how this concept is misused by activists. 

I am a retired air pollution meteorologist with over 40 years-experience analyzing the relationship between air quality and environmental standards.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Clean Air Act, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for six principal pollutants (“criteria” air pollutants) which can be harmful to public health and the environment.  The National Ambient Air Quality Standards (NAAQS) “provide public health protection, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”.  My career is based on the presumption that air quality that meets those standards is acceptable.

In order to achieve and maintain air quality that meets the NAAQS the Environmental Protection Agency working with state and local regulatory agencies have developed extensive procedures.  In this instance the important thing to know is that they have been monitoring air quality ever since the Clean Air Act was enacted and they have developed air quality models that can be used to predict ambient concentrations.  Importantly, the numerical models are based on observations and have been verified as being accurate since the Clean Air Act has been enacted.  Using those tools over the years they have a very good understanding of the status of air quality relative to the NAAQS.  According to the EPA nonattainment/maintenance status summary, there are multiple counties that do not attain the NAAQS for ozone and New York County does not meet the coarse particulate matter standard.  Note that all of New York State meets the inhalable particulate NAAQS.  All the other pollutants are in attainment.

Discussion

There is no question that air pollution can cause health effects.  The issue is whether there is a threshold when the health effect is so weak that it can be ignored.  The linear no threshold model (LNT) is a conservative model used to estimate health effects from small doses of radiation. According to the LNT model, “radiation is always considered harmful with no safety threshold, and the sum of several very small exposures are considered to have the same biological risk as one larger exposure (linearity)”. It is being used today to claim health effects for air pollution levels below the NAAQS. 

There is a fundamental problem with this approach for radiological assessments:

The problem is that, at very low doses, it is practically impossible to correlate any irradiation with certain biological effects. This is because the baseline cancer rate is already very high and the risk of developing cancer fluctuates 40% because of individual life style and environmental effects, obscuring the subtle effects of low-level radiation. Therefore, it is very difficult to validate this model.

Because it is so conservative there are consequences.  It assumes that all radiation is bad and that the health effects increases linearly with dose from the threshold of zero.   As a consequence: “The probabilistic nature of stochastic effects and the properties of the LNT model make it impossible to derive a clear distinction between ‘safe’ and ‘dangerous’, and this creates some difficulties in explaining the control of radiation risks.”

Despite those inherent problems the LNT model has been applied to air pollutants too.  Whenever you hear a claim that such and such a regulation will reduce air pollution and there will be some number of reduced health impacts the LNT model of air pollution impacts was used.  This presumes there is no threshold of an effect on an individual.  It extrapolates observed health effects on a population at high concentration down to low concentrations.  When the resulting small impact is multiplied by a large number of individuals then proponents of this approach claim reducing air pollution will result in a quantitative reduced health impact.

I think this is absurd as I will show in this example.  No one questions the fact that prolonged exposure to wood smoke can cause health problems.  I have no doubt that there are health studies that have conclusively shown that at high pollution levels people have contracted cancer.  For the sake of argument assume that the health studies have found that wood smoke at a continuous dose of 100 ppm for one year causes cancer.  The LNT model can be extrapolate that dose response down to 0.00019 ppm per minute.  Using that extrapolation model if 5,256 people sitting around campfires were exposed to the 100-ppm dose for one minute then the LNT models claims one of them will get cancer from that dose.  Anyone who has sat around a campfire probably has been downwind of the smoke and received a dose of wood smoke.  It does not matter what the actual health impact dose response rate is, if you extrapolate that down to the dose of people sitting around a campfire and multiply that by all the people sitting around campfires the LNT model predicts an impact.

Environmental activists combine the LNT model with epidemiological studies of air pollution to contrive health impact benefits particularly for inhalable particulates.  For example, in September, 2011 US EPA Administrator Lisa Jackson testified to Congress that fine particles kill hundreds of thousands of people in America every year, a claim based on EPA epidemiology and extrapolated projections.  However, Enstrom tested the validity of this relationship and found no effect of fine particulates.  Nonetheless, these results have been used for years to justify regulations and legislation.

Conclusion

I do not accept the premise that there isn’t a threshold of acceptable air pollution.  This presumption is behind the cost benefit analysis of most recent EPA air quality regulations.  Now it is being used in New York to justify the legislative phase-out of fossil fuels.  Coupled with the absence of evaluation of the life cycle environmental and economic impacts of fossil fuel alternatives this is a recipe for poor policy.

Fossil Fuel Phase Out Claptrap

Truthout is a nonprofit news organization dedicated to providing independent reporting and commentary on a diverse range of social justice issues.  According to the about description “Truthout works to spark action by revealing systemic injustice and providing a platform for progressive and transformative ideas, through in-depth investigative reporting and critical analysis. With a powerful, independent voice, we will spur transformations in consciousness and inspire both policy change and direct action.”  If the article Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most is any indicator, however, their platform is based on emotion and not facts.  The alleged problems with peaking power plants and neighborhood power plant impacts on local health are exaggerated and nearly fact free.  The proposed solution is untested and likely to make the lives that they want to improve worse.

I am a retired air pollution meteorologist with over 40 years-experience analyzing the effects of meteorology on electric operations.  While doing consulting work for the Environmental Protection Agency I evaluated air quality model performance and later worked at a utility company where I was responsible for ambient monitoring networks in the vicinity of power plants and evaluating their air quality impacts.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for those sources.  This background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The article is prefaced with a note that “this story is part of Covering Climate Now, a global journalism collaboration strengthening coverage of the climate story”.  The author is Leanna First-Arai. “a freelance journalist who covers environmental and climate (in)justice. Her work has appeared in Undark, Sierra Magazine, Yes! Magazine, Outside Magazine, on New England Public Radio and elsewhere”.

The Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most article describes the claims made in the recently released Fossil Fuel End Game report that I described here.  The basic premise is that New York City peaking power plants only operate a limited days per year, they are usually old and dirty plants located in disadvantaged communities, and they received around $5 billion to keep running in the last decade.  Therefore, they should be the first fossil plants to be replaced by clean energy.

I have been following this peaking power plant initiative for about a year and summarized my work here.  This article is the latest iteration of advocacy releases based on the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York StateI discussed the PSE report last year and the PEAK Coalition report entitled: “Dirty Energy, Big Money” in two detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. 

Oswego Harbor Power Plant

In order to show that this article is based on emotion and not facts consider the description and allegation related to the Oswego Harbor Power Plant.  In this section I have annotated (indented and italicized) my comments after each sentence from the relevant paragraph in the article.

Residents living within a one-mile radius of the Oswego Harbor Power Plant, one of only a handful of such plants left in Upstate New York, are ranked in the 99th percentile for incidence of heart attacks, based on an analysis of New York State Health Department data by the nonprofit research institute Physicians, Scientists and Engineers for Healthy Energy (PSE).

The insinuation here is that the residents within one-mile of the power plant have a high rate of heart attacks because of the power plant. 

The 73-year-old plant only went online six times in 2018 (the most recent year for which data are available).

There is a description of the plant in a US Army Corps of Engineers harbor infrastructure report that explains that there are two 850 MW units in operation and in service since 1975 – 46 years not 73.  The older units have been retired since before the turn of the century. The units burn residual oil that is stored on-site.  At the time of their construction residual oil was cheaper than coal and for many years residual oil was cheaper than natural gas so the units ran a lot in the late 1980’s.  The fuel price differential no longer supports the use of residual oil.  However, in times of great need the facility can generate 1,700 MW of dispatchable power without regard to weather-caused outages.

 The EPA Clean Air Markets Program Database provides data for the most recent quarter within 45 days so more recent data are available than claimed.  Table 1 lists annual data through 2020.  The important point in the context of this discussion is that emissions from the plant are minimal which is not surprising because of the short operating times.

 Table 1: Oswego Harbor Power Annual Emissions and Operations Data

Unit IDYear Operating Time Gross Load SO2 NOx CO2
  (Hours)(MW-h)(tons)(tons)(tons)
520169218,071442417,309
6201614623,212632423,659
520179219,132452517,426
6201714122,678562320,811
5201818626,025683225,075
6201816526,600652423,976
520199515,394371914,225
6201924023,600582522,407
5202024926,736693426,760
6202012523,906622521,024

But if residents suspect hazier-than-usual skies, no federal air quality data exists to help make sense of the short-lived plume of pollution, as the closest Environmental Protection Agency monitors are 40 and 70 miles away, respectively, in Syracuse and Rochester.

The insinuation that the DEC, EPA and owner of the plant know nothing about the plume of pollution is completely baseless.  The author clearly knows nothing about air quality regulations, air quality meteorology, or the Oswego Harbor plant.  The New York Department of Environmental Conservation (DEC) is responsible for maintaining air quality that meets the National Ambient Air Quality Standard limits under the guidance of EPA.  They do that by monitoring near emission sources and modeling facility emissions to estimate air quality impacts. 

 At this time there are no DEC air monitoring stations closer than Rochester and Syracuse.  EPA does not monitor air quality in New York.  However, that does not mean that there never was any air quality monitoring closer to the plant.  I know because I as responsible for submitting the data from the network around the Oswego plant.  After several years of not measuring any exceedances from the power plant DEC and EPA agreed that it was no longer necessary to run the monitoring network and it was retired by 1990.   At one time most, if not all power plants, had monitoring networks but one of two things happened.  If, like at Oswego, no measurements indicating problems were found then the networks were retired.  If problems were found then the emission limits were changed for the facility until the monitoring found that there were no problems.  Also note that these data were used to verify that the air quality models used to predict ambient levels near the plants were correct.  Under contract to EPA, I did that verification work using those data sets and later also compared the Oswego Harbor plant modeled impacts to observations.  That work proved that the models correctly characterize nearby air quality.

 It is not surprising that the modeling never showed anything approaching an exceedance of the National Ambient Air Quality Standards or that the highest observed monitored concentrations were accompanied with the smell of chocolate from the Nestles plant that was located in the opposite direction.  The stacks at Oswego are 700’ high and the plume rise from the hot gases pushes the plume higher.  As a result, the pollution plume is nowhere near the ground within a mile of the plant. 

The insinuated claim that the Oswego Harbor Power Plant is somehow associated with local high incidents of heart attacks is unsubstantiated.  The article states that the plant only ran six times in 2018 and the data show it only ran 352 hours so it was online for less than three days at a time.  Present operations are about 1% of the operating times and rates as in 1988 when the monitoring network that showed the plant did not adversely affect air quality.  If I had to guess why there is a high rate of heart attacks my money would be on the fact that Oswego is in the lake-effect snow belt and when it snows, it snows a lot.  Snow removal is a notorious cause of heart attacks.

Peaking Power Plant Replacements

The author and the advocates quoted in the article are unaware of the fundamental problem with the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  PSE defined peaking power plants by their current time of operation not by their design capabilities.  The Oswego Harbor Power Plant is the best example of this problem.  The plant was designed to provide base load power when it was thought that residual oil would continue to be a cost-effective fuel.  The two 850 MW units operated well when that was true but with today’s fuel costs it only offers support to system as backup capacity.  There are three nuclear plants within ten miles of the facility and if there is a problem with those units then the power plant can step in to replace their output.  For example, in the 2004 blackout Nuclear Regulatory Commission operating rules required the nuclear units to go offline and the Oswego Harbor Power Plant was called on to support the system until the nuclear units were allowed to go back online.  The units also come online when loads are very high and all power generation is needed.  There are other power plants in New York that operate much less than they were designed to operate that fulfill similar reliability needs.

The PSE report claims that all of the plants that they claim are peakers can be replaced by renewable energy and storage.  The problem with that is that their definition is based solely on operating times and does not consider the capabilities of the peaking units.  The New York electric system has more stringent rules than Texas.  In the wake of the blackouts last February, Texas is wrestling with how to prevent similar problems in the future by asking should power generators be required to guarantee that they can provide a certain amount of electricity?  New York’s response to this issue includes capacity payments to Oswego Harbor Power for 1700 MW of power six times a year.  This resource is dedicated to that need and can provide that capability because the capital investments necessary have already been paid, even though the fuel is relatively expensive it provides concentrated energy capable of 1700 MW, and the costs to maintain that much power capability are relatively low. 

The first problem with the PSE report claims that the steam turbine units like Oswego that provide peak capacity support can be replaced by renewable energy and storage is that the capital cost to develop enough energy storage to replace all those units has to be paid for a rarely used resource.  A major reason that New York’s capacity payments are as low as they are is because the resources needed to meet New York’s requirements has paid off those costs.  Replacing those facilities with anything will be much more expensive.  The second problem is that the renewable and energy storage approach proposed has never been implemented at the scale needed for New York’s electric resource requirements.  Replacing a system that has worked for decades with unproven technology could very well lead to reliability issues as the system is de-bugged.

Conclusion

All these analyses vilify peaking power plants oblivious to their value to the grid.  The PSE study estimated that they received around $5 billion in the last decade but only ran less than 5% of the time.  The New York electrical system pays for these units to provide capacity and ancillary services so that the electric system can reliably provide power when it is needed most.  The Texas energy system does not have a similar policy in place.  While Texas average prices are lower than New York prices their system is vulnerable to blackouts when peaking power is unavailable.  Simply put, New York peaking power plants are an insurance policy to prevent Texas-style blackouts.  The February 2021 Texas blackouts caused dozens of deaths and tens of billions of dollars in damages.  The New York peaking power plant insurance policy looks like a good deal to me.

Another big driver in the vilification of peaking power plants is the claim that they adversely affect air quality in neighboring disadvantaged communities. However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  My primary objection to this claim is that the health effects attributed to peaking power plants are based on air quality impacts from ozone and particulate matter.  However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5, that the impact is away from the adjoining neighborhoods.  That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most. Importantly regulations are now in place that ensure that they are retired or that their pollution control equipment is upgraded on a schedule that guarantees in-kind replacement of capacity and ancillary services.   In order to maintain existing levels of affordability and reliability I think it is best to rely on a proven solution using fossil fuels.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because wind, solar, and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly, in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.  It is the height of hubris that the New York legislature has pending bills to over-ride the reliability planning process and existing environmental regulations without including a feasibility study to define the wind, solar and energy storage resources needed, the technological readiness of those resources at the scale needed and the costs of that approach.

Finally, I do not disagree with the premise that disproportionate environmental risks to disadvantaged communities need to be addressed.  However, that goal has limits.  First, and foremost, it simply is not good policy to expect the removal of all environmental impacts.  For example, a replacement state-of-the-art natural gas fired combustion turbine that reduces existing impacts substantially should be an acceptable choice because it provides a proven affordable solution and reduces well-known impacts.  The proposed alternative of renewable energy and energy storage is unproven technology at the scale needed, is costly when the cost to provide uninterruptable power is considered, and could very well lead to worse overall environmental impacts especially when the effects of the rare earth metals needed for those resources is included.  The result is there is a high likelihood of problems with affordability, reliability, and environmental impacts due to the implementation of the proposed solution.  If those problems occur then the disadvantaged communities that these advocates want to protect will be disproportionately impacted.  I don’t think that the advocates understand that those impacts could be worse than the problems that they want addressed.

Community and Climate Investment Act Climate Pollution Fee

In the spring of 2021, the New York state Senate introduced the Climate and Community Investment Act (CCIA).  Coming on the heels of the Texas energy debacle one might think that politicians would not propose any changes to energy and environmental laws until the causes of that disaster were understood or would at least make implementation contingent upon feasibility studies to determine if the ambitious goals of this legislation don’t risk a similar outcome in New York. Such is not the case, however as I will show in this post

I have written extensively about implementation of the Climate Leadership and Community Protection Act (CLCPA) because I believe it will adversely affect affordability and reliability as well as create more environmental harm than good. The CCIA will make those impacts worse.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The sponsor memo for this proposed regulation lists specific provisions in the proposed legislation.   I prepared an annotated version of the draft bill that includes internal links to the sections of the bill corresponding to those provisions.  The summary of Senate Bill S4264A states:

Enacts the climate and community investment act; prioritizes the allocation of public investments in disadvantaged communities; addresses climate change challenges through the expansion and growth of clean and renewable energy sources; adopts best value requirements for the solicitation, evaluation and award of renewable energy projects;  establishes a community just transition program; establishes a climate pollution fee and a household and small business energy rebate; and creates the climate and community investment authority.

This article discusses the climate pollution fee which is another name for carbon pricing.  In theory, this supposedly measures the cost of the accumulated damage for centuries to come from emitting a ton of carbon dioxide today.  According to Resources for the Future (RFF), carbon pricing is a climate policy approach that works by charging industrial sources for the tons of emissions of carbon dioxide (CO2) they emit.  The problem is that there is a large gap between the elegant theory of carbon pricing described by RFF and real world carbon pricing.  In theory applying a carbon price across the globe on all sectors could incentivize the market to find the most efficient solution to provide energy at the lowest cost and not unduly affect the public by using the revenues to replace existing taxes.  The reality of the CCIA climate pollution fee proposed is that it is in one limited area with the funding going to special interests. As a result, tt is a regressive tax and a prescription for potential leakage and misapplied price signals.

The CLCPA mandated that the Department of Environmental Conservation (DEC) stablish a value of carbon.  At the end of 2020 DEC published this guidance document.  The Value of Carbon Guidance provides values for carbon dioxide, methane, and nitrous oxide for use by State agencies along with recommended guidelines for the use of these and other values by State entities. The guidance Value of Carbon Guidance  document summarizes the methodology and rationale.  The recommended values are provided in the Appendix: Social Cost Values. The CCIA legislation shows no sign that the months long CLCPA process to develop an appropriate system for valuing carbon was considered, much less incorporated.

Discussion

In order to address the recognized problems of a climate or carbon pollution fee in just New York, the proposed regulation includes a border carbon adjustment fee.  The fee applies to any carbon-based fuel sold, used or brought in the state by an applicable entity.  Consequently, the logistical requirements to calculate border adjustments is a big effort. 

The premise of a climate pollution fee is that it will incorporate the future cost to society of CO2 emissions today.  The DEC Value of Carbon guidance bases its recommendations upon the work of the Federal Integrated Working Group (IWG) social costs of carbon.  Dr. David Kreutzer explains that:

Estimating the social cost of carbon is susceptible to political pressure and model-gaming. The assumptions in play—about unsupportable time horizons, exaggerated emissions projections, overly high estimates of carbon dioxide’s impact on warming, and others—are all too easily corrupted, resulting in wildly varying estimations.

In fact, reasonable assumptions can push the social cost of carbon negative (which implies that a policy of subsidies for carbon dioxide emissions is the answer). However, the single input that has the most potential to overstate the social cost of carbon is understating the discount rate.  The constant pressure to justify ever lower discount rates for social cost of carbon calculations is almost comical when it mistakes wealth for poverty.

It is worth noting that the DEC Value of Carbon guidance did not follow the IWG recommendation for the discount rate recommended choosing instead to pick a lower value.  The CCIA fee appears to use the IWG recommended discount rate of 3%.

The fee calculation methodology is complicated.  The price is adjusted by year and a newly defined environmental integrity metric.  That metric adjusts the price based on the state’s reductions relative to a defined trajectory.  For example, the 2021 statewide GHG emission target is set at 85% of the 2018 GHG emissions.  DEC has not released its draft emission inventory for years since 1990 but my money is on an increase since 2018 simply because the State closed down 1,070 MW of nuclear capacity in 2020 and is closing another 1,080 MW of nuclear capacity this year.  I estimate that the power needed to replace those facilities will generate over 8,000,000 tons of CO2.  The CLCPA Climate Action Council process is underway and I believe is charged with determining the appropriate reduction schedule.  It is very likely that the schedule in the proposed law will not be consistent with the CLCPA recommendation.

I have given up trying to figure out how the environmental integrity metric will affect the price because of its complexity.  Without a lot more work I cannot determine how the five-year metric using cumulative actual and target emission reductions could affect the differing adjustments to the carbon pollution fee.  My impression is that the methodology and values chosen will ensure that the maximum increase (10%) of the climate pollution fee is inevitable.

The last statewide GHG emissions inventory developed by the New York State Energy Research & Development Authority estimated that the total emissions in 2016 were 377 million metric tons of CO2e.  Assuming that emissions will be the same in 2022 when the proposed legislation starts applying the fee the annual fee will be over $16 billion.  The annual adjustments keep the fees about the same for five years or so but then the reductions in emissions reduce the fees collected.  Obviously when all the GHG emissions have been eliminated the fee will also be eliminated. 

My biggest problem with this proposed legislation is mandates for specific information that is already available elsewhere.  In order to determine the tax levy, the emissions must be known.  The regulation includes a section for the calculation of emission factors which when combined with electricity production data can be used to estimate emissions.  This is a flawed approach for those facilities that actually monitor and report their emissions.  Direct measurements are a more accurate methodology than this approach.  Moreover, the DEC and NYSERDA already have a process in place to calculate emissions.  Importantly, the New York Independent System Operator has proposed a carbon pricing scheme that includes a methodology to estimate emissions for its fees.  Both systems are incompatible with this law.

There is a section for exemptions and deductions.  In order to prevent double payments a source affected by 6 NYCRR Part 242 (the Regional Greenhouse Gas Initiative) can deduct “the amount it paid to purchase CO2 emission allowances”.  Exemptions for de minimis quantities of emissions are also allowed.

Emissions leakage refers to a situation where a policy in one jurisdiction moves the emissions out of that jurisdiction to a less restrictive one such that the total emissions are not actually reduced.  The CCIA law includes a mitigation policy that calls for studies of ways to reduce this effect.  Leakage has been a concern in the CLCPA implementation process so the scoping plan recommending policy measures to prevent emissions leakage is redundant except for the fact that the CLCPA evaluation has not included an explicit cost like the $16 billion annual CCIA fee.

The legislation creates funds within the authority including 33% for the “community just transition fund”, 30% for the “climate jobs and infrastructure fund”, 30% for the “low-income and small business and household energy rebate fund”, and 7% for the “worker community assurance fund”. 

Finally, the climate pollution fee includes a requirement for report on the implementation of the fund.  The report is supposed to include the total revenues, the effectiveness of the fee to reduce GHG emissions, the amount of leakage, and overviews of the benefits and costs.

Conclusion

Dr. Steven McKitrick evaluated carbon pricing policies in Canada and explained that “there may be many reasons to recommend carbon pricing as climate policy, but if it is implemented without diligently abiding by the principles that make it work, it will not work as planned, and the harm to the Canadian economy could well outweigh the benefits created by reducing our country’s already negligible level of global CO2 emissions”.  This is entirely analogous to New York and the CCIA.   Importantly he notes:

However, a beneficial outcome is not guaranteed: certain rules must be observed in order for carbon pricing to have its intended effect of achieving the optimal balance between emission reduction and economic growth. First and foremost, carbon pricing only works in the absence of any other emission regulations. If pricing is layered on top of an emission-regulating regime already in place (such as emission caps or feed-in-tariff programs), it will not only fail to produce the desired effects in terms of emission rationing, it will have distortionary effects that cause disproportionate damage in the economy. Carbon taxes are meant to replace all other climate-related regulation, while the revenue from the taxes should not be funnelled into substitute goods, like renewable power (pricing lets the market decide which of those substitutes are worth funding) but returned directly to taxpayers.

The CCIA violates all these rules.  New York has emissions regulations for Part 242 and the CLCPA that both mandate specific reductions.  The revenue from the climate pollution fees won’t even be used to support renewable energy development and only a small fraction will be returned to ratepayers.  This is simply a regressive tax that will dis-proportionally adversely affect those it purports to want to help.

Climate Leadership and Community Protection Act Lesson from the German Energiewende

The German Energiewende (“energy transition”) is often touted as an example for the Climate Leadership and Community Protection Act (CLCPA).  I agree but, as explained in a recent article Daniel Wetzel at German national daily Die Welt, the attempt to transition to green energy has shown that there are significant problems using today’s technology.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in posts on implementation of the CLCPA because I  believe it will adversely affect affordability and reliability as well as create more environmental harm than good which affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

According to Clean Energy Wire’s guide to the Energiewende, “Germany’s experience offers valuable insights and can serve as an example on how to wean a major economy off fossil fuels, even for countries with their own unique conditions and challenges”.   However, a German Government Audit report warns that the Energiewende is causing higher costs, and that there is a real danger of electricity shortfalls.  Pierre Goslin summarizes the report in “Explosive” German Government Audit Report: “Energiewende” Has Become “A Danger to all Germany”.

Goslin reports:

The “Energiewende” (transition to green energies) has seen Germany recklessly rush into wildly fluctuating wind and solar energy without properly planning the grave impacts they would have on the power supply grid and prices.

The German auditors had already voiced harsh criticism three years earlier in another special report, whose main focus had been on the high cost of the Energiewende. The latest report now also includes “an explosive analysis” on power supply instability and the high probability of power shortfalls.

The report finds that not only have the costs spiraled out of control, but that the German federal government “does not have a sufficient view of the emerging, real dangers to the security of supply” and that “ever higher electricity prices” are to be feared in the current system.

German electricity are among the highest in the world, and there is still no end in sight for the cost spiral. One study found that another whopping 525 billon euros will be needed by 2025 to upgrade the power grid, according to Die Welt.

The development of green energies in Germany has gotten so bad that the Federal Audit Office sees the risk the Energiewende could “endanger Germany as a business location and overburden the financial sustainability of electricity-consuming companies and private households.”  “This can then ultimately jeopardize the social acceptance of the energy transition,” warned Scheller.

Die Welt characterizes the Government Audit report as “explosive” and a long overdue wake-up call. The auditors accuse the federal government of not having properly taken into account the consequences of the coal phase-out, making assumptions that seem “unrealistic or are outdated by current political and economic developments” and making overly optimistic assumptions on the future available wind and sun.

Advocates for the CLCPA believe that wind and solar provide an economic way to transition off fossil fuels.  David Wojick recently published an article that succinctly explains why that approach why one factor makes that a false assumption: the Minimum Backup Requirement (MBR).  Wojick explains that “The minimum backup requirement is how much generating capacity a system must have if it is to reliably produce the electricity we need when wind and solar don’t.”  I have written about this issue but was unable to simply describe it this well.

Michel at the Trust, yet Verify blog evaluated the potential effect of increased electricity production from intermittent energy sources in a post using a simple solar and wind capacity increase data analysis model and found that in Belgium in enormous amounts of over-building are required to cover periods with low wind and solar.  With help from Michel we did a similar analysis for New York and I found that even with unrealistic assumptions about the “best case” availability of solar and wind capacity, there are periods with significant deficits. In order to prove the extraordinary claim that solar and wind can replace existing fossil the State of New York, a similar type of analysis using actual data to estimate realistic energy production must be done. That is the only way to provide the extraordinary proof showing just how much energy storage will be required to prevent deficits.

Conclusion

The Government Audit report accuses the federal government of making assumptions that seem “unrealistic or are outdated by current political and economic developments” and making overly optimistic assumptions on the future availability of wind and sun available.  The draft plans for the CLCPA are going down that same path.  I believe the German results will also occur in New York.

Climate Leadership and Community Protection Act Off-shore Wind Resiliency

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. 

The CLCPA was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation but there is one massive flaw.  The lawmakers who enacted this law presumed that the transition of the state’s energy system could be implemented by political will so did not include feasibility conditions in the targets or schedules.  This post is a short description of one aspect of the many implementation problems of this law.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in posts on implementation of the CLCPA because I  believe it will adversely affect affordability and reliability as well as create more environmental harm than good which affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

One of the targets of the CLCPA is to develop 9,000 MW of offshore wind by 2035.  This is considered necessary because off-shore wind has a higher resource availability.  Importantly this is just the start of what is accepted as a much larger offshore wind capacity that eventually will be needed for the ultimate goal of a net-zero emissions economy in New York in 2050.  For example, the Brattle Group analysis for the NYISO, New York’s Evolution to a Zero Emission Power System, estimates that 25,000 MW of offshore wind will be needed in 2040.  This article considers resiliency of the offshore wind capacity needed for the CLCPA.

Tony Heller writing at  Real Climate Science does an amazing job digging up newspaper accounts of past weather events like this description of the “Greatest Cataclysm in American History”.   In that article he uses newspaper archives and other contemporaneous accounts to describe the extreme weather on March 27, 1913 when there was widespread flooding in Indiana and Ohio, a massive tornado hit Omaha, NE, and tornadic storms ranged east into Pennsylvania.  One can only imagine the hysterical cries of climate change impacts if this situation were to repeat itself today. 

I think that comparing the weather of the past to today is important to understand that natural variability causes most of the observed extreme weather observed.  Historical weather observations should also be used to evaluate plans for the future.  If we cannot plan for the past then we shouldn’t even try to plan for the future.  Heller recently described a 2014 report from the Swiss Reinsurance (Swiss Re) Company titled “The Big One, the East Coast’s USD 100 billion hurricane event” that is the impetus of this post.  In the report Swiss Re examines how the 1821 Norfolk and Long Island hurricane would impact the region today. 

The Swiss Re report’s introduction describes the storm:

Nearly 200 years ago, a powerful hurricane decimated the Mid-Atlantic and Northeast United States. Packing wind gusts of over 156 miles per hour, the Norfolk Long Island Hurricane of 1821 surged up the Eastern Seaboard creating chaos and wreaking havoc from the Outer Banks of North Carolina all the way up to the Boston metropolitan area. If this hurricane was measured by today’s standards, it would be a strong Category 4 storm — unlike anything the Mid-Atlantic and Northeast have recently seen or experienced.

In comparison, Hurricane Sandy, with its unique track, 1,000-mile-wide wind field, and low central pressure, pushed record-breaking storm surge into the New York and New Jersey coasts, destroying businesses, homes, and lives in a short 24-hour period. But for all the devastation and damage that Hurricane Sandy brought, its intensity at landfall, measured by 1-minute maximum sustained winds, was equivalent to a weak Category 1 hurricane. Other events in recent years (Irene, Isabel, Gloria, and Bob), while significant, weakened prior to landfall, coming onshore as either Category 1 or Category 2 hurricanes, and not the major hurricanes originally anticipated and feared.

The report states that “If the 1821 Hurricane were to happen today, it would cause 50% more damage than Sandy and potentially cause more than $100 billion in property losses stemming from storm surge and wind damage.”  I had never heard of this storm but I knew about the “Great Hurricane of 1938” which decimated Long Island and New England leaving over 700 dead.  The question is how would a hurricane similar to these storms New York’s proposed offshore wind facilities.

The New York State Energy Research and Development Authority Offshore Wind Projects site describes the current status of the program to reach the 9,000 MW target by 2035.  As of early 2021 there are five offshore wind projects in active development.  The following figure from the website shows where the projects from the first two offshore wind procurements are located.

I wondered whether a storm with the same track as the 1821 and 1938 hurricanes would affect these locations. The Swiss Re report reconstructed the storm track and wind field for the 1821 hurricane:

The New York City National Weather Service has a web page describing the Great Hurricane of 1938 that includes a wind field map developed by Dr. Isaac Ginis at the University of Rhode Island:

The answer to my question whether a storm similar to the 1821 and 1938 hurricanes would affect the five offshore wind projects is unequivocally yes.  The Forward of the Swiss Re report makes an important point regarding this threat:

It’s been two years since Hurricane Sandy reminded us that the Northeast United States is vulnerable to hurricanes, and for those still recovering from the storm’s aftermath, the trauma of the hurricane continues. Yet despite Sandy being the third largest hurricane loss on record, the majority of New York, New Jersey, and other Northeast residents did not experience how devastating a hurricane could be. For many of us Sandy is little more than a distant memory of a temporary inconvenience.

In the months following Sandy many experts told us that Hurricane Sandy was a very unusual event. It was unusual in terms of its westward storm track, its interaction with the jet stream, the high tide, and how it intermingled with the continental weather systems. They tell us that the probability of a similar storm taking the same perpendicular track as Sandy is at least one in 500 years.

Once in 500 years is misleading. Although Sandy was unusual in a meteorological sense, it wasn’t a particularly intense storm and lacked the widespread high winds and rainfall that can occur with a Northeast hurricane. It’s highly unlikely that we will see a hurricane with the same characteristics as Sandy. However it’s very likely (1 in 50 years) that we will see, and in fact, have seen, other hurricanes in the Northeast that would have caused economic damages equal to or greater than those caused by Hurricane Sandy if they were to occur today. Sandy is a harsh reminder of what greater event potentially awaits us.

Conclusion

The official story is that renewable energy like offshore wind will be more diversified and resilient than the current electrical system. Different types of fuels at existing power plants truly provide a redundant and flexible power system that can provide reliable electricity when needed.  In contrast wind and solar power which are utterly dependent upon the vagaries of weather cannot be called flexible and certainly are not dependable without additional energy storage and grid support services that markedly increase the cost.  The claim that wind and solar are less prone to massive outages is absurd given that every night with calm winds causes an outage of both of these generating resources.  

Unfortunately, resiliency in the event of extreme weather is an even bigger problem. There is no question that a hurricane with stronger winds than Sandy will go through the area where New York is developing offshore wind.  The fact that two hurricanes with winds well over 100 mph have passed over New York’s offshore wind development areas should be a major concern.  I worry that New York will invest billions in these resources, get to a point where they are necessary for reliability only to see one storm come through and knock out the resource for an extended period. 

Climate Leadership and Community Protection Act Environmental Justice Tradeoffs

On January 11, 2021 the Climate Leadership and Community Protection Act (CLCPA) Generation Advisory Panel met as part of the Climate Action Council Scoping Plan development process.  During that meeting one discussion considered the health effects of New York City peaking power plants on environmental justice communities.  The CLCPA process focus on this problem needs to consider the impacts of the solutions proposed as alternatives.

On July 18, 2019 New York Governor Andrew Cuomo signed the CLCPA which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The January 11, 2021 the Generation Advisory Panel notes document the discussion about New York City peaking power plants.  Following the publication of the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State last summer, these plants became a touchstone for environmental justice issues in New York City.  I discussed how the analysis was used in the PEAK Coalition report entitled: “Dirty Energy, Big Money”.  In another post provided information on the primary air quality problem associated with these facilities, the Peak Coalition organizations, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  A second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.  All three reports were also summarized.

Since the Power Generation Advisory Panel meeting, I prepared a post explaining that the Peak Coalition analysis of peaking plants misses the point of peaking plants and their environmental impacts.  The claimed air quality health impacts are from ozone and inhalable particulates.  Both are secondary pollutants that are not directly emitted by the peaking power plants so do not affect local communities as alleged.  On the other hand, the proposed solutions have much greater health impacts than the air quality problems that are present in New York City’s environmental justice communities.

NYC PM2.5

I prepared a post specifically on New York City PM2.5 because the primary public health reference in the PEAK Coalition report was the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report.  The PEAK coalition description of air quality public health impacts quotes the conclusion from the DOHMOH report: “Each year, PM2.5 pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.”  These conclusions are for average air pollution levels in New York City as a whole over the period 2005-2007.

In my analysis I found that the DOHMOH report claimed that:

Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits. Achieving the PlaNYC goal of “cleanest air of any big city” would result in even more substantial public health benefits.

It is rarely noted by environmental activists that PM2.5 air quality has improved markedly since 1999 mostly because of national reductions in sulfur dioxide and nitrogen oxides emissions.  The NYS DEC air quality monitoring system has operated a PM2.5 monitor at the Botanical Garden in New York City since 1999 so I compared the data from that site for the same period as this analysis relative to the most recent data available (Data from Figure 4. Baseline annual average PM2.5 levels in New York City). The Botanical Garden site had an annual average PM2.5 level of 13 µg/m3 for the same period as the report’s 13.9 µg/m3 “current conditions” city-wide average (my estimate based on their graph).  The important thing to note is that the latest available average (2016-2018) for a comparable three-year average at the Botanical Garden is 8.1 µg/m3 which represents a 38% decrease.  That is substantially lower than the PlaNYC goal of “cleanest air of any big city” scenario at an estimated city-wide average of 10.9 µg/m3.

Note that in DOHMOH Table 5 the annual health events for the 10% reduction and “cleanest” city scenarios are shown as changes not as the total number of events listed for the current level scenario.  My modified table (Modified Table 5. Annual health events attributable to citywide PM2 5 level) converts those estimates to totals so that the numbers are directly comparable.  I excluded the confidence interval information because I don’t know how to convert them in this instance. I estimated the health impact improvements due to the observed reductions in PM2.5 as shown in the last three columns in the modified table.  I estimate that using the DOHMOH methodology the observed reduction in PM2.5 concentrations prevented nearly 1,300 premature deaths, 800 hospital admissions and 2,400 emergency department visits. It is important to note that New York’s power generation fleet cannot do much more to continue these health improvements simply because the emissions are so low now tht comparable emission reductions are not possible.  In any event the peaker units in the city don’t contribute to these secondary pollutant impacts.

Environmental Justice Hypocritical Tradeoffs

The apparent preferred option to fossil-fired power plants is to use energy storage ultimately powered using renewables. Energy storage, wind generation and solar generation technology all require rare earth metals found in terrestrial rocks in infinitesimal amounts which have superb magnetic, catalytic and optical properties needed for these resources.  Therein lies an environmental justice problem unless it is addressed in the CLCPA process..

French journalist and documentary filmmaker Guillaume Pitron has been following the global trade in rare earth metals. Unfortunately, mining these materials come with heavy environmental and social costs. Mining generates massive amounts of polluted wastewater, which left untreated, poisons crops and makes people sick. Guillaume documents these issues in his 2018 book “Rare Metals War’.  Recently his work was summarized in the article “Toxic secrets behind your mobile phone: Electric cars, wind turbines and solar panels… how our so-called green world depends on the mining of rare metals which is a filthy, amoral industry totally dominated by China”.

 

Pitron explains that he visited the Weikuang Dam – an artificial lake into which metallic intestines regurgitate torrents of black water from the nearby refineries. He looked ten square kilometres of toxic effluent.  He went to a village called Dalahai on another side of the artificial lake. Here, the thousands of inhabitants breathe in the toxic discharge of the reservoir as well as eating produce, such as corn and buckwheat, grown in it.  What he found was a real environmental nightmare:

Cancer affects the local population and many villagers have died. The hair of young men barely aged 30 has suddenly turned white. Children grow up without developing any teeth.

One villager, a 54-year-old called Li Xinxia, confided in me despite knowing it’s a dangerous subject. He said: ‘There are a lot of sick people here. Cancer, strokes, high blood pressure… almost all of us are affected. We are in a grave situation. They did some tests and our village was nicknamed “the cancer village”. We know the air we breathe is toxic and that we don’t have that much longer to live.’

The provincial authorities offered villagers compensation to relocate but these farming folk were reluctant to move to high-rise flats in a neighbouring town.

In short, it is a disaster area.

When you consider the immense effort necessary to produce these rare earth metals for batteries I believe it is hypocritical to demand replacement of fossil-fired power plants without considering the environmental impacts of its alternatives.  In the case of New York City power plants, the health impacts associated with the power plants are statistical creations whereas the health impacts of rare earth metal extraction are incontrovertible acute impacts.  While there still is room for improvement in New York, no children are growing up without developing teeth.

Conclusion

One of the fundamental problems with any Greenhouse Gas emission reduction program is leakage.  Pollution leakage refers to the situation where a pollution reduction policy simply moves the pollution around the globe rather than actually reducing it. Similarly, economic leakage is a problem where the increased costs inside the control area leads to business leaving for non-affected areas.  There also is an economic leakage effect in electric systems where a carbon policy in one jurisdiction may affect the dispatch order and increase costs to consumers in another jurisdiction.  I also submit that environmental impact leakage where efforts to reduce much greater impacts are the result elsewhere.

The CLCPA specifically mandates that emissions inventories for the energy sector include an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption.  However, because the replacement renewable energy resources are dependent upon rare earth metals there is a large environmental problem associated with their deployment.  It is hypocritical for the CLCPA to demand lifecycle analyses of one aspect of energy development but not all others.  Therefore, the implementation process should demand ethically sourced rare earth metals be used for batteries, wind energy, and solar energy.

Climate Leadership and Community Protection Act CLCPA Agriculture and Forestry Advisory Panel Strategies Comments

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Agriculture and Forestry Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

I have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  Each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

General Comments

There are major potential land use and environmental impact ramifications of the CLCPA on agriculture and forest lands.  I believe it is necessary to do a cumulative environmental impact assessment of the Scoping Plan’s projections for wind and solar development and I strongly recommend that this panel work with the land use panel to take the lead in developing a strategy to evaluate those impacts.

At the end of September 2020 the Department of Public Service released the  Final Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act (“CLCPA SGEIS”).  Unfortunately, that analysis only evaluated the 70% reduction by 2030 target and did not even use the latest estimates for the wind and solar developments for that target.  Based on the projections by E3 in their presentation to the Power Generation Advisory Panel on September 16, 2020 and the Analysis Group September 10, 2020  presentation of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study significantly more wind and solar will be required than was analyzed in the CLCPA SGEIS process.  Because the capacity estimates from these analyses and others are so much larger than the latest CLCPA SGEIS estimate I believe that another environmental impact analysis is needed when the Climate Action Council finalizes its Scoping Plan.

I extrapolated results from several projects to estimate the potential cumulative impacts for the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last DPS impact statement that evaluated wind energy cumulative impacts.  If all the wind projects are built on agricultural land, then between 12% and 56% of the agricultural lands will be covered with wind turbines.  Of course, it is more likely that wind turbines will be sited on ridge lines but that will affect forest land use.  Nonetheless that study also projected 39,262 MW of utility scale solar that will have to go somewhere.  It is not just land use that will be affected.  The environmental impacts of this much wind generation could cause the deaths of between 91 and 804 bald eagles a year.

I recommend that the Agriculture and Forestry Advisory Panel develop a strategy that includes preparations for the cumulative analysis of the Scoping Plan recommended wind and solar development.  That process should start soon and determine a threshold for unacceptable environmental impacts.  For example, I am worried about eagles.  If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful.  Now that has occurred and I am not willing to risk that environmental victory for the CLCPA goals.  Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines.  There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed.  The ultimate goal should be to refine the NYSERDA  wind power and biodiversity habitat sensitivity maps for the CLCPA resource development planning and siting process.

Comments on Proposed Strategies

The Agriculture and Forestry advisory panel presented 12 strategies in six categories.  It is particularly relevant that the cumulative environmental impacts of all the large-scale renewable energy projects on land use be addressed by this panel.

There were two strategies in the livestock/dairy management category: alternative manure management and precision feed management.  It is not clear to me why these strategies to reduce methane from manure are included because § 75-0109, (2) (b) states “Include legally enforceable emissions limits, performance standards, or measures or other requirements to control emissions from greenhouse gas emission sources, with the exception of agricultural emissions from livestock.”  What is the point of alternative manure management if livestock emissions are exempt?  At the very least accounting for livestock emissions is going to be complicated.  If there are no enforceable emissions limits then should the emissions be included in the inventories?

It appears to me that the strategies in the soil health and nutrient management, nutrient (fertilizer) management and soil carbon sequestration, and agroforestry, silvopasture, alley cropping, and riparian forest buffers, categories are consistent with § 75-0103 (13) (d) “Measures to achieve long-term carbon sequestration and/or promote best management practices in land use, agriculture and forestry”.

I agree that the land conversions category strategies of agricultural protection and access and no net loss of forestland are important and should be included.  However, the CLCPA electric sector targets are going to require enormous amounts of solar and wind energy development.  This factor has to be addressed and it was over-looked in the mitigation strategy slides.  The Agriculture and Forestry and Power Generation Advisory Panels must determine how much agricultural land and forests will be taken out of production for solar and wind development sprawl

There were four forestry strategies: urban forestry, statewide afforestation/reforestation efforts, improved forest management, and increase manufacture and use of harvested wood products, and a strategy to support opportunities to substitute fossil fuels in the bioeconomy category.  I have one overall observation for these strategies.  I believe that the increased costs of energy induced by the CLCPA and the desire to backup electric heating is going to put a lot of pressure on forests as more people turn to wood-fired heating.  The mitigation strategy slides did not mention this issue and I think this Advisory Panel should address it.

Conclusion

I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study.  It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar.  The only way this might work will require extraordinary amounts of wind and solar development.  When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.  This panel and the land use panel are in the best position to develop a strategy to address this problem.

Comments on Climate Leadership and Community Protection Act Land Use Advisory Panel Strategies

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Transportation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

I have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  In brief, each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

General Comments – Note that this is pretty much the same for all my advisory panel posts

There are major potential land use and environmental impact ramifications of the CLCPA on agriculture and forest lands.  I believe it is necessary to do a cumulative environmental impact assessment of the Scoping Plan’s projections for wind and solar development and I strongly recommend that this panel work with the land use panel to take the lead in developing a strategy to evaluate those impacts.

At the end of September 2020 the Department of Public Service released the  Final Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act (“CLCPA SGEIS”).  Unfortunately, that analysis only evaluated the 70% reduction by 2030 target and did not even use the latest estimates for the wind and solar developments for that target.  Based on the projections by E3 in their presentation to the Power Generation Advisory Panel on September 16, 2020 and the Analysis Group September 10, 2020  presentation of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study significantly more wind and solar will be required than was analyzed in the CLCPA SGEIS process.  Because the capacity estimates from these analyses and others are so much larger than the latest CLCPA SGEIS estimate I believe that another environmental impact analysis is needed when the Climate Action Council finalizes its Scoping Plan.

I extrapolated results from several projects to estimate the potential cumulative impacts for the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last DPS impact statement that evaluated wind energy cumulative impacts.  If all the wind projects are built on agricultural land, then between 12% and 56% of the agricultural lands will be covered with wind turbines.  Of course, it is more likely that wind turbines will be sited on ridge lines but that will affect forest land use.  Nonetheless that study also projected 39,262 MW of utility scale solar that will have to go somewhere.  It is not just land use that will be affected.  The environmental impacts of this much wind generation could cause the deaths of between 91 and 804 bald eagles a year.

I recommend that the Land Use Advisory Panel develop a strategy that includes preparations for the cumulative analysis of the Scoping Plan recommended wind and solar development.  That process should start soon and determine a threshold for unacceptable environmental impacts.  For example, I am worried about eagles.  If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful.  Now that has occurred and I am not willing to chance that environmental victory.  Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines.  There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed.  The ultimate goal should be to refine the NYSERDA on wind power and biodiversity habitat sensitivity maps for the CLCPA resource development planning and siting process.

Specific Comments

The Land Use and Local Government advisory panel presented ten strategies from three subgroups. I will address each of the strategies below.

In the Land Use Strategies category five strategies were proposed.  The “promote and facilitate county and inter-municipal smart growth planning efforts, including focusing development in priority growth centers” and “promote coordinated regional approaches to meet climate goals while integrating transportation, housing, and land conservation needs” smart growth strategies rationales support conservation of areas.  Supposedly smart growth will support the development of open space conservation areas and conserve natural and working lands.  However, 35,200 MW of on-shore wind energy and 39,262 MW of utility-scale solar estimated by the Analysis Group will likely consume far more land than can be saved by smart growth.  The panel should address this contradiction.

The remaining three strategies proposed are:

      • Streamline and incentivize Smart Growth project review
      • Coordinate State planning funds/activities/entities to ensure that transportation, housing, and conservation actions are not in conflict and achieve reduce vehicle miles, clean energy, and equity goals
      • Build capacity at the regional level and provide support to municipalities to promote smart growth, facilitate clean energy siting, and reduce vehicle miles traveled

All three strategies are intended to facilitate smart growth development.  I think there is a huge disconnect between smart growth advocates and the rest of society.  There are reasons why society evolved to today’s land use patterns in New York and smart growth development is an attempt to change those choices all in the name of it’s for your own good.  If their case is good then fine but what this all means should be publicized more.

Three clean energy strategies were proposed:

      • Establish statewide higher energy codes, benchmarking, building performance mandates, and Property Assessed Clean Energy (PACE) Financing to avoid a patchwork of policies.
      • Encourage local governments to initiate Community Choice Aggregation (CCA) programs and community campaigns to increase local access to clean energy products and services.
      • Overcome legal, financial, regulatory, and technical barriers to greening municipal building, facilities, and fleets

I don’t think that there are any surprises in these strategies.  I do have a reservation about the CCA programs that are touted to allow energy choice.  Those programs cannot pay their own way so someone has to support them.  As more and more of these programs are implemented fewer and fewer will have to provide more and more support.  Unless you can guarantee that this initiative does not increase the number of people with unacceptable energy burdens it should not be included.

There were two Adaptation and Resilience Strategies:

      • Develop policies, programs and resources to reduce risks associated with acute climate hazards
      • Seek to ensure State and local investments assess climate change and resiliency impacts of projects

I support adaptation and resilience efforts because they are no regrets solutions to problems that are not going to go away.  However, I cannot help but take exception to the rationale used because whenever I have evaluated climate data the results don’t support the narrative that climate change effects due to mankind are showing up now.  The CLCPA in general and this characterization in particular confuse 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 reality is that any possible climate effect on extreme weather in the foreseeable future is a small tweak much smaller than normal variations.  Nonetheless acute weather hazards are a problem that should be addressed.

Conclusion

I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study.  It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar.  The only way this might work will require extraordinary amounts of wind and solar development.  When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.  This panel and the agriculture and forestry panel are in the best position to develop a strategy to address this problem.

The Problem with Innumeracy

I am a numbers guy and I am terrified by what appears to be the general perception that numbers don’t matter when it comes to an emotional issue or pre-conceived idea.  This post explains what I mean by data numeracy and offers examples of the problems I worry about.

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.

Meteorology

One of my responsibilities over my career was reporting data from meteorological monitoring stations to regulatory agencies primarily concerned with air pollution transport.  The first problem is that the monitors had to be located where they measured the wind speed and direction that represented the flow in the area.  Ideally the site had to be located in an open field with no nearby obstructions that could affect the wind direction.  Once the wind vane was up and running it was not enough to just report all the data collected.  There is a vital quality control check to make sure the data are realistic.  To do that I developed a program to review the data for oddities.  For example, if the wind direction did not vary at all for several hours that period would be flagged for further review.  If the temperature was below freezing and there was precipitation at the monitor then I would check the local weather station for freezing rain.  If that was observed then it was clearly appropriate to flag the data as missing and note in the data submitted to the regulatory agency that there was freezing rain.  The regulatory agency could easily check that decision and in the end, everyone was confident that the data submitted accurately represented the air pollution transport conditions in the area.

Emissions

Another responsibility of mine was to report data from continuous emissions monitoring systems (CEMS) from power plants.  Coming from my background it seemed logical that the data should be reviewed in a similar fashion as the meteorological data.  The problem is that there are physical relationships between weather parameters that make it much easier to flag problems.  Eventually I developed a system to review the data in a reproducible manner basically by looking for outliers and trends in the data.  My process flagged data that needed to be checked.  It was possible to compare the raw data against operating information and other information to see if the outlying data were just odd or incorrect.  The analysis did not say that the data were wrong only that they needed to be reviewed and validated.

In some cases, the numbers were measured correctly but were not representative. For example, during startup and shutdown fuel combustion processes are inefficient and some pollutant levels are high.  However, if your concern is the long-term average you don’t want to weigh those short-term values too much because they bias the result.  The Environmental Protection Agency uncritically used the CEMS data[1] in a couple of instances and proposed inappropriate limits as a result.

Global Warming

I am irritated by those who make claims that climate change effects are being observed now whenever there is an extreme weather event or a new weather record and have documented instances where the message is incorrect.  In the first place, the message is never that there might be good news associated with warming and more CO2 but always it is a sign of imminent, inevitable Armageddon.  I could write many posts on examples of this but just want to make a point about temperature trends.  Recall that when setting up a meteorological sensor you have to consider whether it will make representative measurements.  When measuring temperature trends, a big concern is whether conditions around the sensor are changing and over long periods of time that is difficult.  In addition, changes to the observing methods or instruments themselves all affect the trend and have to be considered when evaluating the results.  Ultimately measuring temperature trends is not easy and picking and choosing trends has over-hyped the observed global warming.  Not considering the data correctly for the task at hand undermines the concept that CO2 is the control knob for climate change.

Conclusion

Data numeracy recognizes that data should be reviewed and irregularities need to be checked.  Inconsistent data patterns do not prove that there is a problem only that further review is necessary.  If the data are audited in an open and transparent manner then everyone can be confident in the result.  Sadly, too many people will not accept numerical results that run counter to their pre-conceived notions and biases.

My personal experiences with data reporting were in regulatory contexts that in the big scheme of things don’t matter much.  But I think the data I submitted was unambiguous and believe that my results could withstand scrutiny.  On the other hand, the implications of global warming are a big deal because they are being used as the rationale to completely over-haul the entire energy system of New York and the world.  Unfortunately, much of the numerical evidence purportedly proving that global warming is occurring is ambiguous and the results do not standup to close scrutiny.  My concern is that when I have gone through the process to evaluate data to check a climate change impact and shown that the claim is not supported by the evidence it has not been uncommon that people reject the results.

UPDATE – Revised on January 14, 2021

That brings me to the Election of 2020.  From what I have observed there were sufficient irregularities in the presidential election results that an open and transparent audit of the election results was appropriate.  For example, a verification analysis similar to ones I have done in the past looked at data with an algorithm looking for instances of unusually large sudden additions of votes in batches much faster than almost all the others, and far above the “normal” pace. “Odd” in this case means absurdly unusual — in Minnesota one dump at 5:30am was a net gain of 113,755 Biden votes at 19 standard deviations from normal or a probability of 1 in 1081. I am aware of one instance of a computer forensics analysis of the Dominion Voting System in one county in one state.  Something similar is needed anywhere “odd” data were observed.  These issues do not prove anything except that further review is needed.  I hope that there were valid reasons for the irregularities but now it appears we will never know.

In my opinion the failure to follow up and determine exactly what was going on with these irregularities was a massive failure and anyone who argues that it was unnecessary doesn’t understand, does not want to understand, or is covering up.   The failure to reconcile the data undermines my trust in the process and the system itself.

 

[1] For example, an arithmetic average of mostly startup data was used to say that facilities were not using their air pollution equipment correctly.

Climate Leadership and Community Protection Act Deep Carbonization Workshop

On December 8, 2020, the New York State Energy Research & Development Authority (NYSERDA) and the New York State Department of Environmental Conservation (DEC) hosted the “Deep Decarbonization Workshop”.  Given the enormous challenges ahead of New York trying to transition the electric energy system to be completely free of fossil-fired generation by 2040 I naively assumed that the workshop would focus on decarbonization technologies that could be used to help New York achieve its ambitious Climate Leadership and Community Protection Act (CLCPA) goals.  Instead, with one exception, it was an infomercial for solutions that ignored New York’s specific needs and any limitations of the technologies described.

Background

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels: transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting political appointees and supported by agency staff are charged with this responsibility. 

Many of these political appointees were chosen to satisfy particular constituencies rather than for their technical expertise.  I maintain that it would be appropriate for them all to be given an overview of how the energy system, in general, and the electric system, in particular work.  Without that foundational knowledge I fear that their strategy recommendations will either not be grounded in reality or not be effective solutions.  Against that backdrop I hoped the workshop would address this need.

Instead, ”The workshop will feature presentations from nationally renowned technical experts such as the keynote speaker, Saul Griffith, a distinguished energy systems expert, inventor, entrepreneur, and engineer. Mr. Griffith, along with other experts, will discuss the opportunities and challenges around innovative climate solutions such as carbon capture; utilization and storage; green-hydrogen; hydrofluorocarbon replacements and process chemicals; and long-duration storage. The workshop will also feature a roundtable discussion with leading environmental justice advocates across New York State to explore how innovation in decarbonization can help advance environmental justice priorities.”

The CLCPA is the embodiment of the idea that political will can implement policies to meet stringent greenhouse gas reduction targets.  I believe many of the appointees accept that without question.  If anything, this workshop further misled those people.  Nothing in the workshop suggested that there might not be readily available proven technologies capable of replacing fossil fuels, much less the possibility that nothing exists today to solve the multi-day winter doldrum problem. This post briefly describes the presentations and missing context relative to the CLCPA.

Keynote Presentation

Saul Griffith set the tone of the workshop in his keynote presentation. His 15-minute presentation featured 53 slides so you can imagine his carnival barker schtick.  Don’t get me wrong the guy is brilliant. According to the Rewiring America website: “As Founder and Chief Scientist at Otherlab, an independent R&D lab, Saul Griffith helps government agencies and Fortune 500 companies understand energy infrastructure and deep decarbonization. He’s been a principal investigator and project lead on federally-funded research projects for agencies including NASA, Defense Advanced Research Projects Agency (DARPA), Advanced Research Projects Agency–Energy (ARPA-e), National Science Foundation and United States Special Operations Command (SOCOM). He was awarded the MacArthur “Genius Grant” in 2007.”

Unfortunately, his spiel is unrealistic magical thinking.  The underlying premise of his presentation was that a commitment to electrification and decarbonization makes it substantially easier to meet our energy demands.  He claims that 25% of our primary energy needs can be eliminated using distributed renewable energy generation because it reduces energy losses in production and transmission.

He goes on to claim that electrification of heating using heat pumps for homes, offices and some industry eliminates 6-7% more.  He illustrated how that is supposed to work in the following slide.

I will end my description of his presentation with this comment.  Griffith is from Australia and lives in the San Francisco area.  He is not familiar with the Upstate New York winter reality.  Here is my house in a typical winter.  His proposed plan is never going to work here.  By the way it usually is this cloudy and the snow was not particularly deep in this picture.  I can tell because I did not clean the snow off the roof.  One other issue with our winters is the occasional ice storm.  What do these people think will happen when there is no electricity for extended periods? 

Long Duration Storage

Scott Litzelman from U.S. Department of Energy – Advanced Research Projects Agency – Energy gave the most relevant presentation “Long-Duration Energy Storage as a Decarbonization Enabler”.  The organizers should have explained the connection between this resource and the E3 analysis Pathways to Deep Decarbonization in New York State – Final Report . E3 has explained that Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”   While it should be obvious that long-duration storage is needed for firm capacity resources I don’t think that all of the political appointees recognize the enormity of the particular challenge in New York.  The workshop squandered what would have been a perfect opportunity to make the point that if they cannot solve that problem this won’t work.

The presentation itself was pretty technical.  For the Climate Action Council and Advisory Panel members the presentation should have addressed the specifics of New York’s targets.  More importantly, there was no discussion whether the technologies discussed might be ready to be deployed in time for use to meet the CLCPA targets.

Hydrogen

Sunita Satyapal, Director- Hydrogen Program, U.S. Department of Energy, presentation “U.S. Department of Energy Hydrogen and Fuel Cell Technologies Office and Global Perspectives” was a pep talk for a hydrogen economy.  For example, he claimed that there has been a 25-fold increase in deployment in the last decade of electrolyzers that produce hydrogen.  Whether the world-wide deployment of 25 MW in 2019 offers hope or not was not discussed.  Just for context, On September 10, 2020 the Analysis Group presented a discussion of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study.  Their analysis included a generic resource that I think is the biggest problem for the CLCPA.  They call this resource the Dispatchable & Emissions-Free Resource.  It was “included to maintain reliability during the highest load hours of each modeling period” to “provide the majority of energy on the peak winter hour during the CLCPA load scenario”.  Their analysis shows that this category makes up 19% (32,137 MW) of the total capacity for their projected CLCPA load scenario.  Clearly hydrogen deployment with a world-wide deployment of 25 MW has a long way to go to provide any meaningful support to the CLCPA.  The rest of the presentation described many potential hydrogen technologies but completely ignored the context of the implementation needs for the CLCPA.  Completely ignored were the significant technological issues with hydrogen and the weak economic case.

Dr. S. Julio Friedmann, Center on Global Energy Policy, Columbia University gave a presentation entitled “Circular Carbon Economy with Carbon Capture, Carbon to Value, and CO2 Removal”.  His circular carbon economy consists of four components: reducing CO2 emissions, reusing CO2 where possible, recycling CO2 by altering their composition, and removing CO2 after it is produced.  The emphasis was on carbon capture and sequestration (CCS) in different forms.  He claimed there are 20 operating plants that are storing 35 million tons of CO2 per year worldwide.  He also claimed that the science and technology is well established.  According to the International Energy Agency there were 33 giga tons of CO2 emissions in 2019.  In other words, CCS is treating about one thousandth of the world’s emissions.  Again, there was no discussion of CCS in the context of New York.  Importantly, for it to be viable in New York there have to be locations where it can be stored but that issue was not discussed.

The final presentation, “Keeping cool without warming the planet (alt: heat pumps that don’t heat the globe), Climate Friendly Alternatives for High GWP Hydrofluorocarbons”, was presented by Kristen N. Taddonio, Senior Climate & Energy Advisor, Institute for Governance & Sustainable Development.  According to her, hydrofluorocarbons (HFC) have high global warming potential, climate friendly HFC alternatives can avoid up to 0.5 °C of warming and combining energy efficiency can avoid another 0.5 °C of warming.  I accept that there are climate friendly alternatives but am a little leery of the claims that 1 °C of warming can be avoided.  Just how much warming are they expecting?  More importantly is the New York context.  New York’s CLCPA 1990 emission inventory only has a total of 0.05 million metric tons global warming potential of HFC (less than 0.1% of the total) and the latest NYSERDA inventory has 10.37 million metric tons global warming potential of HFC which is less than 5% of the total.  We will have to wait to see what the current emission inventory fraction of HFC will be but I have no reason to believe it will be a significant fraction of the total emissions inventory. 

Conclusion

The CLCPA deep de-carbonization workshop wasted a perfect opportunity to bring some reality to the implementation challenges to: reduce greenhouse gas emissions 40% from the 1990 baseline by 2030, produce all electricity from zero-emission sources by 2040, and reach net-zero by 2050.  Based on my observations of panel discussions I believe many of the individuals charged with the responsibility for developing the scoping plan to implement strategies to meet those goals do not understand the enormity of this task.  A workshop to explain how energy systems work and quantify how much energy is needed and where to provide reliable power would give the panel members a common basis. 

Instead, the workshop mostly reinforced the notion that CLCPA targets will be met because of the political will of the State.  Long-duration energy storage is the key need and the presentation provided some hope in this regard.  Unfortunately, the presentation did not address the availability or applicability to New York so it is not clear if there is a viable solution to this critical requirement in the timeframe needed.  The keynote, hydrogen, and carbon sequestration presentations all sound great superficially but no context relative to the New York needs was given and they all have serious technological or implementation issues.  The hydrofluorocarbon presentation showed that there may be a solution to address this greenhouse gas but there was no mention of the fact that this is not a big deal for New York.

Finally, the workshop included an environmental justice representative roundtable discussion.  I did not listen to that, there are no slides from it and no recording has been posted.