Climate Leadership & Community Protection Act First Impression of Estimated Costs and Benefits

At the October 14, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) presented the first estimates of costs and benefits.  Not surprisingly they conjure up a way to claim that the benefits out weighed the costs.  This will be my first post on those claims.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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

Since I wrote this post the presentation slide deck (available here) and meeting recording (available here) have been posted. 

The Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline by 2030.  In 2030 70% or the electrical energy is supposed to come from renewable resources and by 2040 all electricity is supposed to come from zero-emissions sources.  The Council is composed of political appointees chosen more for their direct involvement in the CLCPA transition than their expertise in the energy sector so the New York State Energy Research and Development Authority (NYSERDA) is providing technical support by developing an integration analysis.

The October 14, 2021 Climate Action Council meeting included the following topics:

  • Overview of scenarios and recap of sectoral results
  • Costs and Benefits Analysis
  • Electric System Sensitivities
  • Air Quality and Health Effects
  • Update on Approach for Potential Carbon Pricing Analysis

There is fodder for multiple posts in this material but most will have to wait until another day.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  NYSERDA and their consultants determined that those recommendations did not meet the targets and prepared an integration analysis to provide alternatives.  The following scenario overview lists three scenarios that meet or exceed the limits.  (For this post I will concentrate on Scenario 2: Strategic Use of Low-Carbon Fuels.)  The integration analysis will be incorporated into the draft scoping plan in October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

October 1, 2021 Meeting Presentation

Societal Benefits

The focus of this post will be on the first mention of cost and benefit data at the October 14, 2021 Climate Action Council meeting.  As expected, they made up a way to claim that the benefits out-weigh the costs.  Readers should keep in mind that the costs are real.  Completely re-building the entire New York energy sector will cost enormous sums of money and, at first glance, estimates of several hundred billion for the complete transition are laughably low for the all-in costs.  On the other hand, estimates of benefits are heavily dependent upon value judgements and analysis assumptions to the point that there are such a wide range of possible outcomes that claiming a single value is fantasy.

According to the presentation the integration analysis approach will include three components as shown in the following slide captures.   The integration analysis will evaluate societal costs and benefits of greenhouse gas (GHG) mitigation for the different scenarios relative to a reference scenario.   The value of avoided GHG emissions will be calculated based on guidance provided by the Department of Environmental Conservation (DEC). The third component is an analysis of health co-benefits.  In the remainder of this post, I will focus on the alleged benefits.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting
Screen capture of slide presented at October 14, 2021 Climate Action Council meeting
Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

According to the presentation the cost of inaction exceeds the cost of action by more than $80 billion.  For the Strategic Use of Low Carbon Fuels scenario the estimated costs are $340 billion and the benefits total $420 billion.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

The benefits breakdown in the Strategic Use of Low Carbon Fuels scenario into two categories.  In the first there are $160 billion in benefits due to improvements in air quality, increased active transportation, and energy efficiency interventions in low- and moderate- income homes.  Reducing GHG emissions avoid social costs due to climate change to the tune of $260 billion.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

Value of Avoided Carbon

I described problems with the DEC Value of Avoided Carbon Guidance in a couple of posts earlier this year.  In my first post I noted that the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal.  I believe that the guidance approach is wrong because it applies the social cost multiple times for each year of an emission reduction.  In the second post I described how I  submitted comments on this topic to DEC and NYSERDA in February and followed up in June.  The response “We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level.”  I will just summarize my arguments and the effect on the estimated benefits here.

In section §75-0113, Value of Carbon the CLCPA states that the “social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions” and that “As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero.”  The Social Cost of Carbon (SCC) is the present-day value of projected future net damages from emitting a ton of CO2 today. 

In my comments to DEC, I explained that it is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. . The social cost calculation that is the basis of their carbon valuation sums projected benefits for every year subsequent to the year the reductions are made out to the year 2300.  Clearly, using cumulative values for this parameter is incorrect because it cumulatively counts those benefits repeatedly.  I contacted social cost of carbon expert Dr. Richard Tol about the use of lifetime savings and he stated that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”.  Note that Dr. Tol is using the social cost of carbon nomenclature rather than value of carbon label. 

The integration analysis claims reducing GHG emissions will provided societal benefits of avoided economic damages of $260 billion.  The correct value is much less.   DEC promulgated the 1990 baseline GHG emission inventory consistent with the CLCPA last year. According to §496.4 Statewide Greenhouse Gas Emission Limits (a) For the purposes of this Part, the estimated level of statewide greenhouse gas emissions in 1990 is 409.78 million metric tons of carbon dioxide equivalent, using a GWP20 as provided in Section 496.5 of this Part.  The DEC Value of Avoided Carbon Guidance recommends a social cost of $121 in 2020 and $172 in 2050.  If New York had magically eliminated all of the 409.78 million tons of GHG in 2020 the societal benefit of those reductions would have been $49.6 billion making the integration analysis 5.24 times too high.  If all the reductions occurred in 2050 the societal benefit would be $70.5 billion making the integration analysis 3.7 times too high.

Public Health Impacts

The health benefits of the strategic use of low carbon fuels scenarios total $160 billion.  While the health effects analysis considered multiple air pollutants and health benefits from energy efficiency the primary pollutant of concern is inhalable particulates or PM2.5.  I did a post on claims of inhalable particulates impacts in New York City last year.  The New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report is often referenced and provides a typical and consistent health benefit estimate from inhalable particulates.  The DOHMOH report concludes: “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.

The DOHMOH report specified four scenarios for comparisons (DOHMOH Figure 4) and calculated health events that it attributed to citywide PM2.5 (DOHMOH Table 5).  Based on their results the report notes 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.

Based on years of developing and using models I prefer observed results any time as opposed to model projections.  In this regard it is important to note that the NYS DEC air quality monitoring system has operated a PM2.5 monitor at the Botanical Garden in New York city since 1999 which provides inhalable particulate trends for New York City.  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 (2018-2020) for a comparable three-year average at the Botanical Garden is 7.4 µg/m3 which represents a 43% 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

Until such time that the CLCPA Scoping Plan bases its inhalable particulate health benefits on the observed health outcome benefits observed from the reductions that have occurred, then I do not accept the health benefits suggested in the Integration Analysis.  If an analysis were done using actual data, I believe that the results would most likely show a much smaller benefit.  Note that the reduction in PM2.5 annual average concentrations in the Strategic Use of Low Carbon Fuels scenario predicts at most a reduction in PM 2.5 of 0.35 µg/m3.  The observed reduction in New York City since 2005-2007 is 5.6 µg/m3

Energy Efficiency

In the effort to prove that the costs of the New York transition to the CLCPA goals is out-weighed by benefits the integration analysis comes up with energy efficiency benefits.  I am not going to discuss this claim in detail so I provide the methodology slide below.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

The following slide lists the health-related measures and I am leery of the claims.  They expect to reduce asthma-related incidents by increasing weatherization presumably to keep polluted ambient air out.  It is my understanding that asthma rates have increased even as pollution rates have gone down so this measure may have the perverse effect of increasing whatever is causing the observed asthma incidents.  I have no idea how this strategy can reduce trip or fall injuries.  Health benefits from reduced hot and cold thermal stress are claimed.  Note that increased costs of energy in England have forced lower-income residents to lower their thermostats thus increasing thermal stress from cold.  This is a likely outcome in New York.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

Conclusion

I have no doubts that when I evaluate their costs for the transition that I will find markedly higher costs.  Even if estimated costs end up being reasonable, the incorrect valuation of the societal benefits of carbon reductions drops the benefits to no more than $70.5 billion. Coupled with their values for health effects benefits that reduces total benefits to $230.5 billion as opposed to costs of $340 billion. 

Moreover, the costs will be real but the benefits are something else again.  The social cost of carbon is the greater alleged benefit.  Because that represents the societal benefits of reducing a ton of carbon today totaled out to 2300 and the impacts of climate change are more expensive closer to 2300 that means that most of those alleged benefits will not accrue to this generation of New York residents, their children, their grandchildren, or even their great grandchildren.  In addition, I have major reservations with the alleged health benefits.

The bottom line is that CLCPA is not cost effective relative to societal benefits.

Climate Leadership & Community Protection Act 2030 Electric System Target Feasibility

On August 29, 2021 I posted an article, CLCPA Electric System Targets, that discussed the politics behind the 2030 electric system target that requires a minimum of seventy percent of the state wide electric generation to be provided by renewable energy systems.  I argued that because the definition of renewable energy systems excludes nuclear and renewable natural gas (e.g., methane capture from landfills, farm manure digesters, and other organic sources) that meeting that target was impossible.  However, I did not provide evidence for that claim.  This article documents why I believe it is impossible.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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 previous article completely documents the target and relevant definitions but here is the simple version.  § 66-p, 1 (b) states that (b) “renewable energy systems” means systems that “generate electricity or thermal energy through use of the following technologies: solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity”.  The target is defined in § 66-p, 2 (a) as “a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems”.

Future Electric System Projections

I looked at feasibility of the 2030 target earlier but I had the mistaken impression that nuclear was included as part of the 70% allowable energy sources.  The premise of my impossibility argument is that the current renewable energy sources distribution from the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017 report is so small that it is unreasonable to expect that it can be raised to 70% in ten years even if nuclear is included.  Table 1 combines data from the NYSERDA patterns and trends document and the New York Independent System Operator (NYISO) Gold Book for the last three years.  In 2020 the CLCPA renewable energy sources contributed only 24% of the electrical energy system generation (Table 1).  This article will look at a couple of refined projections made for the future electric system under the CLCPA.

The first study is the Initial Report on the New York Power Grid Study as described in Appendix E: Zero-Emissions Electric Grid in New York by 2040 Study (“Zero-Emissions Study”).  It is not surprising that this analysis prepared in part by New York Department of Public Service and NYSERDA staff claimed that “there are feasible pathways to meeting the CLCPA targets” because state policy takes it as a given that CLCPA targets are only a matter of political will.  However, upon closer examination using alternate reasonable alternate assumptions the target is unlikely to be achieved.

Table 2 compares the assumptions in the initial scenario of the Zero-Emissions Study with alternative assumptions.  The New York Independent System Operator (NYISO) Gold Book includes estimates of future load in Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  In this table the baseline annual energy forecast is 145,960 GWh but that includes a reduction of behind the meter solar PV 8,013 GWh.  Because the Zero-Emissions Study includes estimates for this parameter it should be added to the annual forecast to make the 2030 expected load 153,973 GWh.  That makes the renewable energy resources percentage of the total smaller.  The Table 2 alternative assumes the same capacity for distributed behind the meter solar, utility-scale solar, and onshore wind but bases the capacity factors on observed data rather than the “NREL Wind Toolkit and National Solar Radiance database”.  Land-based wind capacity factors averaged 25% over the last five years.  Assuming that all the additional wind capacity developed between now and 2030 meets the NREL 34.6% capacity factor and that all the existing wind capacity continues to operate at 25% the more appropriate combined New York capacity factor should be 31.5% thus reducing the expected energy produced.  The latest Gold Book includes data that indicates that grid solar in New York has a capacity factor of 17.6%.  With respect to grid solar in Table 2 that raises the energy produced.  However, the Zero-Emissions Study assumes that distributed solar will have the same capacity factor as utility-scale solar and that is not supportable.  The NYSERDA New York Solar Study lists different capacity factors for three different classes of distributed solar – all lower than the utility-scale value.  For the alternative I conservatively used the highest value of the three.  As a result of all these alternative assumptions the alternate renewable energy resources percentage is 67.1%.

The second analysis was done by Energy and Environmental Economics, Inc. (E3) for NYSERDA in the spring of 2020.  E3 described their analysis in Pathways to Deep Decarbonization in New York State – Final Report [PDF]. E3 used their RESOLVE model to model the electric sector:

Our modeling approach also incorporates detailed electricity sector representation using E3’s RESOLVE model. RESOLVE is used to develop least-cost electricity generation portfolios that achieve New York’s policy goals, including 100% zero-emission electricity, while maintaining reliability.

When the report was released, I analyzed the approach and concluded that: “While their models give the veneer of respectability to the projections, the reality is that the inherent over-simplifications of their models under-estimates the difficulties of the transition in New York and gives a false sense of security to their assurances that implementation will succeed”.  Of particular concern relative to the electric system feasibility is how they handled renewable resource availability.  In the following slide they point out that firm capacity is needed to meet a multi-day period of low wind and solar output in the winter.  In my analysis I argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore.  At the time I asked E3 how they calculated renewable resource availability but they never responded.  The key point is that the ultimate estimate of the electric system generating resources necessary to ensure reliable electricity availability at all times must be able to handle this worst-case situation.  It is not clear to me that the projections in their decarbonization pathway address this in their estimates of resources needed.

I extracted the data in Table 3 from their Supplementary Workbook [XLS] dated October 10, 2020.  I estimate that this analysis projects that renewable energy resources will only total 67.6% instead of 70%.  Even so I think their estimate is high.  My biggest concern is that there are no firm, zero-emissions resources listed for 2030 and I think some will be needed to meet the worst-case period they highlight as a concern.  There also are consistency issues relative to the other estimates.  E3 handled imports differently.  That is good because it does give a renewable energy resource estimate for imported hydropower but it causes the total imports to become negative.  I don’t know how battery storage should be handled relative to the CLCPA definitions so I just lumped it into the renewable energy resources category. 

In addition to the problem that both studies did not prove that their renewable energy resources solution adequately addressed the critical reliability problem of a multi-day period of low wind and solar, both studies presume that the projections for future renewable energy resources can be built on a schedule that ensures that they are available in 2030.  The Accelerated Renewable Energy Growth and Community Benefit Act is supposed to expedite renewable energy development but that does not preclude the possibility of litigation on specific projects or other holdups in the permitting process. In the case of offshore wind, I believe that delays are inevitable because the infrastructure to support building the turbines has to be developed first and those developments are also subject to permitting and construction delays.  Finally, there is a real possibility that the availability of the critical minerals and metals needed for these renewable technologies could slow implementation and increase costs. 

Conclusion

In general, the feasibility approach in the analyses described here is to simply estimate future load and then calculate the energy resources necessary to match that load.  There are multiple issues with these analyses.  First, and foremost, the emphasis appears to be on annual comparisons but the critical reliability issue is a multi-day period in the winter when wind and solar resource availability is low but the load requirements for universal electrified heating and transportation are high and must be met to ensure the safety and health of New York residents.  It is not clear that any of the projections adequately addressed this requirement.  In addition, I don’t think that the projections included the necessary resources needed to provide ancillary transmission grid services as I described in a post on one of the studies.  Finally, I am sure that the studies did not incorporate the resources needed to maintain New York State Reliability Council requirements.  Therefore, these projections under-estimate the resources needed to provide reliable electricity.

The Zero-Emissions Study and the E3 decarbonization pathways analysis both can claim that their approaches achieve the goal that the electric system use 70% renewable energy resources in 2030.  Based on this analysis I think their assumptions about renewable resource availability are overly optimistic.  The practical reality is that time constraints on permitting, procurement, construction and development of supporting infrastructure will most likely delay implementation of the ambitious proposed resource development.  Further compounding the viability of the proposed resources are the New York State Reliability Council requirements and the need for ancillary grid transmission services.  When all these factors are considered, I believe that it will be impossible to meet the 2030 target without endangering reliability.

Climate Leadership & Community Protection Act Electric System Targets

On July 18, 2019 former 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.  I have been posting articles about the feasibility of the CLCPA targets and got the following comment in response to my post CLCPA Feasibility Relative to NYSERDA Patterns and Trends: “Please provide a cross reference to the fact that CLCPA includes nuclear power as acceptable form of renewable energy”.  This post provides a more complete discussion than my reply.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

When I started researching this comment request, I was confident that the legislation actually listed nuclear as a renewable energy system.  However, when I researched it, I found out I was wrong.  Subsequently I discussed this with colleagues who are more attuned to New York policy and legislative considerations than I am.  As is usual with any aspect of the CLCPA whenever you start to dig into the details there are complicating nuances.

Climate Change Regulations

There are three implementing regulations for the CLCPA legislation that became effective on January 1, 2020.  Article 75 – Climate Change was added to the New York Environmental Conservation Law. 

§ 66-p. Establishment of a renewable energy program was added to the New York Public Service law.  Finally, § 54-1523. Climate adaptation and mitigation projects was added to the Environmental Protection Act.

For the purposes of this article the relevant regulation is § 66-p. “Establishment of a renewable energy program”.  The pertinent amended language reads:

§ 66-p. Establishment of a renewable energy program.

1. As used in this section:

(a) “jurisdictional load serving entity” means any entity subject to the jurisdiction of the commission that secures energy to serve the electrical energy requirements of end-use customers in New York state;

(b) “renewable energy systems” means systems that generate electricity or thermal energy through use of the following technologies: solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity.

2. No later than June thirtieth, two thousand twenty-one, the commission shall establish a program to require that:

(a) a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and

(b) that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, the commission shall consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions. The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.

The renewable energy systems definition clearly excludes nuclear.  My colleagues all agreed that was a deliberate choice.  It also excludes renewable natural gas that is to say methane from landfills and other organic sources.  That also was a deliberate design choice by the “anti-natural gas in any form” zealots who drafted the regulation.

The first electric system target in the public service law mandates 70% renewable energy by 2030.  Clearly the intent was that 70% of the electric energy has to come from the defined renewable energy systems.  Note that the 2040 100% Carbon-free Electricity target is for a different set of energy sources.  Also note that there is a lifeline such that the Public Service Commission can modify the obligations to meet the target if there are issues with “safe and adequate electric service”.

Discussion

 In my conversation with colleagues who are more conversant about environmental policy in New York, I explained that my work suggests that meeting the 2030 target is impossible with 70% solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity resources. A forthcoming post will delve into the numbers but for the moment trust that assessment.

The first policy question that comes up is the rationale behind the overly ambitious 2030 target.  Ultimately the decision on that target was made by a few key individuals with former Governor Cuomo at the top.  The first possibility is that the authors didn’t understand the magnitude of the effort needed and inadvertently chose an impossible target for the decision makers.  Given the rhetoric that meeting the “climate change challenge is only a matter of political will” it is possible that they actually believe it.  The second possibility is that political optics were the primary rationale despite recognition that the targets were overly ambitious. Given that we are talking about targets that are nine years away, cynics might wonder if this was the case with the presumption that the decision makers would be out of office by then or that the voters would have forgotten who passed the legislation.

The second policy question is what happens when it becomes obvious that the targets cannot be met.  This question arises on several time frames for the 2030 target.  The first time it comes up is in in the current planning phase.  Preliminary modeling of all advisory panel recommendations to the Climate Action Council which includes all sectors of the economy indicates the collective recommendations fail to meet the near- and long-term emission reduction targets.  The integration analysis presumably has to increase the emission reduction strategies until the plan meets the targets and that comes out later this year.  There is a requirement for an on-going assessment of the status of emissions reductions relative to the targets so the question can come up once the strategies are implemented.  Finally, in 2031 we will know for sure whether the 70% target was achieved.

What happens when it does become obvious that the target cannot be met? The 2040 target includes the language that the PSC may “modify the obligations of jurisdictional load serving entities and/or the targets” but it is not clear to me that allows changes for the 2030 target.  The politicians who put the state in this bind could argue that these are just goals but the environmental advocates and renewable energy grifters have already started flatly stating that this is the law and that it must be enforced.  While there are certainly legal constraints on litigation for this, there seem to be many lawyers willing to push the envelope on legal standing when it comes to suing deep pocket fossil fuel companies for alleged impacts of climate change.  As a result, I suspect that failure to meet the targets will result in litigation.

There is another aspect of this that is relevant.  The CLCPA did not incorporate any funding mechanism and it is wildly optimistic to think that the targets can be met without additional funding.  The last legislative session considered the Climate and Community Investment Act (CCIA) that was intended to fund many aspects of the CLCPA.  Once the costs and direct consumer impacts in the CCIA were estimated by some observers (there is yet to be an estimate of costs by the state agencies) there was a groundswell of disapproval, many legislators backed off support, and the legislation did not pass.  Every indication is that next legislative session this bill or something similar will be back.  The environmental community and environmental justice activists are going to be pushing for passage but will have to overcome the obvious problem of costs.

Conclusion

As I will show in a future post, there is no way that New York can expect to meet the 2030 target for 70% of the electric system energy requirements powered by the defined renewable energy systems of the CLCPA.  In my original assessments of feasibility, I had the mistakenly believed that nuclear power could be used to help meet the 2030 target because that was the only way the state could come close but it turns out I was wrong.  Nuclear is an acceptable source for the 2040 zero emissions electric system but cannot be used for the 2030 goal.  It is a sign of the times that there are activists that want to shut down the upstate nuclear units as well and that will make the 2040 target more difficult. This post clarifies the definitions and addresses possible reasons why the legislation was drafted to make that distinction.  I don’t believe there is any rationale for this that puts the authors of the legislation or the politicians that approved the law in a good light: they either knew and didn’t care or didn’t bother to check feasibility.

I am not sure whether there will be consequences for this particular aspect of the abominable CLCPA.  As the implementation requirements are defined and impossibility of meeting this target becomes evident, I don’t see how this can continue to be a blind spot for New Yorkers.  Hopefully the public will catch on soon that the costs for this virtue-signaling action will be significant and that New York’s contribution to global warming is so small that anything we do cannot have a measurable effect on the alleged warming from GHG emissions.  If that does not end the nonsensical implementation, maybe when the legal requirements to mandate use of electric vehicles or ban the use of natural gas for home heating, cooking and hot-water will initiate protests.  Unfortunately, many in industry agree with me that it might take a catastrophic blackout with impacts comparable to the Texas blackout in February 2021 to finally motivate voters to demand the repeal of the CLCPA.

Climate Leadership & Community Protection Act Reliability Planning Speaker Session

Note: When this was written and posted the recording was not available. The Session recording was posted on August 30, 2021

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. Over the last year Advisory Panels to the Climate Action Council have developed and submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  If reliability is a key condition for CLCPA implementation then the briefing summarized here should have been held a year earlier.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  My posts describing and commenting on the strategies are available here. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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

There is a long history of blackouts in New York State in general and New York City in particular that is a primary driver of reliability concerns in the state.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In 1959 and 1961 surges in electrical use caused blackouts and “The outage spurred changes to better protect the city’s power grid from future blackouts”.  The 1965 blackout was the first regional blackout and was caused by a transmission problem in Ontario causing a wave of disruptions in the transmission system.  Over 30 million people and 80,000 square miles in Ontario, New York, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and Vermont were left without power for up to 13 hours.   There was another blackout in 1977 that was limited to New York City directly related to the fact that most of the City is on islands and is a load pocket.  It was caused by storms cutting off transmission into the City and in-City generation was unable to replace the load without disruptions.  Without sufficient local power, protective devices turn off overloaded lines and transformers to prevent physical damage to the equipment and this led to the outages.  As a result of this blackout, reliability constraints were strengthened to ensure that when storms threaten transmission into the City that sufficient in-City generation is available to prevent a re-occurrence.  In 2003 there was another regional blackout caused by a computer software problem.  Grid operators identified the cause and then developed procedures to prevent it from happening again.  In 2012 tropical storm Sandy caused massive blackouts exacerbated by flood protection weaknesses.  Since then, there have been investments to strengthen the infrastructure to prevent a reoccurrence.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.

The members of the Climate Action Council and the advisory panels who are charged with providing recommendations to meet the CLCPA targets were chosen because of their political connections not their energy system expertise.  During the development of the advisory panel recommendations, it was obvious that reliability was only receiving token consideration and that many of the panel and council members did not understand the issues and requirements for a reliable energy system.  As a result, I was one of many commenters who suggested that a briefing on the topic of electric system reliability would be appropriate.  Obviously, this presentation should have been held early in the process but later is better than never. 

Note:  At one point I found the August 2, 2021 speaker session presentation on a NY website but it not available at this time nor is the recording of the presentation available.  My downloaded copy of the presentation is available here.  I recommend reading the session presentation as it gives a good overview of reliability issues facing New York in the transition to net-zero.

The session included presentations from six organizations with varying levels of reliability background, experience, and responsibilities:

  • New York State Reliability Council – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

I will address each organization and their comments below.

Reliability Council

The New York State Reliability Council (NYSRC) is a Federal Energy Regulatory Council (FERC) approved entity responsible for “the promulgation of reliability standards for New York, which are mandatory requirements for the New York Independent System Operator”.   The presentation explains that one of the primary concerns of the NYSRC is the Installed Reserve Margin (IRM) which is the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   In order to determine that value the NYSRC conducts a “complex probabilistic analysis of generation and transmission resources, and demand response”.  Their presentation went on to describe in the following slide all the responsibilities of the operators who keep the system operating reliably.

The presentation explained that as the percentage of renewable resources increases operating the system must change and the planning for those changes must evolve.  It summed up this section as follows: “Limited fuel diversity and over dependence on energy limited resources is a risk to reliability”.

In the last section of the NYSRC presentation results from some planning work already done were presented.  Using an example of solar resource impact on resource adequacy it was shown that the “addition of 26,000 MW of new solar generation raises the reserve requirement to ≈22,000 MW & allows the retirement of only 4,000 MW of current resources” (my emphasis added).  The presentation went on to show that the addition of all the projected renewable energy resources needed to eliminate the use of fossil fuels in 2040 results in a reserve requirement of ≈50,000 MW in order to meet the CLCPA 2040 goals and the NYSRC Resource Adequacy IRM Reliability Criterion.  The current reserve requirement is around 6,000 MW.  It is important for readers to realize that this means that 50 GW of renewable capacity have to be developed in addition to the 12 GW of onshore wind, 10 GW of offshore wind, 17 GW of utility-scale solar, 6 GW of behind the meter solar, and 15 GW of energy storage projected in the NYS DPS/NYSERDA “Initial Report on the New York Power Grid Study” annual installed capacity supply mix for 2040 because that study did not address the IRM requirement.

The takeaway message of the NYSRC to the Climate Action Council was:

With the intermittency of renewables and the electrification of the economy, substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced, will be required to maintain reliability in the transition to meeting CLCPA requirements.

New York Independent System Operator

The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established a predecessor organization, the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and the NYISO was established to replace the NYPP.  Because the change to the wholesale electricity market is the reason for their existence, the NYISO unquestioningly supports market driven responses to any problem.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the CLCPA. 

Unfortunately, in my opinion, the NYISO is not as independent as it should be.  In a recent post I explained how the Cuomo Administration has co-opted the NYISO to the point that their recommendations are couched in terms that do not adequately convey the enormity of the technical issues associated with this transition.  Moreover, their faith in market solutions de-values the risks of developing those solutions in the face of the fact this has never been done before.

In this light it is not surprising that the NYISO presentation emphasized their recent Power Trends 2021: New York’s Clean Energy Grid of the Future report that describes current and emerging trends transforming the grid and electricity markets.  The report describes how hourly demand patterns fluctuate diurnally and seasonally today.  It goes on to explain that the CLCPA de-carbonization efforts will change the magnitude and demand plans in the future, most notably the peak load will occur in the winter instead of the summer.  One NYISO analysis projected future winter energy production by resource type.

The important reliability finding of the NYISO work is that the worst-case future resource concern will be a winter-time wind lull.  During those periods solar resources are low because days are short and the sun is at a low angle, and wind resources can be less than 25% of the wind capacity for seven days at a time.  Consequently, there is a need for a large quantity of installed dispatchable energy resources needed for a small number of hours.  They must be able to come on line quickly and be flexible enough to meet rapid and steep ramping needs. The report does not come out and emphasize the important point that there is no current utility-scale resource that meets those criteria.

Utility Consultation Group

This is “A consortium of New York’s gas and electric utilities, focused on providing expertise and perspective to the Climate Action Council and its advisory panels”.  Given that most of these utilities are dependent upon rate case decisions made by representative hand picked by the Cuomo Administration there is an obvious reluctance to take a strong contrary position.  Given that Cuomo has threatened to revoke a utility operating license over a disagreement in gas supply, I have no doubt that there is real concern that a difference of a fraction of percentage point in any rate case  increases could easily make a difference in the stock price colors any statements by this organization.

The consortium fully supports the CLCPA goals even while noting that “customers will continue to value reliability, resiliency, and safety of the energy system during and after decarbonization”.  There is the hint that technology development is necessary which may make this a bit difficult and a plea that cost effective solution are necessary.  Finally, there is the obligatory shout out that environmental and economic justice need to be considered.

The presentation claims that the “Transition to a clean energy future is feasible, but must be orderly, responsible and cost effective”.  Heaven forbid that they suggest the transition is anything but feasible but where in the world is there proof that it is possible much less responsible and cost effective?  Given their situation they cannot say this is unlikely to work but it is disappointing that they did not respond with more concern about the potential difficulties.

New York State Department of Public Service (DPS)

DPS has oversight of utility reliability planning.  This covers traditional transmission & distribution investment planning and the utilities’ obligation to “reliably serve forecasted customer loads”.  There is a nuance to this that is not universally understood.  This process is used to ensure adequate transmission and distribution capability to serve customers but the production of the electricity itself is not included.  Instead, the wholesale market overseen by the NYISO provides the power.  Note that the power producers have no similar obligation to generate electricity.  The market is supposed to provide that incentive.  I believe there is a common misconception that somehow if things don’t work out that the generators are covered by some sort of obligation to serve but that is not true in the same sense as the T&D utilities.

The presentation explained that DPS constantly evaluates on a real time and forward-looking basis electric system reliability based on a multitude of factors and impacts including customer demands, planned and unplanned outages, weather, regulatory requirements, interconnection requests, and state policy.  It was noted that staff works with utilities on these matters but that the PSC has regulatory authority and responsibility to ensure reliability is maintained.  The presentation does not explicit make the distinction between T&D reliability planning and planning for generation.  Instead, it was explained that DPS staff participates actively in the NYISO planning process, NYSRC committees, and the NPCC board who do have the generation responsibilities.

In response to the CLCPA and Accelerated Renewable Growth Act, the Public Service Commission (PSC) issued orders directing the Utilities to undertake a study and to propose a planning and investment framework for local transmission and distribution investments driven by CLCPA.  The Utilities filed the study and their proposals for CLCPA investment criteria on November 2, 2020.  At the same time, the PSC and NYSERDA undertook two other studies.  One identified “possible grid interconnection points and offshore transmission configurations and assessed onshore bulk transmission needs to reliably integrate 9,000 MW of offshore wind generation”.  The second study identified “bulk transmission upgrades potentially necessary to support the State’s path to a 100% decarbonization of the electricity sector by 2040”.  The Power Grid Study filed on January 19, 2021 combines all three studies.

The presentation implicitly suggests that this work addresses all the problems.  It is important to note that their summary of reliability considerations makes many of the same points addressed in the NYSRC and NYISO as shown in the following slide.

Vote Solar

The purpose of this reliability presentation was to present the concerns of the organizations and professionals who are responsible for maintaining electric reliability.  In a blatant example of the political machinations that underly the CLCPA and implementation of the law, Stephan Roundtree, Jr., Northeast Director of Vote Solar  presented his take on reliability.  Mr. Roundtree holds a B.A. in History from Boston College, a J.D. from Northeastern School of Law, and a Master’s in Environmental Policy from Vermont Law School.  My point is that in addition to the fact that he is a crony capitalist representing an organization dependent upon the largesse of subsidies from laws like this, he has no apparent relevant utility-scale power system experience. 

Unfortunately, not only does he have no experience he is a member of the Power Generation Advisory Panel.  As such his presentation mirrors the reliability mis-understandings of many of the members of that panel.  Those mis-understandings are precisely the reason that many asked for this presentation.  In my opinion the reliability presentation is a year late in its attempt to provide the background information necessary for the panel to adequately do their job.  A reliability presentation should have been given to the Council and the Power Generation panel at the start of the process.  Admittedly it is not clear that the political appointees would have tried to understand the reliability difficulties described by those responsible organizations and people responsible for keeping the lights on.  As far as I can tell their politically valuable vested interests preclude listening to inconvenient facts much less trying to reconcile them with their pre-conceived notions.

Roundtree’s first slide lays down the gauntlet: “Not a question of whether we can or should shift the grid to be 100% renewable and maintain reliability; it’s the law”.  As someone with no reliability responsibilities that is easy for him to say.  Sadly, because the virtue-signaling politicians that wrote the law did not include a feasibility requirement before implementation of the “best in the nation” emission reduction targets it is the law.  However, if the scoping plan honestly describes the technical difficulties and costs, I cannot see how they can describe implementation of the law as feasible or affordable.  The big question is then what?

Roundtree describes three key takeaways: 

  1. Reliability is paramount, particularly for vulnerable communities in climate crisis;
  2. Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective;
  3. Aggressive adoption of a renewables-based grid is arguably the only lawful path to decarb and equity mandates

He accepts that reliability is “paramount” as the first takeaway.   He notes that “Lack of electricity service during extreme weather events impacts disadvantaged community members first and worst” and that “Interruption of electricity, combined with lack of wealth & resources, can lead to deepening poverty, housing insecurity, illness, and death”.  I agree with what he says.  However, I am sure he does not understand that the greatest threat to electric system reliability is ill-considered implementation of renewable resources in the manner he proposes.

In his introduction the second takeaway states that “Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective”.  In the presentation the second takeaway morphed into “Repowering or perpetuating fossil generation is not necessary for reliability”.  That was a majority position of the Power Generation panel but there was a minority opinion arguing that it is too soon to say whether that is possible.  As proof of the feasibility of a renewable power grid he argues that “Centralized fossil-based grids are proving to be unreliable in our changing climate and cannot withstand increasingly frequent extreme weather events” and cites the Texas energy debacle last February.  I don’t believe the 2021 Texas energy debacle was caused by renewable resources but it does foreshadow the difficulty replacing them when the wind isn’t blowing at night.  The lesson to be learned is that Texas energy policy prioritized and subsidized unreliable energy sources (wind and solar) at the expense of reliable ones (natural gas, coal and nuclear) for decades but did not incorporate market mechanisms to ensure that the system could operate under market conditions that had occurred in the past. 

He goes on to say that “modernizing the grid by adding demand flexibility, efficiency, and distributed energy resources including rooftop solar and storage but also EVs and microgrids is the solution we need to meet reliability needs of tomorrow” and that “renewables pair cost effectively with local grid modernizing infrastructure like storage and microgrid tech don’t have to pay the huge external cost of fossil”.  These claims are articles of faith amongst environmental advocates perpetuated by the grifters selling renewable solutions. 

The proof offered is a Rocky Mountain Institute analysis.  I reviewed their work and found that they selectively choose how they want to treat resources.  There are hopeful assumptions for distributed resources and battery energy storage that have no track record in utility-scale applications (hundreds of MW of capacity).  There is no consideration of life-cycle resources needed for all the batteries, solar panels and wind turbines. Finally, while the treatment of the technological components necessary to provide the resources are overly optimistic in my opinion, their treatment of costs is much worse.  Both current costs and expected cost expectations in the future are more aspirational than rational.  Roundtree also cites an advocate analysis that is contradicted by the NYISO analyses. Frankly I believe that Roundtree’s experience and background are ill-suited for him to realize that his cited proof is anything but evidence that his approach can work to keep the lights in New York City on during the worst conditions.

In the introduction his final takeaway was another veiled threat that “aggressive adoption of a renewables-based grid is arguably the only lawful path”.  This also morphed into “Local generation & storage promotes equity” in the presentation.  Again, his claims are articles of faith.  “Fossil pollution causes vast public health challenges which largely aren’t included in reliability vs transition discussion” is always highlighted as a religious tract but the fact that air pollution reductions from fossil pollution have led to large improvements in air quality while the purported health impacts haven’t also improve sis never addressed.  The true believers also claim that “Building renewables, batteries, and microgrids in high load disadvantaged communities results in improved public health and better preparedness / functionality during grid stresses and shocks”.  The first claim that green energy leads to better public health ignores the environmental and health impacts of the mining of rare earth minerals used in batteries and wind turbines.  The proposed solution will not eliminate environmental and health impacts it will just move them and, arguably, make them worse elsewhere.   The claim that renewables and batteries will improve functionality during grid stresses is unproven on the utility-scale.  The final rationale for this takeaway states that: “Prioritizing state investment in disadvantaged community local grid infrastructure is a pathway to meet CLCPA investment equity mandate” is probably true but should not be a prime reliability concern.

New York Department of State Utility Intervention Unit

The Division of Consumer Protection’s Utility Intervention Unit (UIU) is supposed to act on behalf of the ratepayer.  They represent “the interests of New York consumers before federal, state and local administrative and regulatory agencies engaged in the regulation of energy, water and telecommunication services”.  According to their about webpage:

The UIU participates in the deliberations of the Public Service Commission (PSC), the New York Independent System Operator (NYISO) and the Federal Energy Regulatory Commission (FERC), as well as utility and energy-related interagency working groups, task forces and committees. The UIU analyzes filings, submits testimony and briefs, engages in settlement discussions and participates in evidentiary hearings in PSC and FERC regulatory proceedings and participates in NYISO governance.

Their presentation starts off with an interesting quote by Peter Fox Penner, Institute for Sustainable Energy: “In a nutshell our challenge is to steer clear of the technical and institutional pathway that together yield poor service, expensive power, or a failure to decarbonize quickly.”  I agree that is the key challenge but question whether all of these goals are possible.  Of course, that it is possible to have affordable, reliable and emissions-free electricity is the fundamental basis of the CLCPA so no state agency can question the orthodoxy of it.  Nonetheless including this quote suggests that the agency representing consumer interests is aware of the problem.

The presentation goes on to show three graphic representations: the electric system of the past, the present, and what is supposed to happen in the future.  Then there is a slide that makes the important point that the one constant in all three cases is that load and generation must balance. Then considerations of changes in load over time are discussed.  In 2021 the question is “how are the decisions now going to impact prices in the future and adoption of electrification?”.  In 2025 the status must be evaluated to see if programs have reached their targets and where they stand.  In 2030 we have to ask if we reached the renewable goal.   In 2035 the question is “Are there any new technologies or improvements to existing technologies?”   In 2040, the question is whether the electric system has weaned itself off fossil fuels.  There are strengths, weaknesses, opportunities and threats every step of the way.  In their conclusion the importance of planning was stressed.  I suspect that the UIU is as uncomfortable as I am that the CLCPA does not include a feasibility mandate.

Conclusion

The warning in most of the presentations was similar: it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions.  The NYSRC notes that “substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced” needs to be developed.  The NYISO explicitly points out that a “large quantity of installed dispatchable energy resources is needed in a small number of hours” that “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs” but only implicitly points out that these are magical resources that do not exist yet for utility-scale needs.  The utility consultation group explains that “technology development and diversity of clean resources are essential for long term success” but provide no details of the enormity of that task.  Even the DPS makes the point that “evaluating and implementing advanced technologies to enhance the capability of the existing and future transmission and distribution system” is necessary for future reliability.  The Utility Intervention Unit does not provide a comparable warning but does stress the importance of planning and the need to address new technologies.   None of these organizations was in a position to state the obvious that relying on as yet unproven technology to transition the electric system on the schedule of the CLCPA is a serious threat to reliability.

As further proof that the CLCPA is at its root simply political showmanship and virtue signaling, the technical session on reliability allowed an organization with a vested interest in today’s inadequate renewable technology to be included.  Giving Vote Solar a chance to present the message that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” proves that the whole thing is politically motivated because the presenter had neither the background or experience to understand the dangers and the requirements to maintain reliability.  Moreover, the speaker has no relevant responsibility but the organizations and professionals who are responsible for keeping the lights on all made the point that as the need for sufficient levels of new clean energy resources increases during the grid transformation “some of these resources rely on technologies that do not currently exist for utility scale application.” 

Finally, note that problems with a similar transition are already being noted elsewhere.  In August 2020, California grid operators had to impose rolling electric blackouts to maintain grid reliability standards.  The basic problem was that power demand peaks as people turn on their air conditioning in the late afternoon just as the solar power supplies cut off as the sun goes down.  So little power was available the California grid operator had to reduce load to prevent an uncontrolled, much wider scale blackout in the event of a problem at an operating power plant.  The scale of that problem pales compared to the scale of the situation when the CLCPA requirements to electrify heating and transportation increase winter load and the elimination of fossil generation increases the dependency upon wind and solar electricity generation.  In the winter at New York’s latitude the days are short and the solar panels could be covered by snow.  When there is a prolonged cold snap accompanied by light winds both renewable resources will be unavailable and the only question is for how long.  With respect to reliability, planning for this worst-case availability scenario has to develop a system that can prevent a future New York blackout that could result in people freezing to death in the dark unable to flee. 

The ultimate question is whether the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel. Absent changes to the law itself I fear New York consumers will be lab rats for a politically motivated virtue signaling empty gesture that is going to cost enormous sums of money, and, in the event of a major blackout, cause much more harm than good.

Post Script: This text was drafted before Governor Cuomo resigned over sexual harassment allegations.  In my opinion his actions towards his accusers were the worst kind of bullying.  They are also symptomatic of his Administration’s micro-managing treatment of any dissent from any individual or organization in the state.  I am sure that there are many technical professionals in the staff of many state agencies involved in the CLCPA implementation that know that you cannot have an affordable, reliable, and emissions-free electric system but have no way to speak out with those reservations lest they jeopardize their careers.  They same can be said of organizations trying to provide value for their shareholders.  Hopefully, the new administration will at least consider the reliability risks brought up by the NYSRC, NYISO, Utility Consultation Group, DPS and Utility Intervention Unit.

Energy Storage Best Practices from New England

This article was published at Watts Up With That.

According to their website, the “Clean Energy States Alliance (CESA) is the leading US coalition of state energy organizations working together to advance the rapid expansion of clean energy technologies and bring the benefits of clean energy to all”.  On August 5, 2021, they released “Energy Storage Policy Best Practices from New England: Ten Lessons from Six States” that “explores energy storage policy best practices and lessons learned from the New England states.”  This post gives an overview of the report.

The report “aims to inform state policymakers and regulators seeking to expand energy storage markets”.  I will address the following ten recommendations that “each state should consider as it charts its own course”:

  1. Identify benefits of energy storage that are not priced or monetizable in existing markets; recognize and accommodate the multi-use nature of energy storage resources.
  2. Establish a monetary value for each storage benefit and use those values when calculating cost effectiveness and setting incentive rates. Estimated value is better than no value at all.
  3. Create incentives to support storage operations that further state policy goals. Incentivize storage use, not just storage deployment.
  4. Set ambitious clean energy and/or emissions reduction goals and explicitly include energy storage as an eligible technology. Define how storage is expected to be deployed and operated to help meet the goals.
  5. Incorporate energy storage into existing clean energy and efficiency programs.
  6. Incorporate equity considerations into energy storage program design from the start, not as an afterthought.  This should include significant incentive adders for qualifying participants.
  7. Support a wide variety of storage ownership, application, and business models.
  8. Anticipate and proactively address needed regulatory changes.
  9. Replicate and improve on successful programs implemented in other states.
  10. Fund demonstration projects when needed, but do not rely on grants alone to build a market.

After Superstorm Sandy struck New York City the importance of resilient power became evident to the green energy policy makers and the idea that battery storage could help was broached.  The report states that their efforts began “with the idea that advanced battery storage—especially when combined with rooftop solar and other energy resources—could provide clean, resilient backup power, allowing critical facilities such as emergency shelters and health clinics to ride through future grid outages.”   A frequently used example of the viability of distributed systems is a hospital in Princeton, NJ that remained on-line despite widespread grid outages due to Sandy.  Unfortunately, proponents of these distributed energy approach who cite this as proof of the viability of the concept don’t mention that the hospital had a natural gas fired backup system.  The presumption that coupling battery storage with renewable resources will work as well is untested in practice.

The report goes on to note that energy storage can be used to provide other energy services: “demand management, frequency regulation, grid infrastructure investment deferral, renewables integration, and load shifting.”  The report claims that: “As the list of possible storage applications expanded, state storage policy would need to become more sophisticated, and state utility commissions would need to review many regulations that had been written prior to the widespread availability of advanced battery storage, which now needed to be revised to accommodate this new technology”.  The ten recommendations address these points.

The first recommendation is to “Identify benefits of energy storage that are not priced or monetizable in existing markets and recognize and accommodate the multi-use nature of energy storage resources”.  The example benefit given is behind-the-meter (BTM) resilient power that is the ability to support critical facilities and infrastructure during an electric grid outage.  As proof they note that that is “widely recognized as having value—otherwise, there would not be a thriving market for backup generators.”  The claim is that “Battery storage, when properly configured, can provide resilient power, and this is one of the storage applications that customers value most highly.”  Therefore, they recommend that the states figure out some way to monetize this benefit.  However, in my case while I chose to install a generator because resilient power is important to me, I wanted the system to be able to handle the multi-day outages I have experienced due to a wind storm and an ice storm.  In both cases there is no way I could have installed enough rooftop solar and storage to provide power throughout those days-long outages.  Resilient power needs are for the worst case, not just most of the times the power goes out.  The worst case is a long duration extreme hot or cold weather situation and energy storage is a poor choice for those scenarios.

In this recommendation, the report states that “Advanced energy storage can provide a wide variety of energy services, and storage owners frequently need to “stack” multiple services (each representing a revenue stream or cost savings opportunity) in order to make storage investments economic.”  It includes a highlighted section that discusses a “multi-use” resource.  While it recognizes that the different services are “not necessarily” available at the same time, it goes on in Table 1 to list the ratepayer individual savings for six beneficial services then sums for the total.  Clearly, this is not appropriate.

The second recommendation is to “Establish a monetary value for each storage benefit and use those values when calculating cost effectiveness and setting incentive rates. Estimated value is better than no value at all”.  The paper lists values for seven non-energy benefits of distributed storage in Massachusetts.

The first claimed benefit is Avoided Power Outages – “Battery storage helps avoid outages, and all of the costs that come with outages for families, businesses, generation and distribution companies”.  I agree that outages have costs for families and businesses and battery storage that can reduce or eliminate them clearly has value.  However, the only way I can think that outages would affect generation companies is if there is a power plant outage and energy storage is used during the outage but the existing system has enough spare capacity to handle that concern.  I cannot think how energy storage would reduce costs for a distribution company.

The second value is Higher Property Values – “Installing battery storage in buildings increases property values for storage measure participants by: 1. Increasing leasable space; 2. Increasing thermal comfort; 3. increasing marketability of leasable space, and 4. reducing energy costs”.  My understanding is that energy storage systems need space so it is unclear how they would increase leasable space.  The other three benefits also seem to be stretch the concept of “value”.

Next is Avoided Fines – “Increasing battery storage will result in fewer power outages and fewer

potential fines for utilities”.  I have no clue how energy storage can provide this benefit.  Utilities get fined when they don’t plan for enough resiliency in their system to prevent extreme weather impacts on their transmission and distribution systems.  Energy storage cannot prevent power outages caused by damages to the wires.

The fourth value is Avoided Collections and Terminations – “More battery storage reduces the need for costly new power plants, thereby lowering ratepayer bills, and making it easier for ratepayers to consistently pay their bills on time. This reduces the need for utilities to initiate collections and terminations.”  The ability of battery storage to reduce the need for new power plants is an article of faith amongst the advocates of this technology.  However, the claims are long on rhetoric and short on quantitative analysis.  If an old power plant has to be replaced it would take one heck of a lot of energy storage to provide the output of any natural gas fired turbine.   Until I see their numbers then I will continue to believe that the costs of sufficient energy storage coupled with renewable resources would be far more than the costs of a new turbine.

The fifth value is Avoided Safety-Related Emergency Calls – “Increasing battery storage results in fewer power outages, which reduces the risk of emergencies and the need for utilities to make safety-related emergency calls”.  In theory if a customer has a need for uninterrupted power a personal battery storage system could reduce emergency calls.  However, you are back to the issue of energy storage capacity versus outage time.  If I have the need for uninterrupted power, I want it available for long durations.  In order to provide that with energy storage I have to purchase so much capacity for such a rare event that it cannot be cost effective relative to a generator.

The sixth value in the document is Job Creation – “More battery storage benefits society at large by creating jobs in manufacturing, research and development, engineering, and installation”.  I have my doubts about this claim but don’t want to do the research necessary to refute this.

The last value in this recommendation is Less Land Used for Power Plants – “More battery storage reduces the need for peaker plants, which are more land-intensive than storage installations—benefiting society by allowing more land to be used for other purposes.”  This is only true at the facility itself.  However, the grand plan is to combine energy storage with power generated from wind and solar power.  Ignoring the vast land use requirements for enough coupled energy storage and diffuse renewable generation is an egregious oversight as shown in the following picture from the report.

The third recommendation is to “Create incentives to support storage operations that further state policy goals. Incentivize storage use, not just storage deployment.”  The report states that because

“clean energy incentives generally support broader policy goals such as energy sector decarbonization, electrification, sustainability, modernization, efficiency, resilience, and reliability” that the “energy storage incentive program should not be about ‘storage for storage’s sake,’ but should be designed to support specific policy goals”.  The report notes that battery storage can “provide several different services depending on how it is used” so it suggests that “a state energy storage program must actively link the use of battery systems to applications that support specific policy objectives. However, it does not recognize that battery systems that support one policy objective cannot necessarily support all other policy objectives.  For example, batteries used for energy storage when intermittent renewables are not available need to be kept charged at their maximum capacity but batteries for frequency regulation and to smooth intermittent fluctuations in supply are kept at an intermediate capacity so that they supply power and draw power as needed.  Consequently, I believe the report underestimates the amount of energy storage needed.

Furthermore, there is another example of the disconnect between energy storage by itself and energy storage coupled with renewable energy to solve intermittency.  Figure 4A, Misaligned Financial Signals claims that a California energy storage program to reduce emissions was set up incorrectly because “battery owners frequently discharged their batteries during low emissions periods, rather than charging when emissions were low and discharging when they were high”.  Honestly, I don’t think the author understands emissions control programs or diurnal peak loads.  Time of day emissions matters for conventional air pollution but does not matter for GHG emissions because GHG contribute only to a global long-term alleged problem.  Diurnally, California renewable energy primarily comes from solar which peaks during the middle of the day.  Figure 4A shows the batteries being charged during the day and then discharging later in the day causing the emissions to go to zero.  Diurnal peak loads are usually in the late afternoon so even though there are emissions in the middle of the day the program eliminated emissions during the peak period – it worked precisely as it was supposed to if the goal of the program is to reduce nitrogen oxides for ozone attainment.  The “solution” shown in Figure 4B is simply switching the charging source to wind because if it is charging in the night, it certainly is not coming from solar. 

The fourth recommendation is “Set ambitious clean energy and/or emissions reduction goals and explicitly include energy storage as an eligible technology. Define how storage is expected to be deployed and operated to help meet the goals.”  Regulators take ambitious goals as an article of faith believing that somehow the goals can be met because previous air pollution control programs have always met their goals.  The concept that feasibility should be considered is not an element of many regulators and no politician’s thought process.

The next recommendation is “Incorporate energy storage into existing clean energy and efficiency programs.”  I think this is pretty obvious so no comment.

The sixth recommendation is “Incorporate equity considerations into energy storage program design from the start, not as an afterthought.  This should include significant incentive adders for qualifying participants.”  The rationale for this is:

Low-income and underserved communities spend proportionally more of their income on energy costs than other segments of the population. They are also more likely to suffer from energy related environmental and health burdens; and they are hit hardest by natural disasters and the accompanying grid outages and have fewer resources with which to recover. In short, they are most in need of the cost savings, resilience, and health benefits energy storage can offer.

This is another example of limited thinking.  While I do not dispute the underserved communities are disproportionally impacted by environmental impacts and extreme weather events the presumption that cost savings will accrue from clean energy are not supported by the experience of any jurisdiction that has tried it.  Furthermore, if society not only subsidizes clean energy but also attempts to provide it to those who cannot afford existing energy then it only increases the costs to everyone else.  Most importantly, those who may be just able to afford energy bills now but will not be able to afford them in future net-zero energy systems will be impacted by this recommendation.

The recommendation listed in the introduction as “Anticipate and proactively address needed regulatory changes” apparently morphed into the seventh recommendation in the report “Pay attention to regulatory friction points” during the documentation preparation process.  The point of the recommendation is that there may be unintended consequences when new energy storage policies are adopted.  The analogy used is regulatory whack-a-mole where the states will have to “spend several years fixing problems one at a time as they pop up” after they implement a new rule.  In my opinion this should be addressed as part of the feasibility study that most advocates don’t think is necessary.  However, the presumption that all the problems associated with converting an energy system using dispatchable energy sources that has taken decades to evolve to one utterly dependent upon intermittent energy sources in a decade or two can be anticipated is wishful thinking.  Anyone in a net-zero jurisdiction will be a guinea pig for this experiment.

The eighth recommendation is “Support a wide variety of storage ownership, application, and business models”.  The rationale is that energy storage can “integrate renewables and make regional grids more efficient, reduce transmission congestion, defer distribution grid investments, make variable generators dispatchable”. It is also claimed that it can “flatten demand peaks, balance microgrids, make critical infrastructure resilient, and provide ancillary services”.  Not noted is that these applications are mostly theory and, especially in a de-regulated market, developing business models that work for both society and the grifters selling energy storage as the solution to anything and everything will be a challenge.

The ninth recommendation is “Replicate and improve on successful programs implemented in other states”.  Obviously, there is no sense reinventing the wheel so this makes sense.  However, “success” has to be defined well because it can be in the eye of the beholder.

The last recommendation is to “Fund demonstration projects when needed, but do not rely on grants alone to build a market”.  As I read this document, I became more and more convinced that the author had limited electric energy system experience.  He claims that “there is little need to demonstrate another utility-scale lithium-ion battery providing peak demand reduction and frequency regulation services when numerous such projects already exist in the region”.  The report is illustrated with pictures and descriptions of five energy storage facilities with the largest having an 8 MWh duration and totaling 22.4 MWh.  The average daily load in New England is 260,120 MWh so those facilities are inconsequential.  I don’t think there is any question that in these micro grid applications that batteries can provide peak demand reduction and frequency regulation services.  I question whether the author understands that the issue is a matter of scale and it is not at all clear that peak demand reduction and frequency regulation is feasible when non-dispatchable resource penetration is significant.  Ultimately it is obvious that ratepayers cannot provide grants for all the energy storage projects needed to try to support the utility grid. 

Conclusion

The report concludes that “With falling battery prices, increasing adoption of state clean energy and decarbonization goals, and forward-looking utilities (and ratepayers), many states have a strong foundation for success”. The report is supposed to offer “some suggestions to policymakers for building on that foundation”.

I am unconvinced that this report provides any value.  The report was not proofed well because wording of the ten recommendations in each chapter do not match the description of the ten recommendations in the introductory text.  I was prompted to write this article by the following quote from the introduction: “In Vermont, for example, Green Mountain Power’s residential battery program has placed battery systems in more than 3,000 homes; the utility dispatches this aggregated, distributed energy storage resource to reduce peak demand, saving ratepayers millions of dollars.”   The report notes that the “Stafford Hill solar farm includes 7,700 solar panels capable of producing 2.5 megawatts (MW) of electricity, enough to power 2,000 homes. Therefore 3,000 homes are powered by 3.75 MW.  I would love to see the math that produces millions of dollars of savings from shaving peaks by 3.75 MW.  I just don’t think this is credible and indicates a lack of knowledge about electric systems by the author.

I believe there is a fundamental oversight not mentioning that stacking energy storage applications is problematic.  A single energy storage system cannot supply all the different resources suggested (e.g., by summing the benefits of each resource in Table 1) in this report.  There is another fundamental issue with the report because it considers energy storage by itself.  Batteries are supposed to solve non-dispatchable renewable energy issues.  Claiming that energy storage improves resilience when the coupled energy input is fragile and intermittent is at best a stretch.  Finally note that there was very little in the way of caveats and cautions with respect to this unproven, at utility scale and using renewables, technology.  As a result, policy makers will not get a full appreciation of the challenge of this transition.

Climate Leadership & Community Protection Act Feasibility Relative to NYSERDA Patterns and Trends

I recently published an article describing how the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) comprehensive summary of energy statistics and data could be used to assess where the state stands now relative to Climate Leadership and Community Protection Act (CLCPA).  I looked at data up to 2017 to assess the status of two targets: 70 percent of electricity from renewable sources by 2030 and 100 percent carbon-free electricity by 2040. Because the data in the report is three years old, I stated that it was difficult to assess feasibility using historical energy use data.  This article addresses feasibility by projecting energy use requirements.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets cannot measurably affect global warming when implemented.   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

For anyone interested in New York energy information the Patterns and Trends documents are a great resource.  One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data.  For space reasons the report does not list all the numbers but the underlying spreadsheet includes everything.  Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind.  In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of the year.  The latest report available, Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) publication date was March 202,1 38 months after the end of 2017.. 

In the previous article I explained that Patterns and Trends data showed that in 2017 30% of the electricity generated in the state came from fossil fuels and that nuclear provided 32%.   In 2017, hydro provided 18%, municipal solid waste, biomass and geothermal provided  2%, solar had yet to show any significant generation and wind provided 3%.  The CLCPA defines renewable energy sources as wind, solar, biomass, geothermal, hydro and nuclear so recent trends in those sources are important to detemine feasibility of the 2030 goal.

New York Historical Energy Source Calculations

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  This section describes the methology and assumptions used to develop those data. 

In order to determine the feasibility of the 70% renewable by 2030 target these data list four source categories: fossil fuels, imports, nuclear and all the other categories lumped together as CLCPA renewables.  I broke out nuclear to show the impact of the retirement of Indian Point nuclear station.  The CLCPA renewables categories includes biomass and municipal waste generation that I think may not be acceptable as CLCPA renewable at the end of the day but for now they are included.

The data from 2001 to 2017 is directly from Patterns and Trends.  The data from 2018 to 2020 comes from a variety of sources.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  The projected category values are set up to equal these load projections.  The fossil category data are based on heat input data from EPA Clean Air Markets Division reported emissions data.  I included a 1.05 multiplier adjustment to account for difference between historical EPA and NYISO Btu data.  The NYISO Gold Book observed data for the nuclear, wind, and other generation sources was used.  Hydro used the maximum value of the last ten years from Patterns and Trends.  Utility scale solar was assumed to increase linearly to 5 TBtu by 2020.  Imports were calculated as the sum of the maximum observed value over the last ten years from Patterns and Trends plus whatever energy was needed to balance the total electric load and sum of all other categories.  In other words, it was assumed that imports made up the differences in total component loads to total energy forecast load.

It is difficult to make supportable projections but I did want to illustrate the effect of retiring the Indian Point nuclear station so I did project energy use in the best case in 2021 and 2022.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  For fossil use I took the 2020 data minus the annual reductions necessary to get to zero in 2040 by straight extrapolation.  Hydro used the maximum value of the last ten years from Patterns and Trends.  The nuclear electric production was set to the average of the last five years of all nuclear facilities less Indian Point.  Eliminating the load from Indian Point units 2 and 3 removes 15,774 GWh of CLCPA renewable energy from the NYS electric system.  I assumed that waste, land-fill gas and wood are assumed to stay constant at 26 Tbtu, the rounded maximum value in last ten years.  With regards to other renewables note that distributed solar is included in the NYISO total load projections.  For utility-scale solar and wind I used Energy Information Administration Table 54.  Electric Power Projections by Electricity Market Module Region for two New York State regions to estimate the total renewable capacity (GW) additions.  I assumed future utility-scale development will be 50-50 solar and wind with a combined capacity factor of 23% to estimate total energy produced in GWh.  I used Patterns and Trends data to develop a conversion factor based on recent data to estimate TBtu.  As an aside note that for some reason this conversion factor has been changing the last five years contrary to all other sectors.  Finally I believe that the EIA projections for future capacity development are wildly optimistic – 1640 MW are supposed to come on line in 2021.

Current New York Energy Sources

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  In 2001, nuclear provided 28% of the energy and other CLCPA renewable sources another 16% for a total of 44%.  Fossil fuels provided over half the energy and imported energy made up the remaining 5%.  In 2020, nuclear provided 30%, down from the high of 32%, other CLCPA renewable sources provided 24% for a total of 54% of CLCPA renewable energy, fossil was down to 32%, and imports up to 15%.  I project that in 2022, the retirement of Indian Point will reduce nuclear down to 21% and that other CLCPA renewable sources will increase to 30% for a total of 51% of CLCPA renewable energy.  The assumption that fossil fuel use will decrease reduces its share to 29% but increases imports to 20%. 

Eight years after the projections in Figure 1, nuclear and the Climate Act renewable energy category are supposed to provide 70% of the energy to produce electricity.  Those categories only comprise 51% in 2022 in my projection.  Estimating the future growth of those categories is difficult but one key factor should be noted.  Despite the supposed urgency of reducing fossil fuel emissions, the Cuomo Administration shut down Indian Point nuclear station which generated 165 TBtu of energy or about 12% of the total energy of the state.  In order to replace that energy four times as much wind capacity as currently exists has to be developed.  Until such time as the renewable resources to replace the lost nuclear are developed, fossil fueled energy or imported energy has to pick up the necessary load.  In this projection it was assumed that imported energy picked up the load but it is likely that fossil will replace much of the load because of transmission constraints to New York City and Long Island.

There is another aspect to imported electricity that I cannot address.  The CLCPA requires that out-of-state resource renewable attributes be defined so that there is no leakage, that is to say the emissions just move out of state and are not reduced.  Unfortunately, I cannot find any information on the attributes of out of state electricity so I cannot comment on how this will affect meeting the target.

CLCPA 70 percent of electricity from renewable sources by 2030 Feasibility

Now that the status has been established we can look towards 2030.  I changed my methodology to use GWhr instead of TBu to compare different sources.  I based my projections on the feasibility of meeting the 2030 load requirements for wind and solar on the following assumptions.  I assumed that the electricity provided by imports, hydro, geothermal, biomass and municipal waste generation all equal the average of the Patterns and Trends data for 2015 to 2017.  Nuclear generation was also set at the 2015 to 2017 average less Indian Point nuclear station energy.  I calculated the annual reductions needed to meet the 2040 zero fossil fuel emissions target and used the 2030 value.  Using those assumptions that means that wind and solar generation have to meet the difference between the sum of those categories and the total load projected by NYISO or 37,256 GWhr.

There are two CLCPA targets for renewable development.  In 2025 the target is 6,000 MW of solar and by 2035 there is a target for 9,000 MW of off-shore wind.  The NYISO Gold Book projections for total load assume that all of the 2025 solar goal is behind the meter so their load forecasts incoporate the target.  For utility solar by 2030 I assumed three scenarios for solar deployment up to 6,000 MW.  For 2030 offshore wind I assumed three scenarios: all 9,000 MW in 2030, only the current 4,300 MW under development and a third scenario midway between those two.  For on-shore wind I assumed total capacity would be 1,.5, 2, and 2.5 times the current capacity.  This gives a low, medium and high range of potential wind and solar deployment.

Table 1 lists the capacity (MW), capacity factors, and projected energy (GWhr) from all the scenarios and four total scenario projections.  Scenario 1 uses the low end estimates for all sources and has a deficit of 11,736 GWhr.  Scenario 2 uses the mid-point estimates for all sources and has a 1,735 GWhr surplus.  If al the estimates are at the high end in Scenario 3 there is a surplus of 15,205 GWhr.  My personal best guess (Scenario 4) is mid point for utility solar and on-shore wind but the low estimate for off-shore wind because the entire infrastructure to develop off-shore wind has to be built first.  That scenario has a deficit of 6,500 GWhr.

I believe that a major problem with meeting the target is that permitting and construction will slow the deployment of solar and on-shore wind.  I reviewed wind and solar project applications for New York’s Article 10 permitting process to get an idea of the magnitude of development for the bracketing scenarios .  Based on the solar applications between 19,000 and 56,000 acres and between 6 and 18 million solar panels will be needed for the solar scenarios.  The wind applications suggest that between 15 and 25 projects with 60 turbines at each site and that between 900 and 1,500 3.3 MW turbines will be needed for the on-shore wind scenarios.  The off-shore wind project information is too scanty at this point to develop similar information.  This many projects with such extensive scopes inevitably fail to meet schedules.

Conclusion

While the results shown suggest that meeting the 2030 target can be met in two out of four scenarios there is a big issue with the approach used.  Replacing fossil and Indian Point annual energy output with intermittent wind and solar energy outut is not a one for one energy substitution.  While a wind turbine can provide a certain amount of energy during a year, it is not dispatchable.  Because the total annual load is based on the sum of varying loads over hours, days and seasons, much more intermittent wind and solar capacity is needed to replace the dispatchable capacity that produced historical energy and maintain a reliable system that provides electricity whenever and wherever it is needed.  The real test of feasibility is to determine the amount of solar and wind necessary to meet the worst case situation – a wintertime wind lull when both wind and solar generate minimal levels of power.  Therefore do not believe any claims for feasibility that are based only on annual energy output.

I want to re-iterate the point that these data do illustrate one hypocritical aspect of the CLCPA and New York energy policy.  The CLCPA includes nuclear generation in the definition of acceptable “renewable” sources of electricity.  The CLCPA is supposed to protect New Yorkers from the existential threat of climate change but New York energy policy retired nearly 2,000 MW of acceptable renewable power when Indian Point was retired.  If the threat of climate change is so pressing how can that be justified?  The replacement of the annual power produced by Indian Point will consume all of the off-shore wind currently under development so at a minimum it makes meeting the CLCPA targets that much more difficult.

World Weather Attribution Pacific Northwest Heatwave Headlines

On July 25, 2021 the Syracuse Post Standard reprinted an opinion piece from the Washington Post “We need to stop fiddling while the world burns” that described the World Weather Attribution analysis of the recent record-breaking heat wave in the Pacific Northwest.  In order to justify the need for massive transformations of the energy system such as New York’s Climate Leadership and Community Protection Act stories like this that claim that the heat wave would have been “virtually impossible without human-based climate change” receive much publicity.  However, upon close examination the claims are hype and exaggeration that do not prove the need to “stop fiddling”.  The fact is that the reason for the heat wave is mostly extreme weather caused by natural variability with a little bit of climate change thrown in.

The difference between weather and climate is constantly mistaken by CLCPA advocates and the July 22 Climate Action Council meeting presentation included a slide that prominently highlighted the Pacific NW heatwave.  This has become such a frequent mis-representation that I have a page that references my evaluations of climatic effects that turned out to be weather events and other similar analyses by other authors.

In this instance there is no need for me to do an evaluation of how climate change affected this extreme weather event.  Dr. Cliff Mass is a meteorology professor at the University of Washington whose has spent his career developing an understanding of the weather and climate of the Pacific NW.  In addition, he is currently doing research running high resolution, state-of-the-science regional climate models of the region.  I do not believe that there is anyone more qualified to address this event and its relationship to climate change.

In a series of three posts, he has discussed this problem and this post summarizes his findings.  In the first post, Was Global Warming the Cause of the Great Northwest Heatwave? Science Says No, he described the causes of the heatwave.  In the second post, Flawed Heatwave Report Leads to False Headlines in Major Media,  he discussed the specific report that was the basis for the Washington Post editorial.  In his last post, Miscommunication in Recent Climate Attribution Studies, he addressed how that report “provided misleading information”.  I will summarize his findings below.

In the first post, Dr. Mass described the heat wave as follows:

The maximum temperatures during the heatwave were as high as 30-40 degrees Fahrenheit above normal.    Seattle had a high of 108F, 35F above the normal high of 73F.  Quilluyte on the Washington Coast zoomed to 109F compared to a normal high of 65 (44F above normal).  Throughout the region, all-time temperature records were broken, representing the hottest day on record at many locations.

He believes that the “Pacific Northwest is warming and human emission of greenhouse gases is probably the origin of much of it” but goes on to explain the specific reasons for the record setting temperatures.  He showed how a persistent high-pressure ridge developed that brought warm air to the area.  The already warm air became “supercharged” because the wind flows caused downslope winds which compress the atmosphere markedly increasing the temperatures.  In both cases the exact conditions needed to cause the high impacts had to align at the same time.  It was a very rare and extreme weather event.  Dr. Mass believes that climate change has increased temperatures in the area 1 to 2 F so that effect is added to the observed temperatures.  As a result, he believes that climate change is only responsible for that amount of the observed 30-40 degrees observed above normal.

The World Weather Attribution analysis of the heat wave claimed that “Based on observations and modeling, the occurrence of a heatwave with maximum temperatures as observed in the area was virtually impossible without human-caused climate change”.  In the second post, Dr. Mass states:

This claim is not supported in the document or by the rigorous science, and, in fact, the material in the attribution report contradicts this assertion.  I will provide substantial evidence that the heatwave attribution report, which has not been submitted for peer-review, is profoundly flawed, with serious technical and interpretative errors.

Dr. Mass points out that their rationale that global warming was the main factor was riddled with contradictions that show no evidence that their conclusion was true.  In his technical explanation of the flaws in the report he examined local data trends and climate model results.  Dr. Mass evaluated local trends of daily high temperatures and found that their analysis was incorrect.  They used a climate model that was not refined enough to capture the factors that affect local weather conditions and improperly used an inaccurate emissions estimate.  Finally, he showed that their evaluation was inconsistent with their conclusion. He sums up: “If anything, much of the material in the report is highly suggestive of a random, black swan event that is slightly enhanced by greenhouse gas warming”.  Exactly Dr. Mass’ conclusion.

In his final article he explains “why their basic framing and approach is problematic, leading readers (and most of the media) to incorrect conclusions” by way of two examples.  He describes a physically meaningful interpretation with an example where the essential event would have happened without any effect from global warming.  He notes that this is “a good example of the golden rule of climate attribution:  the more unusual and extreme the event, the greater the proportion of the event is due to natural variability rather than global warming”.  In contrast the World Weather Attribution analysis focuses only on the headline interpretation.  They ignore the physical situation and actual impacts and the fact that natural variability is dominating the situation.  Instead, they only look at the event itself.  In this case they note that temperatures were up to 40 F higher than normal and say this would not have happened without global warming.  That is true but it ignores the fact that global warming was only responsible for 2 F and 38 F would have been a record-setting heat wave.  This miscommunication leads people to think that global warming was the primary driver rather than natural variability.

He concludes this article with the following:

Many of the climate attribution studies are resulting in headlines that are deceptive and result in people coming to incorrect conclusions about the relative roles of global warming and natural variability in current extreme weather.  Scary headlines and apocalyptic attribution studies needlessly provoke fear.  Furthermore, incorrect and hyped information results in poor decision-making.  

……………………….

We need to worry about climate change and take steps in both mitigation (reduce greenhouse gas emissions) and adaptation.  But hype and exaggeration of its impacts only undermine the potential for effective action.

I don’t agree with all of his projections for the future because I don’t trust climate models based on my model verification work that found it was possible to get the right answer for the wrong reason.  As a result, I believe it is better to emphasize adaptation over mitigation because the effects of natural variability on extreme weather have devastating impacts which a more resilient society can handle better.  However, we agree that hype and exaggeration of the causes of extreme weather undermine the most effective policies to reduce extreme weather impacts. 

The hype and exaggeration matters to New Yorkers because the politicians who passed New York’s Climate Act based their rationale for mitigating greenhouse gas emissions on the misinterpretation of similar extreme weather events driven primarily by natural variability as evidence that climate change is affecting us now.  As a result, the law’s emission reduction targets will squander state resources that would be better spent on making society more resilient to extreme weather rather than using today’s inefficient, expensive and untested renewable energy “solutions”.

Three Hundred Posts

I wanted to mark the occasion of this, my 300th post, with a bit of retrospective since I started posting on this blog on January 11, 2017.

I am a retired electric utility meteorologist with over 40 years-experience analyzing the effects of meteorology on environmental impacts.  Over that time, I have dealt with a wide range of environmental issues and researched many relevant topics to New York’s environmental and energy sectors.  As part of that work, I had to document the results and potential impacts of many topics that I felt were important.  When I retired, I decided to write about some topics that I felt were not receiving much attention and started blogging.

There is a massive industry associated with environmental causes that produce many opportunities for articles critical of the environmentalist narrative.  Coupled with New York State’s Climate Leadership and Community Protection Act (CLCPA) it seems that every day there is something that I want to write about.  In addition, the current state of New York politics precludes meaningful criticisms from industry so I can say things that companies cannot.  Nonetheless I am always careful to note that the opinions expressed in my blog articles do not reflect the position of any of my previous employers or any other company I have been associated with, the comments are mine alone.

The goal in my blog is to describe environmental issues from a pragmatic viewpoint.  Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues.  Unfortunately, public perception is too often driven by scary one-sided stories that have to be rebutted by getting into details.  I have tried to show the complicated “other” side of environmental issues that gets overlooked during policy discussions too often. My background as a scientist and my earlier responsibilities to provide technical comments on new or revised regulations means that I tend to get bogged down in technical details that are, too be kind, pretty wonky.  I have tried to tone down the technical aspects but have not been entirely successful.

Although my posts cover a wide range of topics that interest me there are two primary topics covered.  Most of my articles (109) have addressed the CLCPA implementation process.  I truly believe that this “solution” will be far worse than the impacts of the problem they are trying to address and that does not consider the enormous costs.  I have also written 36 articles on the Regional Greenhouse Gas Initiative (RGGI).  This greenhouse gas control program is frequently described as a success but I have not been able to resist pointing out the flaws in that belief.

The final question I have asked myself is whether my obsession with this blog has been a success and to me success is having people read the blog.  According to the WordPress statistics, the views of the blog have been steadily increasing and there have been over 16,500 visitors.  There is an option for people to like a post and those have been going up.  Comments have been a bit of a disappointment especially because many of the comments are simply approvals of references to previous posts.  There are 53 people who follow the blog too.

Blog Statistics
YearViewsVisitorsLikesComments
20173,1832,162  
20182,8141,56145
20194,5592,4571413
20207,8734,2863752
20219,0796,0563132
Total27,50816,52286102

So where are the people coming from to find the blog.  Very early on Judith Curry included this blog on her blogroll and a large percentage of the visitors visited since then.  Tom Shepstone started reposting my articles at his Natural Gas Now blog starting 12/28/18 and he has spread my message in nearly 100 reposts.  My thanks to both of them for bringing visitors.

I have done some self-promotion as well.  I have also done blog posts for Judith’s site and Watts Up With That and there usually is a flurry of visitors after those posts.  Francis Menton posted blog articles on my articles about the CLCPA implementation process and both were re-printed on Watts Up With That.  The comments on my work in those posts dwarf the responses on the blog itself and I am sure the total views were larger too.  Most gratifying is the occasional contact from people whose work I respect offering advice, encouragement, and praise.  I have also heard that there are industry people who follow the blog.

The blog statistics note the number of people who visit based on internet searches.  Unfortunately, I don’t know what they are searching for.  I suspect it is a source of frustration to the state that when searching for specific CLCPA items my posts generally turn up.  Most popular article by far is one on the proposed rebuilding of Interstate 81 through Syracuse and I would love to know how nearly 3,000 people found it.

In the future, I plan to develop a simple summary of the issues with the CLCPA that I want to publicize as much as possible.  The layman’s version of that document will be backed up by plenty of technical documentation from the blog.  I am also trying to provide references to the work of others who agree with my concerns relative to the “solutions” for the existential climate crisis.

In conclusion this has been a rewarding experience for me.  I devoutly believe that it is important to keep busy during retirement and this blog keeps me busy.  Just when I get discouraged and think about quitting, some insane proposal or article comes up that provides more than enough incentive to keep writing.  My thanks to everyone who has read my work.

Climate Leadership and Community Protection Act Climate Justice Working Group

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.  The CLCPA established a council, advisory panels and three working groups.  This is a background post on the Climate Justice Working Group which consults with the advisory panels that recommended enabling strategies to the Climate Action Council.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation of the CLCPA.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The CLCPA targets are ambitious: relative to a 1990 baseline there is a mandate for a 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050 as well as a requirement for 100% carbon-free electricity by 2040.  There is no requirement for an assessment of technology and cost feasibility. In order to develop the plans to meet these targets the CLCPA set up ten groups to develop the plan to meet the greenhouse gas emission reduction targets of the law: the Climate Action Council, six advisory panels, and three working groups. 

The Climate Action Council  (§ 75-0103) consists of 22 members: 12 agency heads, 2 non-agency expert members appointed by the Governor, 6 members appointed by the majority leaders of the Senate and Assembly, and 2 members appointed by the minority members of the Senate and Assembly.  Given that 14 members are appointed by the Governor and six more members are appointed by the Democratic majority that passed the legislation there isn’t any pretense for unbiased recommendations.   

Climate Action Council Advisory Panels (§ 75-0103,  provide recommendations to the council on specific topics, in its preparation of the scoping plan, and interim updates to the scoping plan, and in fulfilling the council’s ongoing duties.  The law established advisory panels on transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, and agriculture and forestry and another panel on waste was added last fall.  The panels are also supposed to provide input to the state energy planning board’s adoption of a state energy plan which will incorporate the recommendations of the council.  Ostensibly the members of these panels were supposed to be subject matter experts but the reality is that the majority of members did not understand the complexities of the subjects of their panel and were more interested with social justice concerns and their personal advocacy agendas. 

Consider, for example, the makeup of the power generation advisory panel.  Because electrification of everything is a key implementation strategy, it can be argued that this is the most important panel.  The CLCPA states that the “council shall convene advisory panels requiring special expertise”.  It is no simple matter understanding how the New York electric system works and I believe that it requires a hard science education or electric sector experience.  In my opinion, only five of the fourteen Power Generation panel members have the special expertise necessary.  The draft and final enabling initiatives produced by this panel have been described as showing that New York has no idea whatsoever how to “decarbonize” its electric grid.

The Council and the advisory panels were populated mostly by people with overt agendas for greenhouse gas mitigation means that the scoping plan for decarbonizing the NY system will be based more on ideology than reality.  Unfortunately, it gets worse because the CLCPA includes three working groups that make not attempts whatsoever to incorporate alternate considerations.  The Just Transition, Environmental Justice, and Climate Justice Working Groups were all included in the CLCPA to cater to specific political demographics with only peripheral consideration of the alleged goal to address the “existential” threat of climate change.

The first group, Just Transition Working Group (§ 75-0103), was included to appease organized labor because the closure of fossil-fired power plants will have direct effects on union jobs.  This panel is supposed to:

Prepare and publish recommendations to the council on how to address: issues and opportunities related to the energy-intensive and trade-exposed entities; workforce development for trade-exposed entities, disadvantaged communities and underrepresented segments of the population; measures to minimize the carbon leakage risk and minimize anti-competitiveness impacts of any potential carbon policies and energy sector mandates.

They are also charged with preparing a report that includes: the number of jobs created to counter climate change, which shall include but not be limited to the energy sector, building sector, transportation sector, and working lands sector; the projection of the inventory of jobs needed and the skills and training required to meet the demand of jobs to counter climate change; and workforce disruption due to community transitions from a low carbon economy.  Note that there is no explicit requirement to determine the number of jobs lost directly due to the CLCPA or indirectly when businesses have to flee the state because of higher energy costs.

This post addresses the other implementation working group, the Climate Justice Working Group (§ 75-0111).  The advisory panels are required to “coordinate with the climate justice working group”.  The draft scoping plan that outlines how the CLCPA targets will be achieved “shall be developed in consultation with the climate justice working group”.  Not surprisingly the final scoping plan has to also be “developed in consultation with the climate justice advisory group”.  The group is also responsible for defining “disadvantaged communities” and will meet annually thereafter to review the criteria and affected communities.

The final working group established by the CLCPA is a permanent organization.  The Environmental Justice Working Group (§ 75-0101).  During the implementation phase each advisory panel is required to coordinate with the environmental justice advisory group and both the draft and final scoping plan are to be developed in “consultation with the environmental justice advisory group”.

The Climate Justice and Environmental Justice working groups have explicit charges. As noted, they are both supposed to coordinate with the advisory panels during the development of the draft and final scoping plans.  The Department of Environmental Conservation (DEC) may establish an alternative compliance mechanism to be used by sources subject to greenhouse gas emissions limits to achieve net zero emission and are required to “consult with the council, the environmental justice advisory group, and the climate justice working group.   In addition, the Climate Justice working group has specific requirements. 

The CLCPA has an 85% emission reduction target but it also is “net zero”.  The emissions from the remaining 15% are supposed to be offset by §75-0101,10 “Greenhouse gas emission offset projects”.  These projects include: “natural carbon sinks including but not limited to afforestation, reforestation, or wetlands restoration; greening infrastructure; restoration and sustainable management of natural and urban forests or working lands, grasslands, coastal wetlands and sub-tidal habitats; efforts to reduce hydrofluorocarbon refrigerant, sulfur hexafluoride, and other ozone depleting substance releases; anaerobic digesters, where energy produced is directed toward localized use; and carbon capture and sequestration; ecosystem restoration”   The final type of emission offset projects are those recommended by the council in consultation with the climate justice working group that “provide public health and environmental benefits, and do not create burdens in disadvantaged communities”.

In order to engender support for the Climate Act, legislators included §75-0115, community air monitoring program.  This mandate requires DEC to prepare a program demonstrating community air programs in consultation with the climate justice working group.  It is currently fashionable for environmental justice advocates to claim that the current air monitoring network established by the Clean Air Act to protect human health is inadequate.  The “solution” is to do hyper-local air quality monitoring.  I wrote a post on this topic concluding that inadequate monitoring technology and quality control specifications make the results from these systems barely credible.

Nonetheless, the CLCPA includes a second associated mandate that requires DEC, in consultation with the climate justice working group, to develop a strategy to reduce emissions of toxic air contaminants and criteria air pollutants in disadvantaged communities affected by a high cumulative exposure burden.  I believe that the basis for this strategy will rely at least in part on the results from the community air monitoring program.  One of the primary targets of this campaign against sources in disadvantaged communities are peaking power plants and I have written a series of posts on this topic.  As far as I can tell, ozone and inhalable particulate health impacts provide the basis for the claims that these power plants are dis-proportionally affecting environmental justice communities.  The fact that both are secondary pollutants that do not directly affect the neighborhoods around these power plants has been ignored to date.

The point should be made that participation on these panels is a burdensome chore.  Over the past year, participants have had to endure many meetings and working sessions as well as reviewing information in preparation for the meetings.  Many of the participants work for companies that will directly benefit from the transition like renewable energy developers and many more work for non-governmental advocacy organizations whose primary purpose is to foist the clean energy transition on the public in the name of solving the “existential” crisis of climate change.  It is not immediately clear why environmental and social justice advocates would be willing to invest their time in this process.  Cynic that I am I believe that following the money is a primary motivator.

Section § 75-0117, Investment of funds of the CLCPA mandates that:

State agencies, authorities and entities, in consultation with the environmental justice working group and the climate action council, shall, to the extent practicable, invest or direct available and relevant programmatic resources in a manner designed to achieve a goal for disadvantaged communities to receive forty percent of overall benefits of spending on clean energy and energy efficiency programs, projects or investments in the areas of housing, workforce development, pollution reduction, low income energy assistance, energy, transportation and economic development, provided however, that disadvantaged communities shall receive no less than thirty-five percent of the overall benefits of spending on clean energy and energy efficiency programs, projects or investments and provided further that this section shall not alter funds already contracted or committed as of the effective date of this section.

The point has often been made that the 40% goal is the floor and that more is appropriate.  Of course, the primary discussion is just what programs should be funded and the Climate Justice Working Group is positioning itself to be the final arbiter of those decisions. 

Unfortunately, the reality is that the CLCPA is supposed to be a greenhouse gas mitigation program and that funding of any project that does not directly lead to emissions reductions dilutes the cost-effectiveness of the investments.  For example, the investments made with the proceeds of the Regional Greenhouse Gas Initiative have only been responsible for 5% of the observed reductions at a $858 per ton reduced rate because monies have been diverted like this mandate and because clean energy and efficiency programs are not very cost effective.  Coupled with the facts that mitigation efforts are going to be expensive and the CLCPA does not incorporate a funding mechanism, this mandate will make reaching the targets even more difficult.

Climate Justice Working Group

This section describes the specific mandates of the Climate Justice Working Group (§ 75-0111).

The climate justice working group has been created within DEC.  There are representatives from: environmental justice communities, DEC, the Department of Health, the New York State Energy and Research Development Authority, and the Department of Labor.  

Environmental justice community representatives shall be members of communities of color, low-income communities, and communities bearing disproportionate pollution and climate change burdens, or shall be representatives of community-based organizations with experience and a history of advocacy on environmental justice issues, and shall include at least three representatives from New York city communities, three representatives from rural communities, and three representatives from

upstate urban communities.

I think the biggest responsibility of the working group is to develop the criteria that define disadvantaged communities.  The working group is supposed to work with DEC and the departments of health and labor, the New York State Energy and Research Development Authority, and the environmental justice advisory group to “establish criteria to identify disadvantaged communities for the purposes of co-pollutant reductions, greenhouse gas emissions reductions, regulatory impact statements, and the allocation of investments”.

The CLCPA establishes guidelines for the disadvantaged communities criteria.  In general, there are supposed to be identified based on geographic, public health, environmental hazard, and socioeconomic criteria.  Of course, the devil is in the details but those criteria “shall include but are not limited” to:

  • Areas burdened by cumulative environmental pollution and other hazards that can lead to negative public health effects;
  • Areas with concentrations of people that are of low income, high unemployment, high rent burden, low levels of home ownership, low levels of educational attainment, or members of groups that have historically experienced discrimination on the basis of race or ethnicity; and
  • Areas vulnerable to the impacts of climate change such as flooding, storm surges, and urban heat island effects.

Once the draft guidelines are prepared there are requirements for hearings, a public comment period and “meaningful opportunities for public comment for all segments of the population that will be impacted by the criteria, including persons living in areas that may be identified as disadvantaged communities under the proposed criteria”.  Once the criteria have been established the group will meet no less than annually to review the criteria and methods used to identify disadvantaged communities.  They “may modify such methods to incorporate new data and scientific findings”. Finally the climate justice working group shall annually “review identities of disadvantaged communities and modify such identities as needed”.

Membership

I researched the background of the nine at large members and four members from state agencies and summarized that information here.  There is a significant spread of the quality of the at large members.  Several are nationally recognized experts on environmental justice issues.  Others have extensive experience advocating for environmental justice.  Those people all are working at well known organizations.  On the other hand, a few have little environmental justice background and seem to have been chosen to fulfill the geographical requirements.

With regards to the geographical requirements for three each representing New York City, Upstate Urban and Rural communities I don’t think rural disadvantaged communities are represented well.  In the first place two represent the Adirondacks.  That area is a special case with unique constraints for communities within the Adirondack State Park.  No one comes from the communities in Appalachia and I think the needs and interests of those disadvantaged communities should have been represented.

There is another important point.  While the background of many of the members is well suited for the charge to advise the Climate Action Council with respect to climate justice issues for disadvantaged communities, I did not see any member with appropriate technical education or experience to critique the technical enabling strategies of the advisory panels with one exception.  There are some members with planning experience that could provide meaningful comments to the land use and local government advisory panel.  As a result. I don’t think that technical criticisms from this working group on the advisory panel enabling strategy recommendations should carry much weight.

Conclusion

Similar to all the other panels and working groups, the membership of the Climate Justice Working Group is a mixed bag.  Some are clearly experts in their fields.  However, that does not necessarily mean that their opinions on all topics are meaningful.  Moreover, given that advocacy appears to have been a primary criterion for membership the passion for their “cause” should be considered in the context of society as a whole. 

At the time of this writing there isn’t much to draw any conclusions on the value of their recommendations.  They have commented on a couple of advisory panel enabling strategies which I will discuss in an upcoming post but they have not proposed criteria for the definition of disadvantaged communities.  Because at least 35 to 40% of the CLCPA project funding will be targeted to those communities that definition is important.  Cynically, I believe that designs on that funding is a prime driver of the rationale to become a member.

Update on Climate Leadership & Community Protection Act Emissions and the Value of Carbon

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. Earlier this month I documented issues with the benefits calculations methodology that I expect will be used to show that the “benefits” of Greenhouse Gas emission reductions outweigh the costs.  The New York State Department of Environmental Conservation (DEC) recently updated their Value of Carbon guidance and this post describes the changes and, more importantly, the lack of one change I recommended.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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 DEC updates to their Value of Carbon Guidance are available at Value of Carbon Guidance and updated supplemental materials. The most notable change is that DEC settled on a 2 percent discount rate as the central value, but will also report impacts at one and three percent.  All calculated values are updated in the new version as a result of this action. 

In my previous post I noted that the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal.  I believe that the guidance approach is wrong because it applies the social cost multiple times for each year of an emission reduction.  I submitted comments and recommended that the Guidance be revised.  When I reviewed the recent revisions, I noted that the there was no change to the guidance so I sent a follow up email asking whether my concern had been discussed.  My correspondence with DEC on this topic is available here

In brief my concern is that the Guidance section entitled “Estimating the emission reduction benefits of a plan or goal” includes the following example:

The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $123 per metric ton. The value of the reductions in 2021 are equal to $123 times 5,000 metric tons, or $635,000; in 2022 $124 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.

I explained that it is inappropriate to claim the benefits of the annual reduction over any lifetime or to compare it with avoided emissions.  Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $123 or $6,150,000, but the guidance approach estimates a value of $36,410,000 using this methodology. The social cost calculation sums projected benefits for every year subsequent to the year the reductions are made out to the year 2300.  Clearly, using cumulative values for this parameter is incorrect because it cumulatively counts those benefits repeatedly.  I also contacted social cost of carbon expert Dr. Richard Tol about the use of lifetime savings and he stated that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”.  Note that Dr. Tol is using the social cost of carbon nomenclature rather than value of carbon label. 

I received the following response:

We did consider your comments and discussed them with NYSERDA and RFF. We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level. 

When applying the Value of Carbon, we are not looking at the lifetime benefits rather, we are looking at it in the context of the time frame for a proposed policy in comparison to a baseline. Our guidance provides examples of how this could be applied. For example, the first example application is a project that reduces emissions 5,000 metric tons a year over 10 years. In the second year you would multiply the Value of Carbon times 10,000 metric tons because although 5,000 metric tons were reduced the year before, emissions in year 2 are 10,000 metric tons lower compared to the baseline where no policy was implemented. You follow this same methodology for each year of the program and then take the net present value for each year to get the total net present value for the project. If you were to only use the marginal emissions reduction each year, you would be ignoring the difference from the baseline which is what a benefit-cost analysis is supposed to be comparing the policy to. 

The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action. 

Discussion

DEC believes that their comparison of policies under consideration relative to the no-action baseline is appropriate but they ignore the ultimate purpose of the value of carbon.  At the end of the day, it should be used to determine whether the control policies instituted to meet the reduction targets of the CLCPA provide social value by reducing GHG emissions at a control rate ($ per ton) that are less than the projected social costs. Instead, the integration analysis will compare not only the emission reductions per year but also the avoided emissions relative to a no-action baseline over the time frame of the policy. 

 The calculation of avoided emissions is a public relations ploy along the lines of the claim that an emissions reduction policy is equivalent to taking so certain number of cars off the road.  It may be a very nice number but what is it good for?  Consider, for example, the CLCPA target of a 40% reduction in greenhouse gas (GHG) emissions from 1990 levels by 2030.  In order to evaluate compliance with that target the state will calculate emissions in 2030 and compare them to 1990 levels.  Evaluation of the CLCPA targets includes no consideration whatsoever of avoided emissions or cumulative reductions.

More importantly, in the context of the value of carbon, it is absolutely incorrect to use avoided emissions or lifetime reductions.  DEC’s Value of Carbon guidance defines the social cost of carbon as:

An estimate, in dollars, of the present discounted value of the future damage caused by a metric ton increase in emissions into the atmosphere in that year or, equivalently, the benefits of reducing emissions by the same amount in that year. It is intended to provide a comprehensive measure of the net damages—that is, the monetized value of the net impacts—from global climate change that result from an additional ton of emissions.

Glaringly, there is no mention of avoided emissions or cumulative reductions.

Conclusion

If the societal benefits of GHG emission reductions are greater than the control costs for those reductions, then there is value in making the reductions.  If that is not the case then New York should re-think its mitigation targets and policies and concentrate on “no regrets” policies such as adaptation and resiliency investments.  If New York wants to make a contribution to climate change mitigation, then money should be invested in research and development to produce mitigation measures that are cheaper than the social costs.

It is obvious listening to the Climate Action Council meetings that the “plan” is to prove the value of the advisory panel emission reduction recommendations by calculating the social costs and comparing them to the reduction costs.  Obviously, this is “thimble and the pea” time and the CLCPA hucksters will be inflating the benefits at every opportunity and discounting the costs at the same time.  DEC’s response to my comment concluded that “The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action”.  In the first place the concept of a value on carbon is contrivance designed to justify mitigation policies. Secondly the DEC values of carbon proposed exceed the Federal values to further inflate the “benefits” by choosing assumptions that get higher values.  To top it all off, now we know that the CLCPA integration analysis will use the values of carbon incorrectly to further inflate the benefits.

Another theme in the Climate Action Council meetings is constant reference to their allegiance to the “science”.  In this instance the science says apply the value of carbon only to emission reductions and not to avoided emissions or cumulative emission reductions.  That fact is inconvenient so the real “science” is ignored.