New York State Electric School Buses

I have argued repeatedly on this blog that the proponents of New York’s Climate Leadership and Community Protection Act (Climate Act) need to listen to the experts.  Recently Governor Hochul announced that New York would be the first state to set an electric school bus requirement.  This article describes an interview with a bus electrification expert about this plan.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. According to the Plan the transportation sector is responsible for 27% of current greenhouse gas emissions so strategies to electrify the sector are planned.

Zero-Emission School Buses

On April 9, 2022 New York Governor Hochul announced fiscal year 2023 investments in clean energy infrastructure, climate resiliency and preservation that New York will become the first state in the nation to set an electric school bus requirement.  According to the press release:

In order to improve air quality for school-age New Yorkers, the State Budget requires that all new school bus purchases be zero-emissions by 2027 and all school buses on the road be zero-emissions by 2035. The State Budget will provide $500 million through the Environmental Bond Act to support school districts in purchases of zero-emission buses and related charging infrastructure including charging stations. Additionally, the State Budget authorizes school districts to lease or finance zero-emission buses for 12 years, more than double the current five-year limitation for diesel buses, in order to help districts meet this goal, and ensures Transportation Aid is provided on zero-emission buses and related charging infrastructure. 

While doing research for this article I found a series of webinars on electric school buses put together by the Center for Transportation and the Environment (CTE).  They are a “member-supported 501(c)(3) nonprofit organization that develops, promotes, and implements advanced transportation technologies, vehicles, and fuels that reduce environmental pollution and fossil fuel dependency”.  “In partnership with the U.S. Departments of Defense, Energy, Interior, and Transportation, the U.S. Armed Services, and NASA, among many others”, CTE and its 89 member companies work together to improve transportation technologies and fuels while reducing their environmental impacts.  Despite the fact that CTE’s primary interest is foisting their “zero-emission” transportation vision on us all, the webinars (Bus Technology,  Charging Infrastructure, and Program Funding) are a useful overview of the technology needed for zero-emissions school buses.

What Do the Experts Say?

Jeff Sweet is an engineer at the Niagara Frontier Transportation Authority (NFTA).  His last task before retirement is to get the first electric buses and charging infrastructure operational for NFTA.  He has a lot of experience making buses work for their customers and, importantly, working with Metro Rail light rail vehicles in the NFTA.  Over the past couple of years, NFTA has begun the process to add battery-electric buses (BEB) to their fleet.  We recently talked about the challenges of bus electrification using the CTE webinar slides as a guide. 

NFTA took the position that converting the 323 buses currently in operation to battery electric vehicles should not lower the bar.  The BEBs need to achieve diesel bus efficiencies and standards of performance. The more I think about that approach the more I approve.  Why should we have to accept lower performance standards especially given that New York’s GHG emissions are lower than the average annual increase in global emissions over the last 30 years.

The first webinar includes a slide that explains why electric school buses are being considered now:

  • Zero criteria emissions around vulnerable populations
  • Quiet operation
  • Lower Greenhouse Gas emissions
  • Funding availability
  • Lower fuel and maintenance costs
  • Vehicle availability

There are issues with each of these points.  Zero emissions at the point of release ignores the environmental impacts of the materials needed for battery technology.  Most of the time quiet operation is an advantage but it also means pedestrians might not hear them coming.  The difference in GHG emissions when total life cycle emissions are compared is pretty small.  Current funding availability only works when someone, somewhere else is paying the bill.  The last two claims, lower costs and availability, are frequently pointed out by advocates.  Sweet explained that electric buses don’t have transmissions so that reduces maintenance.  However, he noted that the lower day-to-day maintenance costs advantage can disappear when it comes time for battery replacement.  Ultimately, when everything is considered, these advantages are not as big as they appear at first glance.

The bus technology CTE presentation includes a good overview description of electric vehicle batteries.  A couple of good points were made.  In a series of slides the limitations of the nameplate capacity were discussed.  It turns out that buses won’t move unless they have more than 5% charge, below 10% they have derated performance and that charging them over 90% reduces longevity.  In other words, actual battery capacity is down 20% from the get go.  In addition, there are many factors that cause batteries to age that also reduce performance.  Among the factors are age since production; charging rates and number of cycles; discharging rates and number of cycles; high temperatures; cyclic depth of discharge; sitting at high state of charge; and sitting at low state of charge.

Sweet explained that those battery considerations are not the only things that school districts will have to plan for when they switch to electric buses.  The specifications for buses must consider the duty cycle. It is not just range but also the bus route terrain.  If the buses have routes with many hills that will affect battery use.  Specifications must also consider how they will be used: how many stops, location and terrain are factors.  Based on his experience NFTA is planning to use traction motors like the ones used in their trolley buses.

In order for this all to work the school districts must have specifications for the life and usage of their buses to have the batteries meet the duty cycle.  Financing is another practical consideration.  Sweet explained that given their high rate of use when a bus is leased there is no residual value of the bus at the end of the lease.  On the other hand, car leases can have lower rates because the cars have residual value and can be sold at lease end.  Ultimately, he thinks the leases will be a financing scheme for batteries.

The issue of charging is an important consideration for school districts. There are different kinds of chargers and there is a premium cost for faster charging.  There also different types of charging connections.  Cables are cheaper but pantograph chargers are more flexible.  In addition, the power requirements must be considered.  We agreed that most school district bus garages would need to upgrade their electric service to a higher capacity.  For a large district getting sufficient power could mean upgrades not only to the service to the bus garage but the serving utility might also have to make changes to the electric distribution system. 

New York State School Buses

My primary concern is how school bus electrification will affect New York’s Climate Act implementation.  In the second CTE set of slides there is a presentation titled “White Plains Electric School Bus Vehicle to Grid (V2G) Project” that describes a pilot study with Consolidated Edison.  The utility’s main concern is charging equipment.  The presentation notes that it needs to meet bus needs, funding constraints, and “charge management platform compatibility”.  It goes on to explain that school buses will use a mix of AC and DC charging:

  • AC, Level 2 (most, but not all school buses) Slower charging, up to 22kW, cheaper, smaller
  • DC, Level 3 (becoming more common) Fast charging, 50-60kW typ., expensive, big, better vehicle to grid

My ultimate concern is how much money will be needed and how much is available.  The presentation states that in New York State the plan is to cover up to $120K of the cost of a Type C school bus.  A commentary advocating for more funding claims that there are 45,000 school buses in New York and that the Senate budget plan proposes $1 billion for school and transit bus electrification.  The following table combines that information with the costs for school buses and the costs for charging infrastructure to estimate how much money will be needed.  Depending on the types of chargers used there will be a funding shortfall of between $3 and $5 billion to replace 45,000 diesel school buses.

Conclusion

The costs of electric buses are significantly higher than diesel buses and there is insufficient money available to cover those higher costs.  As a result, the electric bus conversion is an unfunded mandate to New York schools of at least $3 billion.  Furthermore, Sweet’s impression is that the manufacturers and many of the consultants don’t have the practical experience necessary to keep school districts from avoiding potential pitfalls that will further increase costs.  Consequently, it is likely that this is another virtue signaling “great” idea that will end up doing more harm than good.

Climate Act Benefits Greater than Costs Claim

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   In my recent verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading.  This post consolidates documentation that has been presented in multiple earlier posts that supports my statement that the costs far exceed the benefits.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to climate change because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   Bottom line for me is that in its present form the Climate Act will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050.  The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Benefits Exceed the Costs Claim

The Draft Scoping Plan claim that “The cost of inaction exceeds the cost of action by more than $90 billion” is presented in Figure 51 in Appendix G Integration Analysis Technical Supplement. The Climate Act overview presentation for the public hearings included a similar figure and made the claim.  However, there is a caveat or in this case, a trick.  In the following figure I have highlighted the description that notes that the benefits are “relative to Reference Case”.  By the way, that caveat is usually not noted when these results are presented.

Reference Case Costs

The important point is that the costs shown subtract the reference case costs from the costs attributed to the Climate Act.  As a result, the control measures included in the Reference Case make all the difference in the claim.  I did not pick up on this nuance for several months.  When I did notice the qualifying statement, I started looking for Reference Case documentation in the Draft Scoping Plan.  Ultimately, I ended up searching the document for the phrase “reference case.  The following figure reproduces the page with the documentation on page 12 in Appendix G Integration Analysis Technical Supplement Section I. The documentation is buried in the footnote for the circled reference for the blank caption to Figure 4.  Given its importance to this critical claim I can’t help but wonder why this important definition is buried.

The footnote text describes what is in the Reference Case.  It includes a “business as usual” forecast plus implemented policies.  The implemented policies include but are not limited to:

  • Federal appliance standards
  • Energy efficiency achieved by funded programs (Housing and Community Renewal, New York Power Authority, Department of Public Service, Long Island Power Authority, NYSERDA Clean Energy Fund)
  • Funded building electrification
  • National Corporate Average Fuel Economy standards
  • Statewide Zero-emission vehicle mandate
  • Statewide Clean Energy Standard including technology carveouts

The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.   In order to fulfill this obligation, I think the Draft Scoping Plan should describe all control measures, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  While there is a large amount of information provided, this information is not available as far as I can tell.  Particularly concerning is the complete lack of detailed cost information. 

The total system expenditures are shown in Figure 48.  The text notes that the reference case total is $2.7 trillion but that is the only quantified reference.  I estimate that the mitigation scenarios are around $3 trillion making the costs relative to the reference case around $300 billion for the three mitigation scenarios. Also note that the values of the expenditure categories on the right are not listed so readers can only guess the values based on the size of the bars.

Figure 47 lists costs relative to Reference Case for the three mitigation scenarios.  In other words, the numbers presented subtract out the Reference Case costs. The trick used to claim that the benefits are greater than the costs is to argue that significant costs that are needed to meet Climate Act targets are in programs that are already implemented.  For example, consider transportation investments that I estimate total around $700 billion.  There are two already implemented transportation investment programs in the Reference Case: national corporate average fuel economy standards and statewide zero-emission vehicle mandate.  I accept that Federal fuel economy standards don’t represent a cost for the Climate Act.  New York passed legislation setting a goal for all new passenger cars and trucks sold in New York State to be zero-emissions by 2035 in April 2021 so this is technically an already implemented program. 

However, suggesting that the zero-emissions vehicle “implemented policy” should not be included in the Climate Act implementation costs is disingenuous at best. The press release announcing that the Governor signed the legislation states: “The actions announced today in advance of Climate Week 2021 support New York’s ambitious goal of reducing greenhouse gas emissions by 85 percent by 2050, as outlined in the Climate Leadership and Community Protection Act.”  It goes on to quote Governor Hochul: “New York is implementing the nation’s most aggressive plan to reduce the greenhouse gas emissions affecting our climate and to reach our ambitious goals, we must reduce emissions from the transportation sector, currently the largest source of the state’s climate pollution”.  I think that these statements pretty well represent any dispassionate observer’s belief that the only reason for this is mandate is to support the Climate Act.  As such those costs are not legitimate Reference Case costs.

If the Draft Scoping Plan provided the costs for each of the control measures as I believe is appropriate, then it would be a simple matter to determine what the costs for Transportation Investments should be.  Instead, I had to eyeball guess the size of the transportation investment bar in Figure 48 to be around $700 billion.  While that total includes the costs for the Federal fuel economy standard, that has to be much smaller than all the costs associated with going to zero-emissions vehicles.  There are about 10 million vehicles in the state so assuming that the Federal fuel economy standard will cost $7,000 per vehicle that means that the total cost is $70 billion and that zero-emissions vehicles cost $630 billion. As a result, the direct costs increase by $630 billion.

Avoided Cost of Carbon Benefits

In Figure 51 the costs are compared to benefits. As shown in Figure 46, the largest benefit comes from avoided GHG benefits.  I believe there is an error in that calculation.  Scoping Plan relies on flawed DEC Value of Avoided Carbon Guidance.  The Guidance includes a recommendation 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 ton reduced.  I maintain 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 the Scoping Plan carbon valuation sums projects benefits for every year for some unspecified lifetime subsequent to the year the reductions.  As shown above, the value of carbon for an emission reduction is based on all the damages that occur from the year that ton of carbon is reduced out to 2300.  Clearly, using cumulative values for this parameter is incorrect because it counts those values over and over.  I contacted social cost of carbon expert Dr. Richard Tol about my interpretation of the use of lifetime savings and he confirmed that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”. 

Corrections to Figure 51 Net Present Value of Benefits and Costs

The following table corrects the issues described here.  If we fix the misleading trick then the Draft Scoping Plan net system costs are increased by $630 billion.  Correcting the multiple counting error drops the avoided GHG benefits estimate to $60 billion.  The result is that the costs exceed the benefits by at least $690 billion.

There’s More

There is another issue associated with the claim that “The cost of inaction exceeds the cost of action by more than $90 billion”.   As shown, there is a caveat that the comparison is relative to the Reference Case.  I showed how the semantic justification that the transportation investments were already implemented excluded the costs of the zero-emissions vehicle mandate from the costs side of the comparison.  In order to further tilt the results, the benefits attributed to the transportation investments were not excluded in the comparison.   In other words, the comparison takes out the costs that would hurt their case but leaves in benefits that help make the case that the benefits are greater than the costs.

Conclusion

In my opinion the Climate Act story that the benefits out-weigh the costs is incorrect.  I have shown how the trick to deceive the public works.  If the Draft Scoping Plan described all the control measures, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios, then the public would be able to decide for themselves which costs associated with “already implemented” program are appropriate.  The lack of documentation prevents that.

More detailed documentation information is available here and here.

Climate Act Implementing Legislation

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. A couple of pieces of legislation are being considered to implement parts of the transition plan. This post summarizes the Advanced Building Codes, Appliance and Equipment Efficiency Standards Act (Advanced Code Act) and the Gas Transition and Affordable Energy Act (Gas Ban).

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Two bills address the building sector components that need to be changed for the net-zero transition. According to the Advanced Code Act: “Buildings are the single largest user of energy in the State of New York, accounting for almost 60% of all energy consumed by end-use in the State.” Revisions to building codes will be “directly impacting a building’s energy load and carbon footprint”. The Gas Ban notes that the Climate Act “requires greenhouse gas emission reductions from all sectors, which will entail, among other things, converting buildings throughout the state from heating and cooking with combustible fuels to heating and cooking with non-emitting sources such as energy-efficient air, ground, and water sourced electric heat pumps which also provide cooling, and electric and induction stoves”.

Cart Before the Horse

The authors of the Climate Act and most of the Climate Action Council believe that the transition to net-zero is simply a matter of political will.  The Act did not explicitly mandate a feasibility analysis and the Council has not mentioned anything in its deliberations.  However, I believe that the Climate Action emission reduction targets are contingent upon meeting Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4):  “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

Both of these bills suffer from the same under-estimation of the challenges of a net-zero transition.  Until the New York has proven that the Scoping Plan will not impede the conditions described above, I think it is premature to change building codes and energy efficiency standards or implement a ban on fossil-fuel use.

Advanced Building Codes, Appliance and Equipment Efficiency Standards Act

The Senate version (S. 7176) is available here and Assembly version (A. 08143) here. Note that I am not trying to reconcile any differences between the Senate and Assembly versions in this post. The impetus of this legislation is to support the Climate Act and I believe revised building codes are necessary to improve building shells for electrified residential heating.  Section 3.3 Sectoral Results -Buildings in Appendix G, Integration Analysis Technical Supplement Section I is the primary reference for technical information related to the building sector in the Draft Scoping Plan.  It describes the building shell improvements as follows:

Building shell improvements (such as improved insulation, window treatments, or deep home retrofits) are modeled as reducing service demand for HVAC devices. Improvements to buildings incur costs but improve home and office comfort in addition to reducing energy bills. Two bundles of building shell improvements have been included: a basic shell upgrade and a deep shell upgrade. Basic and deep shell upgrades include a variety of measures focused on reducing energy use and increasing occupant comfort; these measures include, for example, varying levels of roof and wall insulation improvements, window treatments such as double or triple paned windows and infiltration improvements. Space heating demands are reduced by 27-44% with the basic shell package and 57-90% with the deep shell package, depending on building type. Air conditioning demands are reduced 14-27% with the basic shell package and 9-57% with the deep shell package. The total impact of building shell improvements on total HVAC service demand in buildings is a function of the market penetration of each package and distribution of building types. Building shell improvements include both retrofits and new construction, although all new construction in residential and commercial is assumed to be code-compliant and therefore has lower HVAC service demands relative to the existing building stock. (Footnote for this sentence said “E3 calculated the stock rollover of building shells with a 20-year lifetime to reflect improvements in new construction and opportunities for home retrofits.”

There is no reference to building shells in the Advanced Code Act.  Amended Section 2 (a) reads:

The state fire prevention and building code council is authorized, from time to time as it deems appropriate and consistent with the purposes of this article, to review and amend the code, or adopt a new code, through rules and regulations provided that the code remains cost effective with respect to building construction in the state. In determining whether the code remains cost effective, the code council shall consider:

(i) whether the life-cycle costs for a building will be recovered through savings in energy costs over the design life of the building under a life-cycle cost analysis performed under methodology as established by the New York State Energy Research and Development Authority in regulations which may be updated from time to time, and

(ii) secondary or societal effects, such as reductions in greenhouse gas emissions, as defined in regulations. Before publication of a notice of proposed rule making establishing the methodology or defining secondary or societal effects, the president of the authority shall conduct public meetings to provide meaningful opportunities for public comment from all segments of the population that would be impacted by the regulations, including persons living in disadvantaged communities as identified by the climate justice working group established under section 75-0111 of the environmental conservation law.

For residential buildings, the code shall meet or exceed the then most recently published International Energy Conservation Code, or achieve equivalent or greater energy savings; and for commercial buildings, the code shall meet or exceed the then most recently published ASHRAE 90.1, or achieve equivalent or greater energy savings.

The biggest question I have is whether the revised codes are consistent with the Draft Scoping Plan building shell requirements.  If so, what level?  For a single-family residence the Draft Scoping Plan estimates that a basic shell upgrade will cost $6,409 but a deep shell upgrade is expected to cost $45,136.  As you can see this makes a huge difference in the costs.

A few other points.  Note that cost effectiveness test includes “secondary or societal effects, such as reductions in greenhouse gas emissions, as defined in regulations”.  New York mistakenly multiplies its social cost of carbon rates by the avoided carbon emissions for every year over the lifetime of a project.  The social cost of carbon metric estimates the value of a ton of carbon reduced on societal benefits of reduced sea-level rise, reduced diseases, etc. impacts of climate change out to 2300.  Clearly counting this for every year of the lifetime of a project over estimates the benefits. 

One concern of mine is that there are many old buildings that cannot be upgraded to modern building shell standards.  The bill does acknowledge that this is an issue.  However, the exemption is limited to historic buildings related to the national register. That is an issue because there are many old houses that cannot be upgraded easily and cheaply that are not “historic”. In addition, some homeowners don’t want to register their homes because of restrictions on what they can do with their homes.

Gas Transition and Affordable Energy Act

The Assembly version (A 9329) is available here.  In brief, this bill: “Aligns utility regulation with state climate justice and emission reduction targets; repeals provisions relating to continuation of gas service; repeals provisions relating to the sale of indigenous natural gas for generation of electricity.”  A primary focus of the Draft Scoping Plan is to transition off of natural gas.  It has become such a hot button issue on the Climate Action Council that the semantics of labeling natural gas as fossil gas has been a topic of heated debate.

The first goal of the bill is to align utility regulation with state climate justice and emission reduction targets.  The climate justice target requires the state to “invest or direct resources in a manner designed to ensure that disadvantaged communities to receive at least 35 percent, with the goal of 40 percent, of overall benefits of spending on: clean energy and energy efficiency programs and projects or investments in the areas of housing, workforce development, pollution reduction, low-income energy assistance, energy, transportation, and economic development.”  The emission reduction targets require New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and no less than 85 percent by 2050 from 1990 levels.

The bill states:

After such plan is established, the commission or other relevant governing authority shall take any such action, after notice and a hearing, as is necessary to facilitate the achievement of the climate justice and  emission  reduction  targets in article seventy-five of the environmental conservation law, but in doing so it shall actively encourage a transition away from combustible fuels and ensure that all residential customers have access to electric heating and cooling services without unreasonable qualifications, unreasonable costs, or lengthy delays with a goal that low-to-moderate income customers, defined as households with annual incomes at or below eighty percent of the area median income of the county or metro area where they reside,  are  adequately  protected  from bearing energy burdens greater than six percent of their income, including any undue burdens imposed by the cost to purchase and operate electric equipment needed to facilitate the termination of gas service.

It seems obvious to me that the bill should be written such that the first step is an analysis to determine if this is feasible.  If it is not then implementation will only exacerbate the energy burden problem.  It is disappointing to me that the environmental justice community has not addressed this aspect of the situation.  As much as they all want to do something about climate change the fact is that ill-considered legislation and regulation can cause more harm than good.

The bill also repeals provisions relating to continuation of gas service.  In order to make the net-zero transition someday, somewhere the State is going to have to force people off their gas appliances.  The details how this will be accomplished are not made clear.

Finally, the bill repeals provisions relating to the sale of indigenous natural gas for generation of electricity.  There are special provisions in current law that relate to an electric generating facility that has its own supply of natural gas.  New York’s irrational war on natural gas precludes the use of the massive shale gas deposits underneath much of the state so this is a moot point.

The bill acknowledges that affordability is an issue.  It states that:

Over two and a half million households in New York struggle to pay their heating bills. The Public Service Commission has declared, but not yet achieved the goal that customers should not pay more than 6% of their income for utility energy services, a number based on a nationally accepted standard. 

Unfortunately, the bill sponsors do not state where the state stands relative to the standard and how the bill could affect it.  Great Britain has similar net-zero transitions but is further along implementing the programs necessary to meet the goals.  According to a recent article, “Britain’s cost-of-living squeeze is starting to bite into the spending power of most parts of the country, with 43% of those who pay energy bills saying they will struggle with the costs”.  The article explains that “The findings underscore the scale of the hit to consumers from a jump in electricity and natural gas prices that has pushed up inflation across the economy to a 30-year high.”   It is not clear how New York can avoid the same outcome.

The biggest question is how much will this cost?  There are 5,889,200 residences that currently use natural gas.  Conversion to heat pumps will not save them money so they will never save enough money to pay off the heat pump conversion costs.    

Finally, there is no acknowledgement that an all-electric energy system is not resilient.   The Council has been silent on a plan for the inevitable ice storm or heavy snow event.  It is bad enough that the fragile transmission system creates health and safety issues when everything possible is electrified.  The Climate Act goes even further.  The current electric generating system that has taken decades to develop into the reliable and affordable system that exists today.  The Council has not acknowledged that transitioning from a system dependent upon dispatchable generating resources to one dependent upon non-dispatchable wind and solar resources in less than 20 years carries enormous risks to reliability.  In February 2021, the Texas electric grid failed when needed most.  Russell Gold’s article “One year after the deadly blackout, officials have done little to prevent the next one—which could be far worse” does an excellent job describing what happened. He explains that as the frigid air behind the winter storm blanketed the state and the electric gird, operators started dealing with problems:

Nobody yet knew just how widespread the blackouts would become—that they would spread across almost the entire state, leave an unprecedented 11 million Texans freezing in the dark for as long as three days, and result in as many as seven hundred deaths. But neither could the governor, legislators, and regulators who are supposed to oversee the state’s electric grid claim to be surprised. They had been warned repeatedly, by experts and by previous calamities—including a major blackout in 2011—that the grid was uniquely vulnerable to cold weather. 

Conclusion

These bills are sneaking through under the radar of most New Yorkers.  They will be expensive, limit personal choice, and risk health and safety because limiting energy use to one source is not a resilient approach.  I have not been able to find out how New York stands relative to the energy affordability policy goal that customers should not pay more than 6% of their income for utility energy services.  Shouldn’t there be a state-wide goal for the percentage of customers that don’t meet that target and shouldn’t bills that will affect that target include a contingency to not exacerbate that metric?  Given that New York’s emissions in context with the rest of the world are less than one half of one percent of total global emissions and that those emissions are increasing by more than one half of one percent per year, it does not seem appropriate to increase energy poverty in the state for emission reductions that will be displaced in a year.

Another Example of Gamesmanship in the Climate Act Integration Analysis

I still have not figured out how to do guest posts.  Dietmar Detering from Nuclear New York has been digging into the economic assumptions used in the Climate Act Integration Analysis, sent me his latest analysis and asked if I would share widely.  We have collaborated on this post describing his analysis of the Draft Scoping Plan gamesmanship with numbers to “prove” value for the net-zero transition.

Detering is a member of Nuclear New York, independent advocates for reliable carbon-free energy.  His organization strongly supports nuclear power as a necessary component of any zero-emissions transition because it is the only scalable proven zero-emissions technology available.  After growing up on a dairy farm in Germany, Dietmar Detering earned his Ph.D. in political science in 1999 at Münster University. He then moved to New York City and built an online event publishing business (EventMe! Inc.), which he still runs. He has served in volunteer leadership roles with several community organizations while raising two daughters with his wife. Passionate about environmental protection since he was a teenager, Dietmar started focusing on nuclear power advocacy in 2018. Besides his activities in New York, he is also a member of Germany’s Nuklearia group.

Climate Act Background

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050. .  The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Draft Scoping Plan Shortcomings

There are many obvious shortcomings of the CAC scoping plan/NYSERDA integration analysis.  The projections for renewable energy use exaggerated capacity factors for wind and solar, leading to vast underestimates of needed investments, land requirements and environmental impacts.  The future capacity projections also rely imported electricity from both clean sources and dirty sources.  It appears the projections are biased to underestimate the needed investments in solar, wind, battery, and hydrogen infrastructure.

Despite its proven capabilities there is no commitment to expand the use of nuclear energy.  In fact, there have been comments from working groups that argue that the existing power plants should be shut down sooner rather than later.

Detering and I share the concern that the Draft Scoping Plan does not recognize some practical implementation issues.  There is no appreciation of rural resistance to wind and solar build-out at the scale needed.  As word gets around about the massive buildout needed there will be more and more resistance.  Affordability is a major concern and the Draft Scoping Plan overestimate how much New Yorkers will be willing to pay for higher energy prices for the benefit of future generations in other countries.

The largest benefit claimed is associated with societal benefits of avoid carbon emissions.  I have shown that the Draft Scoping Plan manipulates emissions inconsistent with all other jurisdictions to increase benefits and incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times.  Detering notes that the Integration Analysis uses a discount rate 3.6% per year for all of its economic projections. However, for social costs of carbon, it is using NY’s official $125/ton which is based on a 2% discount factor. Apples and oranges!

Gross State Product (GSP) Degrowth

The main point of this post is that Detering has uncovered a truly bizarre aspect of the NYSERDA Integration Analysis economic modeling. One of the key drivers of future energy use is how the GSP will change over time in the future.  The Key Drivers Outputs spreadsheet lists future annual GSP in the GSP table.   He confirmed that the spreadsheet explicitly uses 2020 dollars, for past and future years. 

Detering prepared a spreadsheet that incorporates the GSP data from the Key Drivers Outputs spreadsheet.  The spreadsheet shows an average 1.9% per capita GSP growth in the years back, but .84% for the future.  On the other hand, the text in Appendix G says that the Integration Analysis assumes a 1.9% growth of GSP (not per capita) and a .2% growth of population. It is not clear whether they are using nominal GSP numbers, which would explain the mismatch with the table, which uses 2020 dollars.  The point is that 1.9% GSP growth is a good number for real dollars (inflation-adjusted) but not nominal ones. The table shows that their growth assumption (in 2020 dollars) per capita practically drops by half (-55%).

He has checked this math and is confident about the assumed 55% drop in per capita GSP growth. The possible conclusions are all bad:

  • NYSERDA’s Integration Analysis needs a low growth because GSP is linked to energy usage. Over 30 years, .84% translates to a 29% growth, but 1.9% means a 76% growth. Big difference – much less wind and solar to plan for, again!
  • NYSERDA’s Integration Analysis assumes with a program like this, there is no way New York can pull off much more growth in incomes and wealth. High energy costs will drive jobs away and New Yorkers will be poorer as a result. Naturally, growth assumptions need to be reduced.
  • It appears that NYSERDA’s Integration Analysis is yielding to degrowth ideas.
  • This is a game of low expectations.  It allows the state to say 30 years from now: Look, the Climate Act wasn’t so bad for the state after all. We assumed annual per capita GSP growth of only .84% and we’ve gotten over .9% on average!

Conclusion

Jim Shultz recently described the text of the Draft Scoping Plan: “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”. Dietmar Detering and I have found that the Integration Analysis documentation spreadsheets are worse.  There are reams of numbers hiding the fact that the numbers really needed to explain the cost implications of the plan are not included.  There are only a handful of people who have dug into the complexities of the Draft Scoping Plan enough to understand the deceitful actions being taken to “prove” that the Climate Act transition will have benefits that out-weigh the costs. 

Detering’s analysis documents another game with the numbers in NYSERDA’s Integration Analysis.  In order to “prove” benefits out-weigh costs for the future net-zero energy system, there have been multiple games played to lower costs.  In this example, future load is reduced by using a lower growth rate for the economy.  This lowers the cost of the necessary wind and solar resources needed.

Draft Scoping Plan Verbal Comments 26 April 2022

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  This post documents the verbal comments I submitted at the Syracuse Draft Scoping Plan Public Hearing on April 26.  Public comments are limited to two minutes so I could only make points without providing any context.  The verbal comments reference written comments submitted on April 22. 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to climate change because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.  In addition to written comments the Council accepts verbal comments at a series of ten public hearing.  This post documents the verbal comments I submitted on April 26, 2022 in Syracuse.

Verbal Comments

The written comments submitted on April 22 that was the basis of the verbal comments listed the presentation comments and provided detailed documentation for the statements.  If this blog post spurs your interest, then I encourage you to check out the written comments. I spent a lot of time on that report.  The text includes internal links to the relevant documentation so that you can check details for the verbal comments more easily.

In the introduction I referenced my written comments so that I could dispense with any background information.  I have always worried that most New Yorkers have no clue what is included in the Draft Scoping Plan and given the lack of documentation I doubt that most Council members fully understand the implications either.

I am going to summarize the written comments I submitted on April 22 to the Council.  I don’t think the Council, much less the public, appreciates the Draft Scoping Plan’s claimed benefits, costs, threats to reliability, or effect of the proposed reductions on global climate change.

At this time there are over 190 articles about the Climate Act on this blog.  Consequently, the verbal and written comments cover material already presented here.  The discussion of the benefits was mostly based on a post in January.

The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   That statement is inaccurate and misleading. The plan claims $235 billion societal benefits for avoided greenhouse gas emissions.  I estimate those benefits should only be $60 billion.  The Scoping Plan gets the higher benefit by counting benefits multiple times.  If I lost 10 pounds five years ago, I cannot say I lost 50 pounds but that is what the plan says.

One point in favor of checking the written comments is that some aspects of points made in the blog posts have been refined since the original post.  A month ago I caught on to cost calculation trick that includes massive implementation costs in the Reference Case and then presents the costs benefits relative to the Reference Case.  As shown in the written comments, the Draft Scoping Plan not only excludes costs but at the same time includes benefits for those control measures.

The cost estimates are poorly documented but I have determined that they misleadingly exclude the costs in the transportation investments category needed to make the necessary reductions. The semantic justification is that the program is already implemented.  Adding $700 billion for that and using the correct avoided cost of carbon means that costs are at least $760 billion more than the benefits.

Due to the time constraint, I could not do anything but mention reliability concerns.  I intend to submit a written comment that concentrates on reliability issues but in the meantime I did include an extensive description of reliability concerns in the written comments based in large part on this post.

Reliability will be risky. When buildings are 100% electric and transportation rely on electric vehicles, what happens when there is an ice storm?  There are many similar “what if” scenarios not considered.

The supposed rationale for the Climate Act is to do something about climate change.  The reality is that if New York’s emissions and economy are considered in context relative to the other countries this is an exercise in futility.

New York emissions are less than one half of one percent of total global emissions.  Global emissions have been increasing on average by more than one half of one percent per year.

In the conclusion I brought up the concept that it seems pretty obvious that the schedule should be based on technological feasibility.  Last November I wrote that the first principle of electric energy planning should be to not endanger reliability and if there are warning signs the plans should be re-examined.

Anything we do will be displaced in a year, cost a lot of money and risk catastrophic blackouts.  The plan must be revised to one based on technically achievable incremental steps that maintain current standards of affordability and reliability.

Conclusion

Unfortunately, I believe that the Climate Action Council is simply going through the motions of the public comment process.  The Albany mindset is so fixated on the nobility of their quest that I am not sure what kind of reality slap would be needed to knock some sense into the process.  As it stands now the Climate Act will do far more harm than good.  I would like to think that when my public comment directly contradicts the overview presented at the public hearings (the costs are far higher than the benefits), that some members of the Council would take a look at my written comments to see why I am saying that.  I have my doubts.

My written comments concluded that the Climate Action Council should focus its efforts on developing acceptability criteria for the implementation schedule instead of discussing specific components of the plan related to the personal interests and agendas of its members.  In order to address reliability, the Council has to start listening to the organizations responsible for New York grid reliability.  Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. That is exactly what the Climate Action Council will be doing if they do not listen to the experts. 

Is New York State Coming After Our Furnaces?

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. I recently read a Niagara Gazette commentary by Jim Shultz titled: Is New York state coming after our furnaces?.  While I agreed with much of what he wrote I did send him an email explaining my concerns with certain aspects of his commentary.  I reproduce it below and include my comments after it.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to climate change because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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.

Is New York state coming after our furnaces?

I received a post card the other day from state senator Robert Ortt warning me, in the midst of a cold winter, that I might be made even colder in years to come under a new state action plan on climate change. The card warned that starting in 2030 we would no longer be able to get new gas furnaces, stoves, or clothes dryers, and that gasoline-powered cars would no longer be for sale in New York starting in 2035. The senator wrote, “Well intended as it might be, this Plan could mean even higher energy and consumer costs for you.”

The plan Mr. Ortt is referring to comes with a classically bureaucratic name: The New York State Climate Action Council Draft Scoping Plan. I skimmed through its pages over the weekend, all 331 of them. The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it. Here’s an example: “Regardless, any transition must be carefully planned, detailed, and clearly communicated to ensure that expectations are aligned across stakeholders.”

What does that even mean?

Most of those 331 pages are dedicated to telling us why the state needs to move swiftly away from the fossil fuels that cause climate change, a premise that I agree with. Far fewer pages actually say what specific actions the plan would recommend to state lawmakers. You couldn’t make it less accessible to average citizens if you tried. Finding the specific policies that Ortt is referring to was no easy task.

On gas furnaces, the report says (on page 129): “2030: Adopt zero emission standards that prohibit gas/oil replacements (at end of useful life) of heating and cooling and hot water equipment for single-family homes and low-rise residential buildings with up to 49 housing units.”

What does this mean (and not mean) in concrete terms?

It does not mean that in January 2030 you will no longer be able to use a gas furnace in your home or that you will be required to buy a new electric one when the gas unit you have works just fine. What it does mean is that after 2030, when your gas furnace does need to be replaced (this could be in 2040 or later if your furnace is relatively new), you will need to make the transition to an electric one. The plan includes financial incentives to help pay for the change.

State environmental planners warn that because gas is a major contributor to climate change it is going to get phased out eventually. It is a waste, they say, for New York to keep sinking more money into the gas infrastructure that would be needed to keep servicing gas appliances 20 or 30 years down the road. It would be like investing in Blockbuster Video after the entire world migrated to Netflix. Ortt got the phase-out target date for new gas clothes dryers and stoves wrong by five years. It’s actually 2035.

On the matter of gasoline automobile sales, the plan takes a very deep dive into bureaucratic gobbledygook to get to the answer to that (on page 103). The New York plan is essentially: Adopt California’s new plan to transition to zero emission cars. But when you look at the actual California plan that New York would copy, it does not say: It will be illegal to buy a gasoline-automobile from 2035 onward. What it says is: “It shall be a goal of the State that 100 percent of in-state sales of new passenger cars and trucks will be zero-emission by 2035.”

To be clear, a goal and a prohibition on the sale of gasoline cars are not the same thing. I might have a goal to lose five pounds by summer, but if I come up short that doesn’t mean I stop eating. We ought to have ambitious goals that would let us drive to our jobs without making climate change an even worse crisis for our children to deal with. But the transition is big and it is complicated, so the path has to be practical as well.

If you are part of that small minority in the United States that doesn’t believe climate change is real (or don’t care about it because you expect to be dead by the time things get really bad) then none of this make any sense. But if you do believe in the science of climate change and do worry about the future we are handing our children, then making the transition away from fossil fuels is really important, but also not a simple thing.

It’s easy to toss out one-line warnings on a post card and make people feel like state bureaucrats are coming for our furnaces. It is harder to bring forward the facts in a more complete way, free of all the bureaucratic jargon. What we need to do, as citizens, is look closer at what is actually being proposed, call out what doesn’t make sense for our communities, and offer up smarter alternatives. This is the homework of democracy.

If Senator Ortt is sincere in his desire to help us make our voices heard, a more effective thing to do would be to bring some of the state officials who helped put the plan together here to Lockport, to present that plan to the community — in plain language. These issues are important. They should not be buried under indecipherable gibberish or just turned into political fodder. What we need from our state leaders is real information, and an informed and thoughtful discussion about the way forward.

Jim Shultz is the founder and executive director of the Democracy Center and a father and grandfather in Lockport. He can be emailed at jimshultzthewriter@gmail.com.

My Response

I am writing in response to your commentary in the Niagara Gazette titled “Is New York State coming after our furnaces?”.   I wanted to point out that I agree with Ortt’s conclusion: “Well intended as it might be, this Plan could mean even higher energy and consumer costs for you.”

I have been studying the Climate Leadership and Community Protection Act (Climate Act) since April 2019 and written over 185 posts on topics related to the Act and implementation of the Act at my blog Pragmatic Environmentalist of New York.  I believe that it is very likely that implementation of the technology necessary to meet the targets of the Act will adversely affect energy sector affordability and risk current reliability standards.  Unfortunately, most New Yorkers are unaware of it and only a handful understand the implications.  Many of the articles I have published are overly technical for the general public.  In order to address the need for a concise resource of the potential impacts of the Climate Act for laypeople I have developed the Citizens Guide to the Climate Act.

Given that you only skimmed the Draft Scoping Plan you did a good job summarizing the furnaces and vehicle mandates.  However, your comment that “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it” massively underestimates the degree to which the Scoping Plan hides some critical information. My concern is that the problem and the solution have both been over-simplified.  Every issue I have looked at it gets more complicated as you dig into it.  I prepared an overview of the Scoping Plan as it relates to affordability and reliability that addresses some of the nuances that are not immediately obvious relative to the points you made.

I agree with your characterization that “after 2030, when your gas furnace does need to be replaced (this could be in 2040 or later if your furnace is relatively new), you will need to make the transition to an electric one”.  However, the heating transition to electric will include an upgrade to building codes for building shells.  There is a table showing heating retrofit costs in the overview post that shows that adds costs of between $6,409 and $45,136.  I believe that when you try to sell your home it has to be up to code so wouldn’t you be required to retrofit your furnace and upgrade the shell before you can sell?

The Scoping Plan does not even attempt to claim that the electrification retrofit will save money.  All the benefits listed are societal benefits that cannot be used to offset consumer costs.  You explain that you worry about the impacts of climate change.  The avoided GHG emission impacts on climate change societal benefit attempts to quantify the impacts of our emissions on climate change.  The overview post shows that the Scoping Plan cheats to maximize that benefit by counting benefits multiple times.  When that error is corrected the costs are greater than the benefits.  It does not make sense to me to implement these measures if they aren’t cost-effective.  It makes more sense to invest in R&D to come up with cheaper, more reliable zero-emissions alternative technology.  Until that technology is available it is unlikely that the developing countries will forgo the advantages of electrification.

With respect to automobile electrification, don’t forget the hidden costs to set up the infrastructure for charging.  It is bad enough to install something at home but who is going to pay for the chargers for those who park on the street or in parking lots. 

While I understand that you want to do something about climate change, the only conclusion that I can draw from my evaluation of the Climate Act is that it will cause more harm than good.  Please take a look at my Citizens Guide and let me know if you have any questions.

Response from Shultz

Thank you for your detailed note.  The point of my brief article was that these issues, as you note, are complex, and I think citizens are poorly served by quick politician proclamations on the one hand and hundreds of pages of bureaucratic babble on the other.  I will pass along your note and links to others who are looking at this more deeply than I am.  I would certainly encourage you to be in touch with reporters covering the issue in Albany.

New Climate Act Related Pragmatic Principle

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. I recently used my pragmatic environmentalist principles to show that there are very few aspects of the Climate Act that represent a pragmatic approach to climate change mitigation. I recently read an article about green hydrogen that described it as a process that is technically feasible, but highly undesirable.  I am going to add the description of that type of process to my list of pragmatic principles.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  Unfortunately,  I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.

My primary concern is that the Climate Act over-simplifies the problem and the solution.  There are serious challenges for the transition to a zero-carbon grid that have not been adequately addressed by the Draft Scoping Plan.  In my opinion the biggest issue is intermittency of wind and solar.  In order to address those times when the wind is not blowing at night, for example, energy storage is required.  The ultimate problem is that there are multi-day renewable resource drought periods when the wind resource is low and, especially in the winter, solar resources also can be reduced.  It is especially concerning because those periods can coincide with the highest expected future loads after homes and cars are electrified.  In order to help meet these requirements a generating type called Dispatchable Emission-Free Resource (DEFR) has been identified.  The Draft Scoping Plan proposes the use of “green hydrogen”, that is to say produced by wind and solar hydrolysis,  as a placeholder for this technology.

Green Hydrogen Swindle

A recent article in the Telegraph by Andrew Orlowski describes the United Kingdom’s hydrogen initiatives and the issues surrounding the use of hydrogen as has been proposed there.  The introduction described a principle that I hadn’t heard before, “Kicking a dead whale down the beach”:

Engineers will rarely tell you something is impossible, even when your proposal is a very bad idea. Computer scientists at Stanford and MIT in the 1970s came up with a wonderful expression for this, an assignment that was technically feasible, but highly undesirable. They called it “kicking a dead whale down a beach”. The folklore compendium The Hacker’s Dictionary defines this as a “slow, difficult, and disgusting process”. Yes, you can do it like that. But you really don’t want to.

The article continues on to describe two big problems with hydrogen that turn any project into a dead whale exercise.

The first is that pure hydrogen doesn’t exist – it’s both everywhere and nowhere. We must generate all the hydrogen we can then use, and this requires a lot of energy. This is fine when the output of the process is something very valuable to us, such as fertiliser. But less so when the output of the process must compete with much cheaper commodities, as it must in an energy market.

Secondly, hydrogen’s intrinsic physical properties create a whole range of unique problems. It’s a tiny atom that easily escapes confinement. Keeping it captive for storage is expensive, and moving it around safely even more so, because in liquid form it must be very cold.

Hydrogen advocates tend to shrug off these issues – solving them will be someone else’s problem, they reckon. Individually, none of these factors make hydrogen as an energy carrier or storer impossible, but the whale-like properties are becoming harder to ignore.

The rest of the article is a highly recommended summary of the many issues that make a hydrogen economy technically feasible but highly undesirable.

Conclusion

All of the issues that are being raised in the United Kingdom related to the hydrogen economy envisioned there will inevitably also come up in New York as the Climate Act transition unfolds.  Orlowski describes our fate well:

In its efforts to show the world how keenly it is embracing CO2 emission targets, our Government has left a lot of dead whales on the beach for us, and as consumers, we’ll be the ones doing the kicking.

The “dead whale on the beach” principle is a great example of pragmatic environmentalism.  Just because a so-called solution is technically feasible it may not be desirable for a whole host of reasons.

Pragmatic Principle 13 Kicking a dead whale on the beach

An article in the Telegraph by Andrew Orlowski describes the United Kingdom’s hydrogen initiatives and the issues surrounding the use of hydrogen as has been proposed there.  The introduction described a principle that I hadn’t heard before, “Kicking a dead whale down the beach”:

Engineers will rarely tell you something is impossible, even when your proposal is a very bad idea. Computer scientists at Stanford and MIT in the 1970s came up with a wonderful expression for this, an assignment that was technically feasible, but highly undesirable. They called it “kicking a dead whale down a beach”. The folklore compendium The Hacker’s Dictionary defines this as a “slow, difficult, and disgusting process”. Yes, you can do it like that. But you really don’t want to.

Pragmatic approaches are all about assessing tradeoffs.  There are risks to environmental “solutions” that must be considered for sound policy.  Some solutions sound appealing at first but when everything is considered turn out to be not such a great idea. 

This principle is one in a set of principles that I believe exemplifies pragmatic environmentalism which I suggest is the necessary balance of environmental impacts and public policy.  This means that evidence-based environmental risks and benefits (both environmental and otherwise) of issues need to be considered.  Unfortunately, public perception is too often driven by scary one-sided stories that have to be rebutted by getting into details. 

Climate Act Draft Scoping Plan Scenario Components

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The comment period for the Draft Scoping Plan is open until June 10, 2022.  The Council requested feedback on the components of three mitigation scenarios.  This is an overview summary of the components.  I plan to describe the components by sector in more detail in future posts.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.

Integration Analysis Reference Case and Scenario 1

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates.  The primary reference for the scenario descriptions is Appendix G Section I: Techno-Economic Analysis (Section I).  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)” (Section I p.11). The initial analysis found that the Advisory Panel recommendations in Scenario 1 did not meet the Act emissions limits (Figure 1).

There is another aspect to Figure 1.  In order to understand the true impact of these scenarios it is important to know what is included and what is not included.  In particular the Reference Case has “a business-as-usual forecast plus “implemented policies”.  The inclusion of implemented policies in the Reference Case means that many New York State policies that exist only to meet climate goals are not included in the expected costs for the Climate Act itself. 

Figure 1: Screen capture of Figure 4 and its foornote on Section I – page 12.  Note that there is no caption for the figure but there is a footnote.  The footnote is the primary reference for the definition of the Reference Case

The footnote for the preceding figure states that the Reference Case includes a business as usual forecast plus implemented policies, including but not limited to federal appliance standards, energy efficiency achieved by funded programs (Housing and Community Renewal, New York Power Authority, Department of Public Service, Long Island Power Authority, NYSERDA Clean Energy Fund), funded building electrification, national Corporate Average Fuel Economy standards, a statewide Zero-emission vehicle mandate, and a statewide Clean Energy Standard including technology carveouts.  The following table from Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions lists specific programs in the Reference Case.  In order to provide a full accounting of the control measures the Scoping Plan documentation should include a description, the emissions reductions expected, and the costs expected for each of the scenarios.  That information is not provided so the Draft Scoping Plan is fatally flawed.

Figure 2: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Integration Analysis Mitigation Scenarios

The consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   Figure 3 lists the control measures used. The three mitigation scenarios are described in Section I on page 14:

Transformative levels of effort are required across all sectors, and all three scenarios include high levels of electrification, including Scenario 2, which also incorporates the strategic use of low-carbon fuels. Scenario 3 pushes harder on accelerated electrification to meet the emission limits using a very low bioenergy and low-combustion mix of strategies. Scenario 4 pushes beyond 85% direct reductions in 2050 by layering some low-carbon fuels back in, examining very high VMT reduction, and assuming high (but also highly uncertain) levels of innovation in the waste and agriculture sectors. Scenario 4 is the only evaluated scenario that achieves carbon neutrality without the use of negative emissions technologies like direct air capture of CO2, which is also subject to high uncertainty, but is required in Scenarios 2 and 3 to address the gap between remaining gross emissions in 2050 and the ambitious assumed projections of natural sequestration.

Figure 3: Integration Analysis Technical Supplement, Section I, Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions

Chapter 9 of the Draft Scoping Plan includes four figures (starting at page 72) that list projected emission reductions and the strategies employed to achieve them for all four scenarios.  The following text reproduces the figures and extracts the sector strategies for multiple dates in the timeline in order to show how the strategies differ between the scenarios.

Scenario 1: Advisory Panel Recommendations

Representation of the Advisory Panel recommendations, which provide a foundation for all scenarios; however, scenario modeling shows that further effort is needed to meet Climate Act emission limits.

Figure 4: Draft Scoping Plan Page 72

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
    • Bioheat blends in NYC buildings
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 0.9 million homes electrified with heat pumps
    • 13% of all homes have efficient shell upgrades
    • 15% renewable natural gas in pipeline
  • Transportation
    • 1.8 million zero-emission light-duty vehicles
    • 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3.6 GW battery storage
  • Hydrofluorocarbon (HFC)
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
  • Industry
    • 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
  • Forestry
    • Forest sequestration returnes to 1990 levels (-35 MMT)

Scenario 2: Strategic Use of Low-Carbon Fuels

Advisory Panel recommendations adjusted for strategic use of bioenergy derived from biogenic waste, agriculture and forest residues, and limited purpose grown biomass, as well as a critical role for green hydrogen for difficult-to electrify applications. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 5: Draft Scoping Plan Page 72

Italicized items are changes from Scenario 1

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
    • Bioheat blends in NYC buildings Scenario 2 eliminates bioheat blends
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps.
    • 1.5 instead of 0.9 million homes electrified with heat pumps
    • 25% instead of 13% of all homes have efficient shell upgrades
    • 9% instead of 15% renewable natural gas in pipeline
    • There is no figure that provides similar information for the Reference Case so it is not clear, for example, how many homes are electrified with heat pumps in the Reference Case
  • Transportation
    • 2.7 instead of 1.8 million zero-emission light-duty vehicles (90% new sales)
    • 100% zero-emission bus sales
    • 75% renewable distillate instead of 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3 GW instead of 3.6 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
  • Forestry
    • Forest sequestration returnes to 1990 levels (-35 MMT)
  • Negative Emission Technology, for example, direct air capture
    • -26 MMT

Scenario 3: Accelerated Transition Away from Combustion

Advisory Panel recommendations adjusted to include a very limited role for bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation. This scenario includes a role for negative emissions technologies to reach carbon neutrality.

Figure 6: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 2

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 1.8 instead of 1.5 million homes electrified with heat pumps
    • 25% of all homes have efficient shell upgrades
    • Early retirement of old heating systems
    • 4% instead of 9% renewable natural gas in pipeline
  • Transportation
    • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
    • Early retirement of old vehicles
    • 100% zero-emission bus sales
    • 75% renewable distillate instead of 3% renewable diesel
  • Generation
    • 70% clean energy standard
    • 3 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission
    • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 83% instead of 33% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation
    • 100% renewable natural gas, renewable distillate and renewable jet fuel
    • Limited reuse of captured methane
  • Forestry
    • Additional afforestration and forest management -40 MMT instead of -35 MMT
  • Negative Emission Technology, for example, direct air capture
    • -20 MMT instead of -26 MMT

Scenario 4: Beyond 85% Reduction Advisory Panel recommendations adjusted to reflect accelerated electrification and targeted use of low-carbon fuels. This scenario includes additional reductions in VMT and innovation in methane abatement. This scenario reduces gross GHG emissions beyond the 2050 limit and avoids the need for negative emission technologies.

Figure 7: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 3

2022

  • Buildings
    • Increased sales of high efficiency appliances and smart devices
    • Start ramping up sales of heat pump space heaters and water heaters
  • Transportation
    • Start ramping up sales of zero-emission light-duty vehicles

2025

  • Oil and Gas Sector
    • Leak detection
    • Strategic pipeline decommissioning

2030

  • Buildings
    • All new sales of single-family and low-rise residential heating systems are heat pumps
    • 1.8 instead of 1.5 million homes electrified with heat pumps
    • 25% of all homes have efficient shell upgrades
    • Early retirement of old heating systems
    • 7% instead of 4% renewable natural gas in pipeline
  • Transportation
    • 3.4 instead of 3.7 million zero-emission light-duty vehicles (98% new sales)
    • Early retirement of old vehicles
    • 100% zero-emission bus sales
    • 7% renewable distillate
  • Generation
    • 70% clean energy standard
    • 3 GW battery storage
  • HFC
    • Adoption of ultra-low global warming potential technologies

2035

  • Buildings
    • All new sales of multi-family and commercial heating systems are heat pumps
  • Transportation
    • All new sales of light-duty vehicles are zero-emission
    • Accelerated transition to zero-emission medium and heavy duty vehicles

2040

  • Generation
    • 100% zero-emission electricity
  • Transportation
    • All new sales of medium and heavy duty vehicles are zero-emission

2050

  • Waste
    • 100% waste diversion
    • Additional methane capture
  • Agriculture
    • Mitigation in animal feeding, manure management and soils
    • Future R&D
  • Industry
    • 83% of natural gas use electrified
    • Hydrogen use
    • Carbon capture and sequestration for all cement and iron&steel facilities
  • Aviation?
    • 100% renewable natural gas and renewable distillate
    • 71% renewable jet fuel
    • Limited reuse of captured methane
  • Forestry
    • Additional afforestration and forest management -40 MMT instead of -35 MMT
  • Negative Emission Technology, for example, direct air capture
    • -20 MMT instead of -26 MMT
  • Additional innovation in methane mitigation and natural sequestration

Conclusion

There are only a couple of things to mention.  I have noticed that anyone who has addressed the Council request for feedback on the components of the three mitigation scenarios has advocated for Scenario 3, Beyond 85% reductions.  Given the paucity of information available I can only assume that they supported it because it sounded more stringent. 

The list of control measures that are included in the Reference Case, and thus don’t show up as direct costs for the Climate Act, includes multiple measures that only exist as part of the State’s initiatives to address climate change.  I think that is a semantic trick that disguises the real costs of the transition to net-zero because it is clear that the costs associated with at least some of those measures are not included in the cost-benefit analysis.  Because the control measure descriptions, emission reductions and costs are not provided in detail, it is impossible to determine how many are misleadingly categorized to be able to claim that the Climate Act benefits are greater than the costs.  It is also impossible to determine if the Draft Scoping Plan excluded the emission reduction benefits associated with those measure.  If their costs were not included then it is wildly inappropriate to not exclude the benefits from the cost-benefit analysis.  There is no indication that those emission benefits were excluded.

In future posts I will address specifics associated found in specific sectors.  From what I have seen so far there are plenty of concerns.

Failure of the Climate Change Scoping Plan to Meet the Requirements of the Climate Act

This post describes the comments submitted on the Draft Scoping Plan by Herschel Specter. If I knew how to do guest posts on this site, I would have made this a guest post.  My apologies but I am going to have to wing it.

Herschel Specter is the President of Micro-Utilities, Inc. and holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the New York.  He is a passionate supporter of nuclear power.  While I don’t agree with everything in his comments there are many great points.  I asked Herschel if I could make his comment letter into a post and he agreed.  The following text is from his cover letter.  I have posted his comments here.

Overall Conclusions

(A) The largest challenge facing the CAC and NY State is to regain the confidence of the people of New York that its energy plan is fact-based, technically agnostic and sound, and is forward looking, free of any past political or ideological influences. The Scoping Plan does not convey such confidence-building characteristics, and 

(B) The scoping plan fails to implement the Community Protection (CP) portion of the Climate Leadership and Community Protection Act (CLCPA), detailed below. Even if this NYSERDA scoping plan could work, what good is it if most people cannot afford the electricity this scheme would produce, and,

(C) The claim in Section 3.1 of the scoping plan that NY State is a leader in dealing with climate change is unsupported by the facts. For years NY State has favored imported fracked gas over building renewable energy infrastructure, while also opposing further expansion of clean nuclear power. (See Appendix C, page 43, of the attached critique). It is not convincing that NY is a leader in climate change when a major state agency, NYISO, recently reported that the State, and especially New York City, face dangerous shortages this decade in electricity generation and in electricity transmission. (See Reference 2 of the attached critique).

Specific Comments

1.High Costs. Electricity is a critical commodity, but its cost is regressive. High electricity prices disproportionately burden LIM (low income-to-middle income) families. The scoping plan places near exclusive reliance on renewable energy (solar and wind). Yet other studies have shown a mix of variable energy sources (solar and wind) joined with firm energy sources (nuclear and/or fossil fuels with no net carbon) are far less expensive. In one study a mix of energy sources reduced the electricity costs of a proposed all renewable electricity future from 15 cents/kilowatt hour to 9 cents per kilowatt hour. (See Table A4, page 20, of the attached critique). NYSERDA should have investigated which combinations of variable and firm energy sources are the least burdensome for low and middle income families. High electricity costs can cause businesses to relocate outside of New York, causing job losses.

2.Jobs-1. How many jobs will actually be created in New York when developing offshore wind capacity compared to jobs outside of New York? The Empire Wind Project is instructive. Two huge oil companies, British Petroleum (UK) and Equinor (Norway), have secured a contract from NY State to build the Empire Wind Project.  Not being in the wind turbine business, these oil companies turned to Vestas, a Danish wind turbine company, to build a huge (600 to 700 feet tall) wind turbine off of NYC. This assumes that the conditions of the Jones Act can be met. British Petroleum and Equinor recently filed a request with the Federal Energy Regulatory Commission for a one and a half year delay. Delays do not produce jobs. Importing wind turbines produces  jobs, overseas.

3. Jobs-2. It takes a special type of ship, called a jack ship, to lift the very heavy offshore wind turbine hub (the nacelle) and football field length turbine blades into place while at sea. New York does not make or own such jack ships. There is only one jack ship under construction, for a different state in the USA, large enough to install the huge 15 MW Vestas design. This specialized ship has a cost of $500 million dollars and requires three years to construct. However China makes such huge specialized ships with the latest one deployed off of the east coast of England. It takes an enormous crane to lift the nacelle and turbine blades. New York does not manufacture such huge cranes, but many overseas companies do. What is the NYSERDA plan to install these very large offshore wind turbines? How many MWs/year can be installed considering the limited number of jack ships? Per NY taxpayer dollar, how many pennies go to New York workers to build and install this mammoth offshore project and how much money goes out of state?

4.Jobs-3/ land use. According to the Daily News [“State reaffirms Alle-Catt wind farm”, Matt Surtel, September 30,2020] the 30,000 acre Alle-Cat wind farm will employ 182 jobs during construction, but this will decrease to just 13 permanent jobs to operate the facility. At that rate, a million acres of onshore wind farms would only create 400 permanent jobs, less than half the number of jobs lost when Indian Point was closed. This 340 megawatt wind farm will need 125 times the area of the Indian Point site to produce less than 5% of the electricity that was generated  at Indian Point.

5.Public anger-1 Upstate communities have taken NY State to court because they were stripped of  Home Rule protection while solar and  wind farms are being imposed on them. This hardly seems like implementing the Community  Protection portion of the CLCPA. Fishermen off of Long Island are similarly aggravated with the State’s offshore wind  program and complain of being ignored by the State. Where is consent-based siting? About 1,000 high paying jobs were lost, as well as substantial tax revenue, as a result of NY State’s actions to press for the closure of Indian Point nuclear plants and replace these two nuclear units with gas. Citizens of New York have not forgotten that they were told by former Governor Andrew Cuomo that Indian Point would be replaced by non-carbon sources. That never happened. Such actions are not confidence building. After years of reducing the carbon intensity per KWh of NY’s electricity, it is on the rise again because clean electricity from Indian Point was replaced by gas. The price  for electricity and home heating and making hot water with gas has skyrocketed. This is partly due to world conditions, but as  newspapers in the Hudson Valley point out, it is also due to the closure of Indian Point which did not burn fossil fuels, but rather produced 80% of the carbon-free electricity in downstate New York..

6. Public anger-2  The Danskammer plant in  Newburgh, NY, originally was an old coal burning plant that  was shutdown. It was refurbished to run on gas, but a special regional surtax on people was set up to pay for this refurbishment. If the people are paying  for new gas infrastructure, why don’t they own this gas infrastructure? Moreover, people were told that this refurbished plant would only be used infrequently; during times of peak demand. Later there was an effort to allow Danskammer to run full time, which angered local people, many of whom live in nearby environmental justice areas. Thanks to Governor Hochul and the DEC, this expansion of Danskammer use was not permitted, nor was a large new gas plant in Astoria, Queens approved. But as NYISO makes clear, this compounds the dangerous electricity reliability issue. No State agency has come forward with a plausible plan to provide clean electricity while reducing greenhouse gases in a time frame that would avert the potential blackouts this decade that NYISO has warned about. How does NY State simultaneously deal with climate change and continue to meet reliability requirements using realistic renewable energy manufacturing and installation capacities? This emerging crisis NYISO identified would not be pending if the Indian Point units were still operating.

7. Still more public anger-3. It appears that the CPV gas plant has been allowed to operate without all required permits and this plant has EJ areas nearby. If this lack of all necessary permits is still true, the DEC should require full compliance or shut CPV down.

8. Security issues. Increased use of natural gas for electricity production, home heating, and in making hot water has prompted gas delivery utilities to seek additional pipeline infrastructure. The former Governor was opposed to this, which led to open conflict between the former Governor and these gas utilities. This has been temporarily resolved by allowing some gas to be delivered by trucks, even though pipelines are safer and less expensive. This compromise has created a new class of terrorist targets; “truck bombs” that drive on our neighborhood streets.

9. Land use. In order to implement the NYSERDA scoping plan an estimated 24.4 million solar panels, each 25 square meters in size, would be needed. (See page 43 of the critique). A “rule of thumb” published in recent solar literature is that each megawatt of solar energy capacity requires about ten acres of land. At that rate it would take about 950 square miles. of New York farm and forest lands to accommodate this massive solar buildout. What will be the reaction of upstate New Yorkers to such a huge expansion? Yet solar energy is the least attractive choice for dealing with climate change. It is inherently less resilient to climate change than firm energy sources (See section 6.3 of the attached critique) It has the lowest capacity factor of any clean energy source, around 14%, as reported by NYISO, while nuclear is over 90%. Without expensive storage It is not dispatchable and is incapable of reducing the peak demand in winter which occurs after sunset. As NY State moves towards being a winter peaking state, this winter limitation of solar energy becomes an even larger negative attribute. Further, such extensive reliance on solar energy furthers  upstate/ downstate friction. Upstate people are to make sacrifices in values they hold dear, such as not being a victim of renewable energy industrialization in their back yard, just  to provide electricity  to downstate areas and NY City. NYSERDA should clearly and completely discuss the future use of present upstate nuclear plants which many upstate people support, particularly since their land use per KW hour is far less than renewable energy sources and jobs at these units pay well..

Land use is a highly charged subject. Not only is it an issue in upstate NY, it shows up  everywhere. For example, people in White Plains recently rejected the installation of solar panels in a cemetery because doing so  would have required the cutting down of a large stand of trees.  The two nuclear units at Indian Point supplied enough clean electricity to power 25% of the electricity in New York City and Westchester County, yet their land use was less than one half of one square mile. 

10.Data  errors. The NYSERDA plan has serious data errors in the capacity factors it used (See Section 8 of the attachment) . These data errors, collectively, would produce a capacity shortfall are almost the size of the whole NY State present electricity capacity.

11. Modeling errors. In 2021 an estimated 702 people died and almost $200 billion dollars worth of damage occurred in Texas when there was a gap in the supply of electricity during a polar vortex. Two things are happening simultaneously which call for a careful analysis of what is needed to design a NY  future electric grid. We  will experience extreme temperatures, hot and cold, more frequently and for longer durations. Also, we are moving towards a more electrified future we are far more dependent on electricity.. When there is an electricity gap during a time of extreme heat or cold,  people may die.  It appears that the  NYSERDA draft plan is not based on preventing an energy gap during extreme conditions like a polar vortex or very high statewide temperatures, but is just designed to meet the  typical energy needs during a week of cold weather in January, 2050. (See Section 9.2 of the attachment). To prevent loss of lives the grid should be designed to cope with extreme temperatures, with an additional margin  for unanticipated losses of generation and transmission. Further, NYSERDA did not account for very large and long duration wind lulls like that which occurred last year over all of northern England (See Reference 6  in the attached critique). There are other modeling errors identified in the attachment, as well as very questionable assumptions about the rate renewable energy devices, like offshore wind turbines, can be built and installed.

12. Energy storage. Unlike nuclear plantswhere energy storage is built right into the uranium pellets in the fuel rods, renewable energy needs energy storage because of its variability and for times when the sun is not shining and/or the wind is not blowing.  Unlike other New York energy future  studies which relied on Renewable Natural Gas, an undeveloped technology, NYSERDA turned to hydrogen for energy storage. It is hard to imagine a more difficult material to work with. Because of its very small molecular size, hydrogen has a much higher propensity than natural gas to leak out of piping and storage systems. Hydrogen leakage is important from a safety point of view; hydrogen has an ignition range six times wider than what natural gas has. (See TABLE A-8 of the attached critique.)

The volumetric energy density of hydrogen is very low. In order to achieve economically attractive volumetric energy densities, hydrogen would either have to be compressed to pressures in the 10,000 to 15,000 PSI (pounds per square inch) range or cooled to minus 253 degrees C, which is approaching absolute zero. Because of the required very high pressures, hydrogen cannot be distributed through the present natural gas piping or used in present gas storage infrastructure. It takes a significant amount of energy to cool hydrogen down to an extremely low temperature and to maintain this very low temperature. Hydrogen also embrittles steel. How did the NYSERDA plan account for this?

These challenging attributes of hydrogen make it difficult to store or distribute at reasonable costs. In practice, when hydrogen is used in industry, its source and the end user, like a refinery, are co-located on the same site. This co-location minimizes hydrogen storage and distribution issues. The distributed nature of NYSERDA’s energy sources and NYSERDA’s end users greatly limits co-location opportunities. The scoping plan describes a process of using solar energy to make hydrogen from water by  electrolysis. This (compressed?) hydrogen would be stored for months then, assumedly, burned  in some kind of a hydrogen fueled gas turbine (now under development) or fuel cells to convert the stored hydrogen back into electricity. NYSREDA assigns a 50% round trip energy loss for this process. It is not clear if this includes hydrogen losses through leakage while in storage, or the energy it takes to compress or cool the hydrogen, or the energy losses in the gas turbine. If the source of electricity is solar energy and NYISO’s 14% solar capacity factor is used, the overall efficiency of the solar/hydrogen storage/ burning in gas turbines to get back to electricity would be, at best, about (0.14)((0.50) = 0.07. Would a 7% efficient energy storage system result in a low-cost electricity as needed by LIM families? If it becomes obvious that hydrogen storage is unworkable, what is NYSERDA’s backup storage plan?

About the Author

Herschel Specter, President of Micro-Utilities, Inc., holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the State of New York. At the Atomic Energy Commission in the 1970s he was responsible for the licensing of the Indian Point 3 nuclear power plant. In the 1980s the New York Power Authority hired Mr. Specter to defend its Indian Point 3 nuclear plant in a federal adjudicatory trial. He and his team of experts prevailed in court. Mr. Specter served at diplomat rank for 5 years at the International Atomic Energy Agency in Vienna, Austria where he led an international effort writing design safety standards for nuclear power plants.

Mr. Specter has been Chairman of two national committees on nuclear power plant emergency planning and was a guest lecturer for several years on emergency planning at Harvard’s School of Public Health. He analyzed emergency responses for a hypothetical terrorist attack on the Indian Point power plants which were located in the nation’s highest population density area. Mr. Specter has presented testimony at the National Academy of Sciences on the Fukushima accident and on other nuclear safety matters and has been a guest speaker at many universities on matters of energy policy.Today he is one of 14 Topic Directors in Our Energy Policy Foundation, a group of about 1500 energy professionals who seek to bring unbiased and comprehensive energy information to our political leaders and members of the public.

Mr. Specter has been active in social and environmental matters. He has been a Big Brother and in 1971 had the honor of being selected as “Big Brother of the Year” for all of the USA and Canada. While voluntarily serving as President of Big Brothers of Washington, D.C., the number of boys the agency helped was doubled. He also received a personal letter of commendation from the President of the United States for his work with the Youth Conservation Corps.

Mr. Specter was born in White Plains, NY and lives there now.