New York State Environmental Policy

I started working for Niagara Mohawk Power Corporation in 1981.  Since that time, I have evaluated all proposed New York Department of Environmental Conservation (DEC) air quality environmental regulations in New York and worked on many other environmental rules.  Over that time I have seen New York environmental policy become much more dogmatic and driven by ideology and not science.  These posts address example policies that are not a pragmatic balance of risks and benefits.

New York Codifying NIMBYism, July 15, 2018

At the top of the list of ideological decisions was the refusal to grant a permit to construct a liquid propane storage facility in the Finger Lakes region.

Unintended Ramification of the Finger Lakes LPG Storage Community Character Decision, July 22 2018

It is not clear to me how this decision could not be used against any project.

CPV Valley Energy Center Operating Status August 1, 2018, August 6, 2018

This post recounts the machinations that DEC used to try to stop a completed natural gas fired power plant from operating.  I have not doubts that this decision was dictated by the Cuomo Administration.

New York State Environmental Regulatory Hypocrisy January 12,2019

This post describes a new environmental regulation that promulgates a allowance distribution methodology that DEC has complained about when used in upwind states.

Another Example of New York State Environmental Hypocrisy July 16, 2020

DEC Commissioner Basil Seggos responded  to modifications to NEPA with a press release vilifying the changes to the process.  This post explains why the Commissioner’s concerns are flatly contradicted by the State’s own actions.

Environmental Justice Risks from Hyper-Local Monitoring are Exaggerated February 23, 2021

New York environmental policy caters to the environmental justice community.  While there is no doubt that there are real environmental inequities that should be addressed oftentimes the EJ community gets a pass with their claims even when their numbers are wrong.

Re-building Interstate I-81 in Syracuse, NY May 30, 2021

Proponents of the option to create a community grid highway system to replace the current viaduct in Syracuse, NY claim that the original decision to locate it where it was constructed was because it went through a predominantly black neighborhood.  I argue in this post that once the decision was made to build the highway through the city that the choice had to be that location because of geographical constraints.

Replacing Peaking Power Plants with Battery Energy Storage Systems October 24, 2022

Environmental Justice advocates believe that shutting down peaking power plants and replacing them with battery energy storage powered by renewable energy will lower health risks to adjacent neighborhoods.  However, this post shows that the rationale for air quality health benefits is mistaken and there are potential health risks with the poorly understood battery energy storage systems that exceed the potential air quality benefits claimed.

New York Good Intentions Unsullied  by Reality  February 15, 2023

There is no question that past inequities in environmental burdens were wrong and should be avoided in the future.  Nor is there any question that everyone deserved the right to clean air and water.  The problem is that if this good intentioned solution insists on zero risk, then the reality is that it requires no emissions.  If no tradeoffs are allowed then the only solution is to shut down or not build.

Righteous Risks and the Climate Act  December 27, 2023

Righteous risks are becoming a threat to rational policies, democracies and the public good.   Tradeoffs between Climate Act absolutism, i.e., demanding nothing less than zero, and the extra costs, reliability risks, and unintended environmental impacts are not even on the table for discussion. Given that  New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990, it is clear that New York’s Climate Act cannot affect climate change.  I think that there is no rational reason not to discuss pragmatic solutions.  I am not saying that New York should not do something, but clearly, we have time to make sure that the actions taken do not do more harm than good.  Arguing otherwise is not in the best interests of New York.

Graduation Speech Essay You Need to Hear has Climate Response Implications May 21, 2024

In my opinion, I think there are zero-sum versus positive-sum environmental parallels.  The United States has developed a comprehensive set of environmental standards and there have been unquestioned overall environmental quality improvements over the last several decades.  The sum of benefits and costs are positive.  Regarding emissions in isolation, focusing only on the negatives and disregarding any benefits is an approach like the zero-sum concept of wealth. It creates an unnecessarily pessimistic outlook, hinders growth, and could lead to unintended consequences.

GAO Information on Peaking Power Plants May 28, 2024

The GAO report on “Information from Peak Demand Power Plants” covers some of the peaking power plant issues in New York. This post critiques that report.