Climate Leadership and Community Protection Act Simple Value of Carbon Reduction Benefits

The popular narrative is greenhouse gas emission reductions are necessary to prevent climate change impacts.  In order to justify the monetary costs and loss of personal choices necessary to make those reductions a parameter was developed to “put the effects of climate change into economic terms to help policymakers and other decisionmakers understand the economic impacts of decisions that would increase or decrease emissions.”  At the January 19, 2021 Climate Action Council meeting there was a discussion of New York’s version of this parameter and it has become clear that the Council intends to use it to claim that the costs imposed on New Yorkers are “cost-effective”.  The problem is that they will be comparing real costs today against contrived value-driven estimates of speculative impacts occurring in the far future elsewhere.  In this post I explain the methodology used to value greenhouse gas emission reductions and how assumptions and value judgements radically change the estimated benefits.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.

I have summarized the CLCPA Summary Implementation Requirements and  written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climateThe opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The CLCPA requires that the Department of Environmental Conservation (DEC), in consultation with the New York State Energy Research and Development Authority (NYSERDA), establish a value of carbon for use by State agencies. This value of carbon represents the present-day value of projected future net damages from emitting a ton of CO2 today.  A draft document was issued for comments in October 2020 and in December the Value of Carbon Guidance (“Guidance”), an appendix with values for carbon dioxide, methane, and nitrous oxide, and a supporting memo were released for use by State agencies along with recommended guidelines for the use of these and other values by State entities.

I followed the development of this guidance throughout the process and if you want to get into the weeds then check out my previous posts. In an earlier post I quantified the impacts of different assumptions in the social cost valuation process and that post documents the information in this post.  I also described the background of the value of carbon after the initial stakeholder webinar, documented the comments I submitted on the draft document, and described the DEC response to my comments.

The Guidance has prepared estimates, in dollars, of the economic damages that would result from emitting one additional ton of greenhouse gases into the atmosphere to justify the costs of mitigating strategies.  Resources for the Future (RFF) prepared an overview summary of the process used to calculate these values and described how the values are used in policy analysis.  Note that Guidance supporting memo was prepared by the New York State Energy Research & Development Authority (NYSERDA) and RFF and includes much of the same information.  The Guidance recommends using the damages approach to valuing carbon.  RFF refers to the value of carbon using that approach as the Social Cost of Carbon (SCC) and I will use the value of carbon and SCC interchangeably in this post.  According to RFF:

The point of this post is that there many choices that affect the value of the SCC. The emissions, climate response and economic calculations are based on research and expertise from many different fields, such as climate science, demography, and economics. While proponents of this approach give the impression that the input presumptions are based on the “science”, the reality is that assumptions made by model developers play as much of a role as “science” on the results.  Inevitably the assumption decisions are subject to value judgements and the biases of the researchers.  RFF also notes that “the modeling must incorporate information that is inherently uncertain, such as projections of future economic growth.”

The Guidance document makes a recommendation for the value of the SCC to use: “The Department specifically recommends that State entities provide an assessment using a central value that is estimated at the 2 percent discount rate as the primary value for decision-making, while also reporting the impacts at 1 and 3 percent to provide a comprehensive analysis.” For CO2 this translates into a 2020 value of carbon dioxide of $53-421 per ton, with a central value of $125 per ton. The full set of values for 2020-2050 is provided in the separate Appendix tables.

Discussion

All evidence suggests that the Climate Action Council responsible for developing a plan to implement the law intends to estimate monetary benefits by multiplying the values of carbon in the Guidance document and the observed emission reductions to claim that the costs of their strategies to reduce emissions are outweighed by those benefits.  Using their recommended values and the official 1990 baseline emissions for all the greenhouse gases included in the CLCPA the total benefits total $668 billion:

Table 1: Recommended Value of Carbon Guidance 1990 Reduction Benefits (millions)

CO2CH4N2OPFCsHFCsSF6NF3Total
$33,100$373,317$260,758$113$6$501$0$667,795

In my detailed post I documented different factors that affect the benefits calculations.  In this post I will qualitatively describe the value judgements used to, in my opinion, maximize the CLCPA narrative that there is value in the proposed emission reductions.  One example of narrative-driven value judgement is the global warming potential (GWP) time horizon.  This parameter weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame.  Most jurisdictions use a 100-year GWP time horizon but the CLCPA law mandates the use of the 20-year GWP that increases methane (CH4) reductions associated with natural gas.  Note that in Table 1 methane benefits are three times higher than the benefits of CO2.  If the 100-year GWP values were used then reduction benefits would drop 34% 

The biggest driver of social costs from greenhouse gases is the discount value which is used to estimate how much money invested today would be worth in the future so that we can link today’s costs to the future.  It is accepted that there is no consensus or uniform scientific basis for the selection of a discount rate. The CLCPA implementation process claims to follow the “science” but it appears that is only when it is consistent with their narrative to maximize the benefits of reductions.  For example, the Obama Administration Integrated Working Group (IWG) chose a central value 3% and only published results down to 2.5% but New York chose to use 2% as the central value which results in social costs over two times larger.  Combining the GWP and discount value judgements, if New York followed the IWG recommendations the benefits would be 70% lower.

There are other parameters that affect the social benefits of emission reductions.  Part of the argument for using a lower discount rate is that it helps protect our children and grandchildren but the Guidance calculates future net damages out 300 years, far future many generations away.  No one could have imagined the technology available in today’s society one hundred years ago so it is an act of extreme hubris to claim that any projection of how the world will operate in 100 years, much less 300 years, should be used to guide current actions.  In testimony before the U.S. House of Representatives Subcommittee on Environment Committee on Oversight and Reform on September 24, 2020, by Kevin D. Dayaratna determined that if economic impacts are only considered out 150 years the social benefits are reduced 14%.

The entire rationale for the CLCPA is that there is a climate emergency threat to society because of climate change due to greenhouse gas emissions.  The process does not recognize that the climate models used to predict this future are speculative.  One way to minimize modeling uncertainty is to use historical data to estimate climate sensitivity to greenhouse gases.  Dayaratna showed that an empirical approach reduced benefits 48%.

New York chose to calculate world-wide benefits of reductions because “climate change is a global problem”.  It is a fact that climate change impacts will be felt most by countries that are too poor to be resilient.  However, I believe that anyone having trouble paying energy bills today would be hard pressed to accept the higher costs imposed by the CLCPA if they know that their descendants will derive little benefit from today’s sacrifices because most of the benefits will accrue elsewhere.  Considering only benefits that would accrue to the United States from reductions instead of global benefits reduces the benefits 86%.

Conclusion

To sum up, greenhouse gas emission reductions under the CLCPA using the recommended assumptions are supposed to provide benefits of $668 billion.  Using the Obama Administration recommended assumptions the benefits go down to $201 billion.  Using different value-driven estimates, reducing speculation by using observations rather than models, estimates that go out “only” 150 years instead of 300 years, and counting only benefits that occur in the United States instead of the globe results in benefits that are reduced to $12.5 billion.

Ultimately, the value of carbon methodology relies on a complex causal chain from carbon dioxide emissions to social impacts that are alleged to result from those emissions.  Richard Tol testified that these connections are “long, complex and contingent on human decisions that are at least partly unrelated to climate policy. The social cost of carbon is, at least in part, also the social cost of underinvestment in infectious disease, the social cost of institutional failure in coastal countries, and so on.”  The fact is that this process focuses exclusively on negative externalities and completely ignores the benefits of fossil fuels.  I believe these facts make this a contrived process.

One final point.  After all these machinations, the social cost values chosen when applied to the 1990 baseline emissions indicate that reducing those emissions will result in $668 billion in benefits.  The Climate Action Council is charged with developing an implementation plan that should include costs.  What happens if those costs are greater than these benefits?

Climate Leadership and Community Protection Act NY Value of Carbon Cost Effectiveness

At the January 19, 2021 Climate Action Council meeting there was a discussion of New York’s value of carbon guidance document and it has become clear that the Council intends to use the value of carbon to claim that the costs imposed on New Yorkers are “cost-effective”.  The problem is that they will be comparing real costs today against contrived value-driven estimates of speculative impacts occurring in the far future elsewhere.  This extensive post provides context for their numbers that maximize the costs and addresses explanations of the value of carbon guidance provided at the meeting. 

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.

I have summarized the CLCPA Summary Implementation Requirements and  written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

In this post I tried to simplify the discussion as much as possible but still ended up with a post that was too long.  In order to address this, I rearranged the order of the sections.  I provide background information first followed by a synopsis that presents the key findings and conclusions.  If you want to learn where the numbers come from a simplified description of the methodology used to calculate the key findings comes next.  Finally, I present a more detailed description of the CO2 societal cost analysis to provide even more details for anyone interested.  Because I have not figured out how to format tables and show them in the text each table has a link to a formatted version. Stay tuned for an even simpler version if this one gets too wonky.

Background

The CLCPA requires that the Department of Environmental Conservation (DEC), in consultation with the New York State Energy Research and Development Authority (NYSERDA), establish a value of carbon for use by State agencies. This value of carbon represents the present-day value of projected future net damages from emitting a ton of CO2 today.  A draft document was issued for comments in October 2020 and in December the Value of Carbon Guidance (“Guidance”), an appendix with values for carbon dioxide, methane, and nitrous oxide, and a supporting memo were released for use by State agencies along with recommended guidelines for the use of these and other values by State entities.

I followed the development of this guidance throughout the process and if you want to get into the weeds then check out my previous posts.  I described the background of the value of carbon after the initial stakeholder webinar, documented the comments I submitted on the draft document, and described the DEC response to my comments.  Be forewarned however, these posts are wonky.  In this post I attempted to show how differences in purported reduction benefits vary as a function of different assumptions.

The Guidance has prepared estimates, in dollars, of the economic damages that would result from emitting one additional ton of greenhouse gases into the atmosphere to justify the costs of mitigating strategies.  Resources for the Future (RFF) prepared an overview summary of the process used to calculate these values and described how the values are used in policy analysis.  Note that Guidance supporting memo was prepared by the New York State Energy Research & Development Authority (NYSERDA) and RFF and includes much of the same information.  The Guidance recommends using the damages approach to valuing carbon.  RFF refers to the value of carbon using that approach as the Social Cost of Carbon (SCC) and I will use the value of carbon and SCC interchangeably in this post.  According to RFF:

The point of this post is that there many choices that affect the value of the SCC. The emissions, climate response and economic calculations are based on research and expertise from many different fields, such as climate science, demography, and economics. While proponents of this approach give the impression that the input presumptions are based on the “science”, the reality is that assumptions made by model developers play as much of a role as “science” on the results.  Inevitably the assumption decisions are subject to value judgements and the biases of the researchers.  RFF also notes that “the modeling must incorporate information that is inherently uncertain, such as projections of future economic growth.”

The Guidance document makes a recommendation for the value of the SCC to use: “The Department specifically recommends that State entities provide an assessment using a central value that is estimated at the 2 percent discount rate as the primary value for decision-making, while also reporting the impacts at 1 and 3 percent to provide a comprehensive analysis.” For CO2 this translates into a 2020 value of carbon dioxide of $53-421 per ton, with a central value of $125 per ton. The full set of values for 2020-2050 is provided in the separate Appendix tables.

Synopsis

All evidence suggests that the Climate Action Council responsible for developing a plan to implement the law intends to use the monetary benefits derived by multiplying the values of carbon in the Guidance document and the observed emissions to claim that the costs of their strategies to reduce emissions are outweighed by those benefits.  The problem is that they will be comparing real costs today against contrived value-driven estimates of speculative impacts occurring in the far future elsewhere as I show in this post.  Table 1 lists the monetary benefits for seven assumption scenarios that result in a benefits range of $668 billion to 12.6 $billion.

Table 1: Alternative New York 1990 Value of GHG Reduction Benefits ($millions)

1) CLCPA Value of Carbon Guidance 2% Discount & GWP-20
CO2CH4N2OPFCsHFCsSF6NF3Total
$33,100$373,317$260,758$113$6$501$0$667,795

2) CLCPA Value of Carbon Guidance 2% Discount Rate & GWP-100

CO2CH4N2OPFCsHFCsSF6NF3Total
$33,100$111,113$294,751$170$3$653$0$439,789
3) IWG 3% Discount Rate Using GWP-100
CO2CH4N2OPFCsHFCsSF6NF3Total
$14,034$60,988$125,764$72$1$277$0$201,136
4) Dayaratna 300 year horizon, 3% Discount Rate Using GWP-100
CO2CH4N2OPFCsHFCsSF6NF3Total
$10,007$33,592$89,109$51$1$197$0$132,957
 5) Dayaratna 150 year horizon, 3% Discount Rate Using GWP-100 (-14.3%)
CO2CH4N2OPFCsHFCsSF6NF3Total
$12,025$52,257$107,759$62$1$237$0$172,342
 6) Dayaratna empirical ECS, 150 year horizon, 3% Discount Rate Using GWP-100 (-48%)
CO2CH4N2OPFCsHFCsSF6NF3Total
$6,256$27,187$56,061$32$0$123$0$89,660
7) Domestic benefits, empirical ECS, 150 yr horizon, 3% Rate Using GWP-100 (-86%)
CO2CH4N2OPFCsHFCsSF6NF3Total
$876$3,806$7,849$4$0$17$0$12,552

Section 1 lists the benefits (2020 social cost times 1990 emissions for each greenhouse gas.  One example of narrative-driven value judgement is the global warming potential (GWP) time horizon.  This parameter weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame.  Most jurisdictions use a 100-year GWP time horizon but the CLCPA law mandates the use of the 20-year GWP.   As a result, methane reductions associated with natural gas are valued three times higher as shown in Section 2.

The biggest driver of social costs from greenhouse gases is the discount value which is used to estimate how much money invested today would be worth in the future so that we can link today’s costs to the future.  It is accepted that there is no consensus or uniform scientific basis for the selection of a discount rate. The CLCPA implementation process claims to follow the “science” but it appears that is only when it is consistent with their narrative to maximize the benefits of reductions.  For example, the Obama Administration Integrated Working Group (IWG) chose a central value 3% and only published results down to 2.5% but New York chose to use 2% as the central value which results in social costs over two times larger (Section 3).

In order to consider the effect of other parameters, I calculated social benefits values based on different assumptions derived from testimony before the U.S. House of Representatives Subcommittee on Environment Committee on Oversight and Reform by Kevin D. Dayaratna.  Section 4 lists his estimated benefits using the same assumptions as the IWG.  I calculated the % reduction between Section 4 and each of the different assumptions and applied the resulting percentage reductions cumulatively to the Section 3 benefits.

Part of the argument for using a lower discount rate is that it helps protect our children and grandchildren but the Guidance calculates future net damages out 300 years, many generations away.  Moreover, it is an act of extreme hubris to claim that any projection of how the world will operate in 100 years, much less 300 years, should be used to guide current actions simply because no one could have imagined the technology available in today’s society one hundred years ago.  If the economic impacts are only considered out 150 years the social costs are reduced 14%. (Section 3 benefits times (1- 14%))

The entire rationale for the CLCPA is that there is a climate emergency threat to society because of climate change due to greenhouse gas emissions.  The process does not recognize that the climate models used to predict this future are not without shortcomings.  One way to minimize modeling uncertainty is to use historical data to estimate climate sensitivity to greenhouse gases and, as shown here, that can reduce impacts 48%.

New York chose to calculate world-wide benefits of reductions because climate change is a global problem.  It is a fact that climate change impacts will be felt most by countries that are too poor to be resilient.  However, I believe that anyone having trouble paying energy bills today would be hard pressed to accept the higher costs imposed by the CLCPA if they know that their descendants will derive little benefit from today’s sacrifices.  Considering only benefits that would accrue to the United States from reductions instead of global benefits reduces the value of carbon 86%.

To sum up, greenhouse gas emission reductions under the CLCPA using the recommended assumptions are supposed to provide benefits of $668 billion.  Using the Obama Administration recommended assumptions the benefits go down to $201 billion.  At the extreme end of value and scientific judgements the benefits are as low as $12.5 billion.

Ultimately, the value of carbon methodology relies on a complex causal chain from carbon dioxide emissions to social impacts that are alleged to result from those emissions.  Richard Tol testified that these connections are “long, complex and contingent on human decisions that are at least partly unrelated to climate policy. The social cost of carbon is, at least in part, also the social cost of underinvestment in infectious disease, the social cost of institutional failure in coastal countries, and so on.”  The fact is that this process focuses exclusively on negative externalities and completely ignores the benefits of fossil fuels.  I believe these facts make this a contrived process.

One final point.  After all these machinations, the social cost values chosen when applied to the 1990 baseline emissions indicate that reducing those emissions will result in $668 billion in benefits.  The Climate Action Council is charged with developing an implementation plan that should include costs.  What happens if those costs are greater than these benefits?

Greenhouse Gas Reduction Benefits Estimates

This section describes the methodology used to calculate the values shown in Table 1.

The Climate Action Council plans to multiply the values of CO2 in the Guidance document by CO2 emissions to come up with “benefits”.  Table 2, NY Social Cost of CO2 Value of Reductions ($millions), lists the recommended 2020 values for CO2, the DEC Part 496 CLCPA baseline emissions, and the total benefits for completely eliminating 1990 emissions (multiplies the Guidance values by the emissions). It shows how differences in the assumptions changes the potential benefit costs for CO2 for three different discount rates.  In the absence of a recent estimate of New York CO2 emissions I used the DEC official baseline 1990 value of 264.8 million metric tons of CO2 to estimate the potential benefits. Using the 2020 value of carbon dioxide of $53-421 per ton, with a central value of $125 per ton and the 1990 emissions the benefits of eliminating those emissions ranges between $111.5 billion and $14.0 billion with a central value of $33.1 billion.

Table 2: Recommended NY Social Cost of CO2 Value of Reductions ($millions)

2020 Value of Greenhouse Gas Reductions
DiscountCO2CH4N2OPFCsHFCsSF6NF3
1%$421$6,578$140,766$421$421$421$421
2%$125$2,782$44,727$125$125$125$125
3%$53$1,527$19,084$53$53$53$53
1990 Statewide Greenhouse Gas Emissions (million metric tonnes)
GWPCO2CH4N2OPFCsHFCsSF6NF3
GWP20264.8134.195.830.90.054.010
GWP100264.839.946.591.360.025.220
Recommended Value of Carbon Benefits (millions)
DiscountCO2CH4N2OPFCsHFCsSF6NF3Total
2%$33,100$373,317$260,758$113$6$501$0$667,795

The first, and arguably, the biggest judgement that has to be made when the values are developed is the economic discount rate.  According to the Guidance document “Discounting is a common and useful aspect of economic analyses that allows for the balancing of present versus future value and it has been widely discussed in the literature, particularly in its application to the federal social cost of carbon. However, the selection of the discount rate has a large effect on the estimate of the value of carbon, and there is no consensus or uniform scientific basis for the selection of a discount rate.”  I emphasized the key point that there is no consensus for selecting the discount rate chosen.   The discount price chosen boils down to value judgements on the part of the State and the model developers.

During the January 19, 2021 Climate Action Council meeting, Jared Snyder, New York Department of Environmental Conservation Deputy Commissioner for Air Resources, Climate Change, & Energy, described the NY Value of Carbon Guidance and talked about the discount rate choices.  I tried to transcribe his comments but did edit out superfluous wording.   He stated that: “We proposed central values of 2 or 2.5% for public comment.  The Obama Administration did use 3% but a number of economists have indicated their views that 3% is somewhat too high and recommended looking at and establishing a value of carbon based on lower values.”   A key point is that the Integrated Working Group did a more thorough analysis of the discount rates and chose a central value that was not even proposed for comment.  The Guidance 2% value is $72 more per ton and results in increased benefits of over $19 billion compared to the IWG 3% value.  In my opinion the Guidance did not adequately justify their choice to deviate from the IWG expert analysis.

Snyder went on to say that based on information from various economists, “we moved towards the 2% range based on a view that impacts that occur significantly in the future that impact our children, grandchildren and the like, are still important and we did not want to discount those too much.”  He concluded “Informed by the economists and that value judgement we decided that 2% is an appropriate value”.  Snyder states that the discount rate values “impacts in the future versus impacts now”.  An alternative explanation is that the discount rate is used to estimate how much money invested today would be worth in the future so that we can link today’s costs to the future.  Snyder’s response is disingenuous because while it may be appropriate to value impacts today similar to impacts tomorrow for our children and grandchildren, the SCC valuation process considers impacts out to 2300.  According to the internet there are 25.2 years in a generation which means that benefits are being calculated for twelve generations, not exactly our children and grand-children.

There are two other aspects of the CLCPA law that directly affect the social costs.  In addition to CO2, the CLCPA mandates that other greenhouse gases should also be addressed: methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride (SF6).  According to the Guidance document, Global Warming Potential (GWP) weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame.  Contrary to every other jurisdiction the CLCPA mandates that the specified time frame is 20 years, while everyone else uses 100 years. EPA notes in  Understanding Global Warming Potentials that the ”20-year GWP prioritizes gases with shorter lifetimes, because it does not consider impacts that happen more than 20 years after the emissions occur”.

In order to consider the impacts of other greenhouse gases relative to CO2, the concept of equivalency is used. Carbon dioxide equivalence is “a simple way to normalize all these greenhouse gases and other climate influences in standard units based on the radiative forcing of a unit of carbon dioxide over a specified timeframe (generally set at 100 years)”.  The Guidance document found sufficient information to develop social cost values for methane and nitrous oxides so those numbers are used directly.  The CO2 equivalents are used in the subsequent analysis for hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3), which was included in the Part 496 inventory despite the fact that the numbers are listed as zeros.

Table 3 lists the values of carbon that New York included in the Guidance document, GWP-20 and GWP-100 for 1%, 2% and 3% discount rates.  The recommended central value benefits are $668 billion and the range of benefits goes from $201 billion to $1.86 trillion for all the greenhouse gases in the CLCPA.  Note that methane benefits are more than half of the total and an order of magnitude greater than the CO2 benefits. Using the 20-year GWP increases the benefits three times the 100-year GWP benefits. Nitrous oxide benefits are over seven times greater than carbon dioxide benefits.

Table 3: NY Social Cost of CO2 Value of Reductions ($millions)
CLCPA Social Cost Requirements – Value of Carbon Guidance Recommendations
2020 Value of Greenhouse Gas Reductions
DiscountCO2CH4N2OPFCsHFCsSF6NF3
1%$421$6,578$140,766$421$421$421$421
2%$125$2,782$44,727$125$125$125$125
3%$53$1,527$19,084$53$53$53$53
1990 Statewide Greenhouse Gas Emissions (million metric tonnes)
GWPCO2CH4N2OPFCsHFCsSF6NF3
GWP20264.8134.195.830.90.054.010
GWP100264.839.946.591.360.025.220
D.R.GWPCO2CH4N2OPFCsHFCsSF6NF3Total
1%GWP20$111,481$882,702$820,666$379$21$1,688$0$1,816,937
2%GWP20$33,100$373,317$260,758$113$6$501$0$667,795
3%GWP20$14,034$204,908$111,260$48$3$213$0$330,465
1%GWP100$111,481$262,725$927,648$573$8$2,198$0$1,304,633
2%GWP100$33,100$111,113$294,751$170$3$653$0$439,789
3%GWP100$14,034$60,988$125,764$72$1$277$0$201,136

Table 1, Alternative New York 1990 Value of GHG Reduction Benefits ($millions), lists seven scenarios that compare the reduction benefits as a function of different assumptions and value judgements.  The first section, CLCPA Value of Carbon Guidance 2% Discount & GWP-20, reproduces the recommended benefits from Table 2.  The second section, CLCPA Value of Carbon Guidance 2% Discount Rate & GWP-100, compares the differences in benefits when using the 100-year GWP commonly used.  Total benefits drop from $668 billion to $440 billion.  Using the IWG approach, 3% discount rate and 100-year GWP, the total benefits drop to $201 billion.  The only values I have for the IWG approach are for CO2.  To calculate the remaining gases, I made the crude assumption that their social costs would be proportional to the change in social costs of CO2 using values from the second section.

In the remaining analyses I calculate social benefits values based on different assumptions derived from testimony before the U.S. House of Representatives Subcommittee on Environment Committee on Oversight and Reform on September 24, 2020, by Kevin D. Dayaratna.  He used one of the primary integrated assessment models (DICE) used by the IWG to calculate SC-CO2 to calculate the social costs for different scenarios.  My derived values are rough estimates and I applied the reductions in each analysis to accumulate the impacts.  In order to refine the numbers, it is necessary to run multiple models thousands of times and that is way beyond my capabilities.

In the section of Table 1 labeled Dayaratna 300 year horizon, 3% Discount Rate Using GWP-100 (-70%) I list the his values for comparison to the IWG values in the third section.  There is the same issue for the other gases as described for the IWG section and I applied the same approach.

Recall that Snyder justified the 2% discount rate “based on a view that impacts that occur significantly in the future that impact our children, grandchildren and the like, are still important and we did not want to discount those too much.” Note however, that the economic modeling calculates cost impacts 300 years out. But because the impacts of climate change will become more evident further in the future the benefits of reductions today will be much more of a factor closer to 2300.  Dayaratna estimated the effect of the time horizon calculating the social costs out 150 years instead of the 300-year time horizon and found that assumption reduces societal benefits by 14%.

The effect of greenhouse gases on climate is a fundamental driver of the impacts and is another factor affecting the social cost estimates.  Equilibrium climate sensitivity (ECS) is the expected change in temperature when the atmospheric CO2 concentration doubles.  The IWG analysis depended upon outdated, model-derived ECS values.   In his testimony before the Environment Committee on Oversight and Reform on September 24, 2020, Dayaratna also estimated the effect of the ECS on the SC-CO2.  In section 6, he used an ECS estimate based on observed data and found that the benefits would be reduced 48%. 

Snyder’s presentation also noted that the benefits were calculated on a global basis because it is a global problem.  This is another value judgement and the public should be aware of the effect on the benefit values.  In 2017, President Trump signed Executive Order 13783 and Federal projects used social cost estimates based on the same approach as the IWG but differed in two aspects: the only damages that were considered were those in the United States and different values were used to convert to present costs.  A recent GAO report show that changing just those two variables results in very different damage estimates.  I estimate that would reduce benefits another 86%.

By using different value judgements and a different ECS value the $668 billion in societal benefits from greenhouse gas reductions under the CLCPA are reduced to $12.5 billion in benefits.

CO2 Methodology

For the summary analysis I considered all the greenhouse gases but that necessitates the crude assumption that their social costs would be proportional to the change in social costs of CO2.  This section provides a more-detailed description of my CO2 calculation methodology and the discussion of value of carbon cost effectiveness at the January 19, 2021 Climate Action Council meeting.  I suggest that this section is best used as a stand-alone reference to the previous text.

The Climate Action Council plans to multiply the values of carbon in the Guidance document by the greenhouse gas emissions to come up with “benefits”.  Table 4, NY Climate Social Cost of CO2 Value of Reductions ($millions), shows how differences in the assumptions changes the negative externality costs for CO2.  In the absence of a recent estimate of New York CO2 emissions I will use the DEC official baseline 1990 value of 264.8 million metric tons of CO2 to estimate the potential benefits.  The benefits are simply the 1990 emissions multiplied by the values of CO2.

Table 4: NY Social Cost of CO2 Value of Reductions ($millions)
DEC Value of Carbon Guidance 
 
1990 NY CO2 Emissions (million metric tonnes) 
264.8Per DEC Part 496
DiscountValueBenefit of Reductions
1%$421$111,481
2%$125$33,100
3%$53$14,034

According to the Guidance document “Discounting is a common and useful aspect of economic analyses that allows for the balancing of present versus future value and it has been widely discussed in the literature, particularly in its application to the federal social cost of carbon. However, the selection of the discount rate has a large effect on the estimate of the value of carbon, and there is no consensus or uniform scientific basis for the selection of a discount rate.”  I emphasized the key point that there is no consensus for selecting the discount rate chosen.   The price chosen boils down to value judgements on the part of the State.

During the January 19, 2021 Climate Action Council meeting, at 1:23:30 in the video of the meeting Jared Snyder, New York Department of Environmental Conservation Deputy Commissioner for Air Resources, Climate Change, & Energy, described the NY Value of Carbon Guidance.   Snyder explained that “one of the key issues in establishing the value of carbon is establishing a discount rate”.  He went on to say that refers to: ”How do you value impacts in the future versus impacts now?”. He claimed that if you value impacts now the same as impacts in the future you would apply a discount rate of zero.  He noted that in the past experts have looked at discounts in a range of 2% to 5% which values current impacts more than future impacts.  He explained that the Guidance considered a range of discount rates, including zero.  It recommends a central value of 2% ($125 per ton of CO2 in 2020 dollars) with an evaluation range of 1% to 3% ($421 –$53 per ton of CO2 in 2020.  As shown in Table 1 that translates into total benefits due to New York CO2 reductions of $33.1 billion at the central value with an evaluation range of $111.5 billion to $14.0 billion.

After Snyder’s presentation, Council member Bob Howarth asked for the justification of the choice of the discount value especially because the CLCPA mandates evaluation of a zero discount rate.  I tried to transcribe the response made by Snyder to this question but did edit out superfluous wording.   He stated that: “We proposed central values of 2 or 2.5% for public comment.  The Obama Administration did use 3% but a number of economists have indicated their views that 3% is somewhat too high and recommended looking at and establishing a value of carbon based on lower values.”   He went on to say that based on information from various economists, “we moved towards the 2% range based on a view that impacts that occur significantly in the future that impact our children, grandchildren and the like, are still important and we did not want to discount those too much.”  He concluded “Informed by the economists and that value judgement we decided that 2% is an appropriate value”. 

Snyder’s response does not give all the details.  Snyder states that the discount rate values “impacts in the future versus impacts now”.  An alternative explanation is that the discount rate is used to estimate how much money invested today would be worth in the future so that we can link today’s costs to the future.  Snyder states that the Obama Administration recommended a central value estimate of 3%.  The Guidance and supporting Memo discuss the discount rate and address some of the controversies associated with choosing a value.  The Guidance notes that “The federal IWG’s central value applies a 3 percent discount rate that is consistent with the economics literature and in the federal government’s Circular A-4 guidance for the consumption rate of interest” Neither mention that Circular A-4 guidelines state that all cost/benefit analyses are to be scored using both a 3% and a 7% discount rate.  Both the IWG and the Guidance document used their values to choose the rates used.

There are two other aspects of the CLCPA law that directly affect the social costs.  In addition to CO2, the CLCPA mandates that other greenhouse gases should also be addressed: methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride (SF6).  According to the Guidance document, Global Warming Potential (GWP) weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame.  Contrary to every other jurisdiction the CLCPA mandates that the specified time frame is 20 years, while everyone else uses 100 years. 

In order to consider the impacts of other greenhouse gases relative to CO2, the concept of equivalency is used. Carbon dioxide equivalence is “a simple way to normalize all these greenhouse gases and other climate influences in standard units based on the radiative forcing of a unit of carbon dioxide over a specified timeframe (generally set at 100 years)”.  The Guidance document found sufficient information to develop social cost values for methane and nitrous oxides so those numbers are used directly.  The CO2 equivalents are used in the subsequent analysis for hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3) which was included in the Part 496 inventory despite the fact that the numbers are listed as zeros. In testimony before the U.S. House of Representatives Subcommittee on Environment Committee on Oversight and Reform on September 24, 2020, Kevin D. Dayaratna estimated the effect of a wider range of discount rates.  He used one of the primary integrated assessment models (DICE) used by the IWG to calculate SC-CO2 to calculate the social costs for different scenarios.  As shown in Table 5 the range of total benefits based on different discount rates ranges by an order of magnitude from $1.5 billion to $15 billion. 

Table 5: NY Social Cost of CO2 Value of Reductions ($millions)
DICE Model Average SCC End Year 2300 
 
1990 NY CO2 Emissions (million metric tonnes) 
DiscountValueBenefit of Reductions
2.5%$56.92$15,072
3.0%$37.79$10,007
5.0%$12.10$3,204
7.0%$5.87$1,554

Snyder said that based on information from various economists, “we moved towards the 2% range based on a view that impacts that occur significantly in the future that impact our children, grandchildren and the like, are still important and we did not want to discount those too much.” The fact is that the in order to justify using a low discount rate people have to know that the Guidance methodology calculated cost impacts 300 years out and according to the internet there are 25.2 years in a generation which means that benefits are being calculated for twelve generations, not exactly our children and grand-children.  Proponents argue that because most of the warming caused by carbon dioxide emissions persists for many years, changes in carbon dioxide emissions today may affect economic outcomes for centuries to come.  This is described as leaving the world a better place for our grand-children. But because the impacts of climate change will become more evident further in the future the benefits of reductions today will not be a factor until further in the future.  Dayaratna estimated the effect of the time horizon calculating the social costs out 150 years instead of the 300-year time horizon.  Table 6 compares the time horizons using the same discount rates and shows that he found that using a 2.5% discount rate the 150 year time horizon total benefits would drop by 22% but at a 7% discount rate they only drop 0.3%. 

Table 6: NY Social Cost of CO2 Value of Reductions ($millions)
Comaparison of 300 Year and 150 Year Estimates
 
1990 NY CO2 Emissions (million metric tonnes) 
264.8Per DEC Part 496
DICE Model Average SCC End Year 2300
DiscountValueBenefit of Reductions
2.5%$56.92$15,072
3.0%$37.79$10,007
5.0%$12.10$3,204
7.0%$5.87$1,554
DICE Model Average SCC – End Year 2150
DiscountValueBenefit of Reductions
2.5%$44.41$11,760
3.0%$32.38$8,574
5.0%$11.85$3,138
7.0%$5.85$1,549

Snyder’s presentation also noted that the benefits were calculated on a global basis because it is a global problem.  This is a value judgement and in the interest of full disclosure the effects should be noted.  In 2017, President Trump signed Executive Order 13783 which, among other actions, disbanded the IWG and stated that the estimates generated by the Interagency Working Group were not representative of government policy.  Federal projects used social cost estimates based on the same approach as the IWG but differed in two aspects: the only damages that were considered were those in the United States and different values were used to convert to present costs.  A recent GAO report show that changing just those two variables results in very different damage estimates.  As shown in Table 7, at the common 3% discount rate, the prior federal estimate a was $50 but the current federal estimate is only $7.  The value of the reductions goes down from $13.2 billion to $1.9 billion.

Table 7: NY Social Cost of CO2 Value of Reductions ($millions)
Global vs Domestic Damages at 3% Discount Rate
ImpactsValueBenefit of Reductions
Global$50.00$13,240
Domestic$7.00$1,854

The effect of greenhouse gases on climate is a fundamental driver of the impacts and is another factor affecting the social cost estimates.  Equilibrium climate sensitivity (ECS) is the expected change in temperature when the atmospheric CO2 concentration doubles.  The IWG analysis depended upon outdated, model-derived ECS values.   In his testimony before the Environment Committee on Oversight and Reform on September 24, 2020, Dayaratna also estimated the effect of the ECS on the SC-CO2.  Table 8 shows using the Lewis and Curry 2015 ECS values (based on monitoring and not modeling) that in 2020 for a discount rate of 2.5%, the SC-CO2 is reduced 49% using a 300-year time horizon and that the reduction decreases for future estimates.   Using those values, the benefits of the reductions goes from $15.1 billion down to $7.7 billion at the 2.5% discount rate.

Table 8: NY Social Cost of CO2 Value of Reductions ($millions)
DICE Model Average SCC – ECS Distribution Updated in
 Lewis and Curry (2015), End Year 2300
DiscountValueBenefit of Reductions
2.5%$28.92$7,658
3.0%$19.66$5,206
5.0%$6.86$1,817
7.0%$3.57$945
DICE Model Average SCC End Year 2300
DiscountValueBenefit of Reductions
2.5%$56.92$15,072
3.0%$37.79$10,007
5.0%$12.10$3,204
7.0%$5.87$1,554

Climate Leadership and Community Protection Act Energy Efficiency and Housing Advisory Panel Initial Recommendations

As part of the implementation process of the Climate Leadership and Community Protection Act, on February 4, 2021 Energy Efficiency and Housing Advisory Panel had a public engagement session.  The agenda included their preliminary draft recommendations that are under consideration.   This post presents those recommendations with minimal comment.  I believe that most New Yorkers have no clue about the Climate Act, much less what will be required to meet the target goals.  These recommendations ought to be a wakeup call to them.

The Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Requirements and have also developed a summary of the implementation requirements.  In addition, I have written extensively on various aspects of the law.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone

Preliminary Draft Recommendations

The summary of the recommendations included six slides.  The screen captures of each slide is shown below with a few brief notes. Update 2/6/21: The meeting presentation with these slides is available here.

There have been similar strategies proposed for some cities but the recommendation to ban gas/oil for space heating, water heating, cooking and dryers for an entire state is a first.  I doubt that many in New York have any inkling that this is seriously being considered.

This strategy is for multi-family apartment buildings as well as commercial and industrial buildings.  

If they go through with these strategies then a lot of workers will be required but any claims about the number of jobs should be sure to consider the jobs lost too.

My particular concern is home heating and the transition away from fossil fuel options.  According to the most recent NYSERDA Patterns and Trends document in 2016 NYS residential fuel use was 75% fossil fuels.  The same document notes that there were 7,209,054 occupied housing units and 6,061,315 or 84% of them used fossil fuels for space heating.  If non-fossil fuel alternatives were cheaper, then those percentages would be smaller. Even access to “low-cost capital” comes at a price.  How much is needed and where will it come from?

The costs of these programs is going to be huge and this strategy does not include the cost of electrical service upgrades in neighborhoods.  When heating and transportation is electrified it is unlikely that existing distribution networks will be able to handle the loads without upgrades.

Every Advisory Panel includes anti-natural gas ideologues amongst its membership.  The language in this strategy reflects that.  I also think this obsession to get rid of fossil-fuel heating sources will lead to much greater reliance on wood-fired stoves for heat.  If that comes to pass the public health impacts will be much greater than the health impacts alleged to be associated with natural gas and oil.

Conclusion

When I was growing up during the 1950’s I remember the excitement when natural gas came to town so that my family no longer had to deal with maintaining our coal-fired furnace fire, dealing with the ashes and having a coal bin in the basement.  My first house had an oil-fired furnace and I do not miss dealing with an oil tank in the basement and worrying about oil deliveries.  Natural gas is simply more convenient and cleaner than other alternatives.  As a result, I like natural gas for heat, hot water, cooking, drying clothes, and, I even have a whole-house generator powered by natural gas.  In addition to cost savings, I am not comfortable that an all-electric home would protect my family in the event of a prolonged power outage.  In the last 40 years we have only had a couple of multi-day outages but we survived because we had access to natural gas. 

Frankly I was taken aback by these recommended strategies.  I have been following this implementation process and it was clear that fossil fuels would have to be banned but seeing that spelled out still was a shock.  In the introduction I said that I thought most people have never heard of the CLCPA much less had any idea of what would be required to meet the law’s mandates.  When people start hearing about these plans, I imagine enormous pushback.  I can only hope.  

Politics and Global Warming Poll

A recent survey claims that there is wide support for policies to combat climate change by developing “clean” energy.  I am very cynical about polls in general and climate polls in particular.  This post poses some questions about the survey results.

Background

The Politics & Global Warming poll[1] was performed by the researchers from the Yale Program on Climate Change Communication and the George Mason University Center for Climate Change Communication.    According to the Executive Summary:

“Drawing on a nationally representative survey (N = 1,036; including 949 registered voters), this report describes how registered voters view a variety of climate and energy policies. This survey was fielded from December 3 – 16, 2020 – after the results of the 2020 U.S. presidential election were known, but before control of the U.S. Senate was determined. This executive summary reports the results from all registered voters, while the report breaks the results down by political party and ideology.

    • 53% of registered voters say global warming should be a high or very high priority for the president and Congress.
    • 66% of registered voters say developing sources of clean energy should be a high or very high priority for the president and Congress.”

In the Executive Summary I count percentage results for 62 questions.  The report breaks down the results from questions in more detail, but the complete survey text is not included as far as I can tell. There are questions included in graphical results but I believe that there had to be some explanatory text too.  Given the volume of material included in this survey I believe it is expecting a lot to expect respondents to have enough knowledge of the topics to give educated responses.  If the survey does provide background information, that is where the biases of the survey developers could easily affect the results.  If not, then respondents have to depend on sound-bite news stories.  There is nothing in this poll that reduces my cynicism of climate polls.

Premise of the Survey

Section 2, Support for Policies to Reduce the Pollution that Causes Global Warming, describes questions related to strategies to address climate change.  There is an implicit presumption that we understand the reasons for climate change well enough to be able to say climate mitigation policies could actually affect global warming.  If there was any expository text introducing these questions, I am sure that it followed the politically correct meme that there is a climate crisis and we have to act now to save the earth from thermal Armageddon.

What if the respondents were to hear the other side of the story?  In a recent interview Judith Curry described the climate models used to generate the scary stories used to justify the policies:

“However, the most consequential applications of climate models are to tell us what caused the 20th century climate change, how much the climate change is going to change in the 21st century and what’s causing extreme weather events. I mean, those are the more consequential applications and climate models aren’t fit for any of those purposes. And that’s pretty much acknowledged even in the IPCC report. Well, they, they do claim that they can attribute the global warming, but this can’t be easily separated from the natural variability associated with large-scale ocean circulations. And the way they’ve used climate models to do that involves circular reasoning, where they throw out climate simulations that really don’t match what was observed. So, you, you end up, even if you’re not explicitly tuning to the climate record, you’re implicitly tuning. And then the thing with extreme events, weather events is beyond silly because these climate models can’t resolve the extreme events and they can’t simulate the ocean circulation patterns that really determine the locations of these extreme events. And then when you start talking about 21st century, the only thing they’re looking at is the manmade human emissions forcing, they’re not predicting solar variability.”

Paris Climate Agreement

The first subsection stated that “There is bipartisan support for U.S. participation in the Paris Climate Agreement”.  The text states:

“In December, 2015, officials from 197 countries (nearly every country in the world) met in Paris at the United Nations Climate Change Conference and negotiated a global agreement to limit global warming.  On Earth Day, April 2016, the United States and 174 other countries signed the agreement, with all of the other countries following suit. On June 1, 2017, President Trump announced that the United States would withdraw from the agreement, and on November 4, 2020, the day after the U.S. presidential election, the U.S. formally withdrew. President-elect Biden has announced that the U.S. will re-join the agreement soon after Biden’s inauguration on January 20, 2021.”

I have to assume that this text was used in the survey.  There is nothing factually incorrect in this explanation but for a public that has no clue it also does not provide the full story.  Bjorn Lomborg recently pointed out that “Climate change, according to Biden, is “an existential threat” to the nation, and to combat it, he proposes to spend $500 billion each year on climate policies — the equivalent of $1,500 per person”.  He goes on to explain that the agreement will not materially affect global warming itself and that increases in emissions in countries without Paris Agreement commitments will quickly overwhelm any reductions made in the United States.

In Appendix I: Data Tables, the specific question was quoted:

“In 2015, the United States signed an international agreement in Paris with 196 other countries to limit the pollution that causes global warming.  Do you strongly support, somewhat support, somewhat oppose, or strongly oppose the U.S.’s participation in the Paris Agreement?”

The report claims that:

“Three in four registered voters (75%) support U.S. participation in the Paris Climate Agreement, but support varies by party. Nearly all liberal Democrats (97%) and moderate/conservative Democrats (93%) support U.S. participation, as do seven in ten liberal/moderate Republicans (71%) and Independents (70%). About four in ten conservative Republicans (44%) also support U.S. participation in the Agreement.”

If the Lomborg’s background information were provided then I do not believe there would be as much support for the Agreement.

Green New Deal

The report states “A majority of registered voters support a ‘Green New Deal’”, but does admit that “only 18% say they have heard ‘a lot’ about it.”  The Section 2 documentation notes:

“As we reported in 2019, a majority of registered voters support the policy aspirations included in the Green New Deal, although support decreased during the time period between December 2018 and April 2019, particularly among conservative Republicans and regular viewers of the Fox News Channel.  The description of the policy was summarized based on a 2018 policy report: “the Green New Deal will produce jobs and strengthen America’s economy by accelerating the transition from fossil fuels to clean, renewable energy. The Deal would generate 100% of the nation’s electricity from clean, renewable sources within the next 10 years; upgrade the nation’s energy grid, buildings, and transportation infrastructure; increase energy efficiency; invest in green technology research and development; and provide training for jobs in the new green economy.”

Again, I have to assume that this text was used in the survey.  For anyone who has not heard a lot about the Green New Deal summarizing it based on a report from Data for Progress, “a multidisciplinary group of experts using state-of-the-art techniques in data science to support progressive activists and causes” clearly is going to hear only one side of the story.  A complete description would explain the following.  The conversion from fossil fuels to “clean” energy has negative consequences that are overlooked in the simple “clean” description.  It is impossible to convert 100% of the nation’s electricity to clean, renewable energy in ten years by any rational evaluation.  In addition to the technical considerations, costs will be enormous.

In that light of the biased information provided the survey’s findings are not surprising:

“As of December 2020, about two in three registered voters (66%) support the Green New Deal as described above, including a large majority of liberal Democrats (91%) and conservative/moderate Democrats (86%). About six in ten liberal/moderate Republicans (59%) but fewer conservative Republicans (24%) also support the Green New Deal.”

“About one in five registered voters (18%) have heard “a lot” about the policy proposal called the “Green New Deal” (see section 2.12 for a description of the policy). This represents an increase of 15 percentage points since this question was first asked in December 2018. Conservative Republicans were most likely to have heard “a lot” about the Green New Deal (27%), followed by liberal Democrats (23%).”

“Overall, relatively few registered voters have heard a lot about the Green New Deal, which suggests that opinions about the proposal may continue to change over time.”

I agree with the authors of this survey that opinions about the Green New Deal may continue to change over time but I suspect that if the short-comings of the policy and costs become known that the support for it will plummet.

Conclusion

Organizations with the name “Climate Change Communication” in their names are necessarily dependent upon climate change being a problem.  So, it is not surprising that the survey was constructed to get answers supporting their pre-conceived outcome that there is wide support for policies to combat climate change by developing “clean” energy.  However, if respondents who admit to having little knowledge about the topics in the poll are given both sides of the story, I believe the results would be much different.  Nonetheless expect advocates to use this poll to justify action.

[1] Leiserowitz, A., Maibach, E., Rosenthal, S., Kotcher, J., Carman, J., Wang, X, Goldberg, M., Lacroix, K., & Marlon, J. (2021). Politics & Global Warming, December 2020. Yale University and George Mason University. New Haven, CT: Yale Program on Climate Change Communication

 

Climate Leadership and Community Protection Act Environmental Justice Tradeoffs

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

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

Background

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

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

NYC PM2.5

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

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

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

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

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

Environmental Justice Hypocritical Tradeoffs

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

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

 

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

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

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

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

In short, it is a disaster area.

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

Conclusion

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

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

My Accelerated Renewable Energy Growth and Community Benefit Act Comments on the Power Grid Study

On January 19, 2021 the New York State Department of Public Service (DPS) submitted the Initial Report on the Power Grid Study (“Power Grid Study”) prepared pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA).   The AREGCBA legislation is intended to ensure that Climate Leadership and Community Protection Act (CLCPA) renewable generation is sited in a timely and cost-effective manner.  The primary purpose of the Power Grid Study is to “inform planning for the bulk transmission and local transmission and distribution (T&D) investments that will be necessary to achieve the clean energy mandates established under the CLCPA”. In order to achieve those mandates and maintain the same level of reliability as the existing system, somebody, somewhere has to provide transmission grid ancillary services.  Because none of those reports addressed the requirement for those services, I submitted comments to the DPS.  This post documents those comments for future reference.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

I do not understand why the transmission grid ancillary services described here have not been addressed. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism.  New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide the necessary grid ancillary support.

Some, but not all of the disadvantages of solar and wind energy in this regard can be mitigated through electronic and mechanical means. When these renewable resources only make up a small percentage of the generation on the system, it is not a big deal. The system is strong enough that letting a small percentage of the resources that don’t provide those services to lean on the system. But as the penetration of solar and wind energy increases the system robustness will degrade and reliability will be compromised without costly improvements.  A renewable system could be coupled with extensive batteries and other storage devices, large mechanical flywheels and condensers (basically an unpowered motor/generator that can spit out or consume reactive power). These devices could approximate the behaviors of our conventional power system.

My particular concern is that so far, the CLCPA process has only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available.    Unfortunately, the reports in the Power Grid Study primarily considered bulk transmission and T&D investments related to capacity needs. As important as those investments are, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not adequately discussed in the Power Grid Study that is supposed to inform the CLCPA implementation process.

Comments         

I am only going to summarize my comments in this post.  The comments and a previous post provide more details.

The comments were based on my review of four reports in the Power Grid Study to see if the ancillary transmission grid services necessary to keep the grid operating were considered:

        • Initial Report on the New York Power Grid Study;
        • Appendix C: Utility Transmission & Distribution Investment Working Group Study;
        • Appendix D: Offshore Wind Integration Study; and
        • Appendix E: Zero-Emissions Electric Grid in New York by 2040 Study.

I checked these reports in two ways.  First, I reviewed the approaches and then I searched the documents for specific references to these services.

I extracted the study approaches for the Initial Report and Appendices C, D, and E.  In my opinion, there is no indication that any of the approaches included this problem as part of their charge.  It also appears that the guidelines established by the PSC in its May 2020 Order that do not include a charge to look at these services.

The other screening methodology I used was a term search of the documents.  I searched documents for terms that I believe should be associated with the ancillary services requirement.  I used the following search terms: “Synchro”, “Ancillary”, “Frequency”, “Inertia”, “Reactive” and “Vars”.

In the Initial Report I found several cursory references to the ancillary services challenge.  Static synchronous series compensators were mentioned because they offer the operating flexibility to avoid congestion in meshed networks and provide an effective solution to congestion that may arise from variable renewable energy. There were two references to the fact that Smart Inverters can provide ride-through capability for frequency and voltage fluctuations that would typically trip the inverters and can regulate the use of ancillary services that may be provided by solar or storage devices.  However, the full extent of this challenge was not addressed.

The Utility Transmission & Distribution Investment Working Group Study was the only report that included a section of the report that actually addressed the problem.  in a section on potential technology solutions that included “Energy storage for T&D services”.  It addressed ancillary services beyond energy storage:

“Energy storage is increasingly being considered for many transmission and distribution (T&D) grid applications to potentially enhance system reliability, support grid flexibility, defer capital projects, and ease the integration of variable renewable generation. Central to the State’s policies and mandates is the need to enhance power system flexibility to effectively manage renewable energy deployment and the associated increase in variability. As power systems begin to integrate higher penetrations of variable, renewable, inverter-based generation in place of conventional fossil-fuel fired synchronous generation, grid-scale energy storage could become an increasingly important device that can help maintain the load-generation balance of the system and provide the flexibility needed on the T&D system. Pumped hydro storage (PHS) and compressed air energy storage (CAES) are long-established bulk energy storage technologies.”

Utility-scale lithium-ion battery storage has expanded dramatically, as decreasing lithium-ion battery costs make this an increasingly cost-effective solution to meet T&D non-wire, reliability, and ancillary service needs. Redox flow batteries, sodium sulfur batteries, thermal energy storage (both latent and sensible heat), and adiabatic compressed air energy storage are all in various stages of demonstration. This information provides a concise overview of a wide variety of existing and emerging energy storage technologies being considered for T&D systems. It describes the main technical characteristics, application considerations, readiness of the technology, and vendor landscape. It also discusses implementation and performance of different energy storage technologies. In this Report, energy storage systems greater than 10 MW and four or more hours of duration, are considered as bulk and transmission and sub- transmission-connected energy storage.

Two of the eight utilities participating in the report included specific projects related to these ancillary services.  However, the study did not quantify the risks of adverse inverter-based resource behavior or voltage instability in general and only LIPA included specific projects to address that problem.  Clearly, someone has to quantify these risks.

The Offshore Wind Integration Study was primarily focused on the narrow scope of getting offshore wind into the New York grid.  Most of the references to these terms were in the context of transmission capacity not transmission support.  In connection to the costs, it was mentioned that the cost of each offshore wind project could be impacted by certain specific cost drivers such as required ancillary services.

I reviewed Zero Emissions Study the same way.  According to the findings of the report:

“Based on the analysis carried out in the study, New York State should be able to achieve its 70 x 30 and zero-emission generation by 2040 goals under both the Initial Scenario and the High Demand Scenario using a mix of distributed energy, energy efficiency measures, energy storage, planned transmission projects, utility-scale renewables, and zero-emission resources. The most significant difference in these scenarios was the amount of renewable generation added and the scope (transmission capacity increases) of the transmission projects required to manage congestion and reduce costs.”

Note that this summary described transmission capacity increases but did not mention the ancillary support services requirements.  I found no references that addressed reactive power (vars), inertia, or regulation of the system frequency, but they did mention the ramping adequacy ancillary service.   Given that achieving the CLCPA goals will require these ancillary services and the report did not address the problem the conclusion that New York should be able to achieve the goals is unsupportable.

Conclusion

My particular concern is that other venues of the CLCPA process have also only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available.    The Power Grid Study was concerned about the related issue of transmission capacity and availability to support the renewable energy resources projected.  Unfortunately, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not discussed in sufficient detail to acknowledge the problem in three of the reports included in the Power Grid Study that is supposed to inform the CLCPA implementation process.  Instead, all but Appendix C: Utility Transmission & Distribution Investment Working Group Study ignore or dismiss these services.

The future CLCPA electric system that will be dependent upon wind and solar resources has to be coupled with other devices that can approximate the behaviors of our conventional power system in order to get the power where it is needed.  This is a significant shortcoming in the CLCPA process that must be addressed.  The conclusion from these reports that New York State should be able to achieve the 2040 CLCPA targets is not based on adequate analysis.  The transmission grid ancillary services needed for a wind and solar powered electric system issue must be addressed to determine feasibility.

Climate Leadership and Community Protection Act Borrego Solar Rutland Center Solar 1 Project

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The subject of this post is the Borrego Solar Rutland Center Solar One 110-megawatt solar facility in the Towns Rutland and Watertown, Jefferson County, New York.

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

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

Rutland Center Solar

My problem with this project is not the development itself but the lack of planning associated with the headlong rush to develop renewable energy to support the CLCPA.  At the 19 January 2021 Climate Action Council meeting the meeting presentation announced that “New York has made the largest combined renewable energy awards ever by a U.S. State”.  New York’s 2020 renewable energy standard solicitation includes 22 new large-scale renewable energy projects shown in the following map.  The thing that prompted this post is the location of the 110 MW Rutland Center Solar One project due east of Lake Ontario in the north central part of the state.

Anyone who knows anything about the weather at the eastern end of Lake Ontario knows where I am going with this post.  While it is not in the bullseye of the peak lake-effect snow area, the following map shows that it is darn close.  I am a meteorologist who has lived in and studied the lake-effect weather region of Central New York.  Because Lake Ontario does not freeze over in the winter anytime cold air crosses the relatively warm water clouds form if you are lucky and if you are not lucky it snows.  Of course, there are other factors that affect these storms but the key point is that the amount of snow is maximized by the time the upstream air spends over the lake so the eastern end is the optimal location for Lake Ontario lake-effect snow.  There is one other aspect and that is orography or elevation also increase snowfall amounts and the Tug Hill Plateau is at the eastern end of the lake squarely under the bullseye.

According to Wikipedia, the town of Rutland, New York has an elevation of 978’ as compared to Lake Ontario at 243’.  I could find no information about the solar project to determine exactly where it is supposed to go.  As you can see in the snowfall map there is a strong gradient of snowfall from the yellow (120 to 125”) to the pink (>200”).  Given the elevation difference of Rutland above the Black River Valley I believe that this solar center is affected by this orographic effect and is in the 150” of average snowfall per year area.

The problem with the lack of feasibility planning in the CLCPA is that they have not addressed the multi-day winter doldrum period when wind and solar are at their lowest expected availability.  There is a rush of solar energy projects that no doubt make headlines that New York has made the largest combined renewable energy awards ever by a U.S. State.  However, if those solar projects do not provide any power for the worst-case period then it might not be the best investment that New York can make.  Of course, the solar availability is even lower if the solar panels are covered by snow and it sure looks like the Rutland Center location is going to have that problem.

In conclusion, the CLCPA implementation process has to start looking at the big picture of how electricity will be produced during the multi-day winter doldrum because that might guide renewable energy investments.  If a project cannot provide any support during those periods it may not be appropriate to support.

Climate Leadership and Community Protection Act Transmission Ancillary Services – Somebody Else’s Problem

UPDATE January 24, 2021:  After posting this I prepared a comment for the New York Department of Public Service Case 20-E-0197 – Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act addressing the Power Grid Study.  I provide this update to note that there was a fourth document in the reports discussing offshore wind but that the report also did not address the problem described here.

On January 19, 2021 the New York State Department of Public Service (DPS) submitted the Initial Report on the Power Grid Study (“Power Grid Study”) prepared pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA).   The AREGCBA legislation is intended to ensure that Climate Leadership and Community Protection Act (CLCPA) renewable generation is sited in a timely and cost-effective manner.   In order for an electric energy grid powered primarily by renewable energy resources to maintain the same level of reliability as the existing system, somebody, somewhere has to provide transmission grid ancillary services.  However, none of the three reports provided in the documentation address the problem apparently because it is somebody else’s problem.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

First let me describe transmission grid ancillary services. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism.  New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support.

Some, but not all of the disadvantages of solar and wind energy in this regard can be mitigated through electronic and mechanical means. When these renewable resources only make up a small percentage of the generation on the system, it is not a big deal. The system is strong enough that letting a small percentage of the resources that don’t provide those services to lean on the system. But as the penetration of solar and wind energy increases the system robustness will degrade and reliability will be compromised without costly improvements.  A renewable system could be coupled with extensive batteries and other storage devices, large mechanical flywheels and condensers (basically an unpowered motor/generator that can spit out or consume reactive power). These devices could approximate the behaviors of our conventional power system.

My particular concern is that the CLCPA process has only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available.    Importantly, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not adequately discussed in two of the reports included in the Power Grid Study that is supposed to inform the CLCPA implementation process.

Discussion

As far as I have been able to see this component of the future electric system has not been addressed by the CLCPA implementation process.  I have reviewed two processes to determine if it is being considered.  The Power Generation Advisory Panel that is supposed to develop recommendations for the Scoping Plan that will guide implementation of the changes to the electric system needed to meet a goal of zero emissions by 2040.  In my review of their strategy recommendations, I found that they did not mention the problem.

The second process and focus of this post is the Power Grid Study.   According to the Executive Summary:

“Transmission & Distribution (T&D) infrastructure will play a critical role in meeting the State’s goals by connecting new renewable resources to the grid and transmitting and delivering energy to consumers.  Accordingly, the recently enacted Accelerated Renewable Energy Growth and Community Benefit Act directs the Public Service Commission (PSC) to advance the work of identifying T&D upgrades needed to reliably and cost-effectively integrate the required renewable resources, and to establish planning processes to support cost-effective and timely infrastructure development.”

“To meet these directives, the PSC, through the Department of Public Service, initiated a set of system studies, collectively referred to as the Power Grid Study, which is the subject of this Initial Report. The PGS consists of three components, each of which is included in this Report:

          • A study conducted by the Joint Utilities1 on local transmission and distribution (LT&D) needs (Utility Study);
          • A study of offshore and onshore bulk-power transmission infrastructure scenarios, and related environmental permitting considerations, to illustrate possible solutions to integrate the mandated 9,000 MW of offshore wind (OSW generation by 2035, sponsored by the New York State Energy Research and Development Authority (NYSERDA) and conducted by DNV-GL, PowerGem, and WSP (OSW Study)
          • A state-wide scenario-based study to analyze transmission, generation, and storage options for achieving 70% renewable generation by 2030 and a zero emissions grid by 2040, sponsored by NYSERDA and conducted by Siemens (Zero Emissions Study).”

Given the importance of the transmission grid ancillary services needed to keep the lights on I assumed that they would be addressed in the Power Grid Study documents.  Collectively these documents are huge so instead of reading each one to determine if these services were included, I searched them.  I used search terms that I believe should be associated with this requirement.  I used the following search terms: “Synchro”, “Ancillary”, “Frequency”, “Inertia”, “Reactive” and “Vars”.

When I used those search terms in the study of offshore and onshore bulk-power transmission infrastructure scenarios, the only relevant references mentioned static synchronous series compensators and smart inverters.  Those were passing references to specific kinds of equipment and did not address the scope or magnitude of the services necessary to maintain reliability.   I believe this indicates that this study does not adequately address this issue

I also reviewed the Utility Study in the same way and in that report found relevant references.  Eight utility companies proposed plans for local transmission and distribution systems to meet the CLCPA requirements and two included projects targeted to address these ancillary services.  The Long Island Power Authority (LIPA) identified a “potentially major issue on the transmission system with the significant increase of inverter-based resources (IBR) and concurrent retirement of conventional fossil power plants is the weakness of the system and the potential for adverse IBR behavior due to this weakness, as well as voltage instability.”  This is exactly the kind of issue that I believe needs to be addressed.  The report does not quantify this risk but explains that it is very likely that “new synchronous resources will be required (or alternatively, existing resources not being retired and run uneconomically) to strengthen the system such that these new IBR as well as the overall power system can operate in a stable manner.” LIPA included a proxy project for at least one synchronous condenser installation on their system.  Avangrid proposed Power Flow Control Devices at several locations including three (3) different technologies (Series Reactors, Phase Angle Regulators, and Static Series Synchronous Compensator devices).

In addition, the report raised the issue in a section on potential technology solutions that included “Energy storage for T&D services” that addressed ancillary services beyond energy storage:

“Energy storage is increasingly being considered for many transmission and distribution (T&D) grid applications to potentially enhance system reliability, support grid flexibility, defer capital projects, and ease the integration of variable renewable generation. Central to the State’s policies and mandates is the need to enhance power system flexibility to effectively manage renewable energy deployment and the associated increase in variability. As power systems begin to integrate higher penetrations of variable, renewable, inverter-based generation in place of conventional fossil-fuel fired synchronous generation, grid-scale energy storage could become an increasingly important device that can help maintain the load-generation balance of the system and provide the flexibility needed on the T&D system. Pumped hydro storage (PHS) and compressed air energy storage (CAES) are long-established bulk energy storage technologies.”

“Utility-scale lithium-ion battery storage has expanded dramatically, as decreasing lithium ion battery costs make this an increasingly cost-effective solution to meet T&D non-wire, reliability, and ancillary service needs. Redox flow batteries, sodium sulfur batteries, thermal energy storage (both latent and sensible heat), and adiabatic compressed air energy storage are all in various stages of demonstration. This information provides a concise overview of a wide variety of existing and emerging energy storage technologies being considered for T&D systems. It describes the main technical characteristics, application considerations, readiness of the technology, and vendor landscape. It also discusses implementation and performance of different energy storage technologies. In this Report, energy storage systems greater than 10 MW and four or more hours of duration, are considered as bulk and transmission and sub- transmission-connected energy storage.”

There were also several other general references to the ancillary services problem.  However, the study did not quantify the risks of adverse inverter-based resource behavior or voltage instability in general and only LIPA included specific projects to address that problem.  Kudos to the Utility Study for identifying the problem butsomeone has to quantify these risks.

I reviewed Zero Emissions Study  the same way.  According to the findings of the report:

“Based on the analysis carried out in the study, New York State should be able to achieve its 70 x 30 and zero-emission generation by 2040 goals under both the Initial Scenario and the High Demand Scenario using a mix of distributed energy, energy efficiency measures, energy storage, planned transmission projects, utility-scale renewables, and zero-emission resources. The most significant difference in these scenarios was the amount of renewable generation added and the scope (transmission capacity increases) of the transmission projects required to manage congestion and reduce costs.”

Note that this summary described transmission capacity increases but did not mention the ancillary support services requirements.  I found no references that addressed reactive power (vars), inertia, or regulation of the system frequency, but they did mention the ramping adequacy ancillary service.   Therefore, the claim that New York State should be able to achieve the targets is not based on adequate analysis.

Conclusion

There were three reports included in the Power Grid Study documentation.  The Power Grid Study itself did not address any of the component ancillary services issues.  The Utility Transmission & Distribution Investment Working Group Study broached the general problem but only two utilities offered projects to address related components of the problem.  The Zero-Emissions Electric Grid in New York by 2040 confidently claimed that New York should be able to achieve its zero-emission by 2040 goal but only mentioned ramping adequacy as a potential issue.  As a result, this documentation falls far short of what is necessary to guarantee the reliability of the electric system by 2040.  Those unaddressed requirements will lead not only to cost shifting where the total costs of fossil fuel alternatives have to be directly or indirectly subsidized by the public, but also reliability concerns because no electric grid anywhere has resolved these transmission grid ancillary services requirements and successfully maintained a grid that is as reliant on wind and solar resources as the proposed NY grid.

Given the vital importance of transmission ancillary services to maintain a reliable grid how can anyone explain that two out of three reports on the future grid don’t even mention the problem in any detail?  I could not help but notice that this situation is the same as the “Somebody Else’s Problem” phenomenon described by Douglas Adams in his novel Life, the Universe and Everything (in The Hitchhiker’s Guide to the Galaxy comedy science fiction series).  Adams describes the idea of an “SEP field” as a kind of cloaking device. The character Ford Prefect says: “An SEP is something we can’t see, or don’t see, or our brain doesn’t let us see, because we think that it’s somebody else’s problem. That’s what SEP means. Somebody Else’s Problem. The brain just edits it out, it’s like a blind spot.” The text then explains: “The Somebody Else’s Problem field… relies on people’s natural predisposition not to see anything they don’t want to, weren’t expecting, or can’t explain.”   I can only conclude that the authors of these reports didn’t address transmission ancillary services because it was somebody else’s problem.

Climate Leadership and Community Protection Act Power Generation Advisory Panel Strategies Comment

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

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

Power Generation Strategy Comments

I am disappointed by this panel’s strategies.  Arguably the strategies from this panel are the most important because a basic tenet of decarbonization is electrification of everything.  If the proposed strategies are not realistic then everything else fails.  I have no seen no sign that there is sufficient focus on strategies that address reliability and affordability of a completely transformed electric sector.

In a post on the peaking power plant problem in New York City I included a section on public policy concerns.  I have previously described how the precautionary principle is driving the CLCPA based on the work of David Zaruk, an EU risk and science communications specialist, and author of the Risk Monger blog.  In a recent post, part of a series on the Western leadership’s response to the COVID-19 crisis, he described the current state of policy leadership that is apropos to this panel.  He explains that managing policy has become more about managing public expectations with consultations and citizen panels driving decisions than trying to solve problems.  He says now we have “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”.  That is exactly what is happening on this panel in particular.  Facts and strategic vision were not core competences for the panel members.  Instead of what they know, their membership was determined by who they know.  The social justice concerns of many, including the most vocal, are more important than affordable and reliable power.  The emphasis on the risks of environmental justice impacts from the power generation sector is detracting from the need to develop a scoping plan that ensures affordable and reliable electricity.

It is not clear that the members even understand the enormity of the challenge.  I used the panel’s email address for public comments last October to suggest a workshop to explain how energy systems work and quantify how much energy is needed and where to provide reliable power to give the panel members a common basis.  I even included an overview of the energy system to show why the workshop is needed.  There is no sign that anyone on the panel is aware of my comments and there hasn’t been a workshop.  I naively believed that that the deep decarbonization workshop would address this need.  Unfortunately, the workshop did not provide any discussion of the reliability challenges.  Instead, the workshop mostly reinforced the notion that CLCPA targets will be met because of the political will of the State.  Long-duration energy storage is the key need and a presentation on that was useful but it did not address the availability or applicability to New York so it is not clear if there is a viable solution to this critical requirement in the timeframe needed.  The keynote, hydrogen, and carbon sequestration presentations all sound great superficially but no context relative to New York needs was given and they all have serious technological or implementation issues.

The panel organized itself into four sub-groups: equity, barriers, solutions for the future, and resource mix.  They presented ten strategies in the presentation to the Climate Action Council.  I address their strategies below.

The equity sub-group presented three strategies.  I don’t think these should be stand-alone strategies.  Instead, these concerns should be incorporated into strategies for the transition similar to how equity considerations were handled by all the other panels.

The first strategy addressed community Impact suggesting the development of recommendations to identify and proactively address community impacts relating to health concerns, access to renewables and energy efficiency, and siting.  Four equity concerns are described:

        • Reduce disproportionate impacts in overburdened communities (e.g. the operation of high emission power generation facilities result in significant health concerns for neighboring communities)
        • Consider means for increasing access to energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities
        • The siting of renewable projects and their potential impact on local communities both in the short and long term, particularly in rural areas
        • The impacts on communities (e.g. jobs, revenues, etc.) where energy facilities are being retired

The operation of high emission power generation facilities refers to peaking power plants which has become a rallying topic for environmental justice advocates.  Its inclusion confirms my suspicions that panel members need to be provided background information because there are some basic misunderstandings. I prepared and submitted a comment to powergenpanel@dps.ny.gov explaining that the presumption that these peaker plants are contributing to local health impacts because of ozone and particulate matter impacts is simply a wrong premise.  I described another problem in another comment that explained that there is a mis-understanding which New York City power plants are for peaking purposes and which ones are used for other services.

Considering means to increase energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities is also problematic.  This is a power generation strategy so energy efficiency is a different panel’s concern.  In my opinion if this is included then this approach for peaking power should have been a stand-alone strategy. The rationale is to provide equity but in order to do that there are technological challenges that have to be addressed.  There are so many challenges that it deserves its own focus but the naïve under-estimation of the challenges emphasized the goal itself over the implementation effort needed.  The remaining two equity concerns are non-controversial and could have been easily incorporated into other implementation strategies as necessary.

The second strategy is “Access and Affordability for all (Enabling) –Develop recommendations to ensure New Yorkers have access and can afford to participate meaningfully in NYS’s clean energy future”.  Inherent in this strategy is the belief that people want to be able to access clean energy presumably by participating in a community project if they cannot install solar panels at home.  Forgotten is the fact that ratepayers have had the opportunity to purchase “green” energy for years but that subscription to those offerings has always been low.  Overlooked is the fact that if participating means lower prices for participation in specific programs it also means that everyone not participating in those kinds of programs is footing the bill for everyone who does.  As long as there are any people with already unacceptable energy burdens this strategy may do more harm than good.

The final strategy from this subgroup is “Workforce Development (Enabling) –Develop recommendations to enable an equitable clean energy workforce”.  Again, this clearly is more appropriate as an equity concern in implementing strategies rather than as a stand-alone strategy.

The Barriers sub-group presented two strategies both of which should get higher priority than suggested by the presentation:

        • Clean Energy Siting
        • Energy Delivery & Hosting Capacity

Because the primary decarbonization strategy is electrification, clean energy siting is a primary consideration.  This sub-group listed eight issues to explore:

        • Optimizing new transmission builds
        • Collocated storage with renewable energy projects
        • Correctly designing clear and transparent price signals for both energy and interconnection costs
        • How to properly track progress and make course corrections as process progresses
        • Provide standardized property tax assessments for renewable projects
        • Encouraging more robust host community and PILOT plans to increase benefits for community members
        • Explore reducing timeframe and restrictions for siting on brownfields and unused industrial land
        • Siting projects closer to end user areas

The first four issues are fundamental implementation issues.  Because wind and solar energy is diffuse, transmission has to be developed to get it where it is needed.  Because wind and solar energy is intermittent, it is not dispatchable and energy storage is needed to get it when it is needed.  New York’s electricity system is de-regulated so the market will dictate whether these resources are developed.  The ambitious schedule of the CLCPA targets means that tracking progress is a fundamental requirement to achieve those targets.  I agree with them all.  The remaining four issues are less important because they address comparatively minor implementation concerns.

Energy delivery and hosting capacity is another primary consideration.  The sub-group listed six issues to consider:

        • Upgrading aging infrastructure and optimizing the location and operation of new transmission projects, including transmission of off-shore wind, and removing regulatory barriers that make optimization difficult
        • Upgrading the transmission system to be able to host more distributed energy resources
        • Easing interconnections on both the bulk and distribution levels
        • Energy delivery extends beyond transmission to include storage, especially as the saturation of intermittent resources increases
        • How should the economic tradeoff between new transmission, energy curtailment, and energy storage be considered
        • How to properly track progress and make course corrections as needed

All of these are fundamental consideration issues.  There is one glaring omission however.  Wind and solar energy produce asynchronous generation but the transmission grid is synchronous.  The need for ancillary services to provide that support must be included.

Solutions for the future addresses the fact that implementation of the CLCPA targets is pushing the limits of technological capabilities. Unfortunately I believe that is contrary to the presumption of many that meeting the goals is only a matter of political will.  Two issues were raised:

        • Technology and Research Needs
        • Market Solutions –Maximize the market participation of different technologies in a way that adds to system efficiency & send correct price signals to resources over time

The rational for technology and research noted that:

        • Adoption of new technology to enable CLCPA goals must be integrated with more traditional investments for continued safe and reliable operation of the grid
        • Timeframes for adoption of new technology on the electric grid must be accelerated from the typical timeline of 5+ years from initial commercial product availability to deployment at scale

Unfortunately, reality as expressed as a potential implementation challenge is that “demonstration and validation of technology frequently requires large scale projects in real world use cases that are both costly and require coordination of many entities.”  Clearly there is need for a feasibility study to determine what can be counted on from existing technology and what new technology is needed either for feasibility or affordability.  Last year the International Energy Agency (IEA) published “Special Report on Clean Energy Innovation” that concludes that innovation is necessary for jurisdictions to fulfill their de-carbonization targets.  The Energy Transition Plan Clean Energy Technology Guide summarizes 400 component technologies and identifies their stage of readiness for the market.  It should be used in a feasibility study to rate the potential availability of any technology proposed.

The other issue of market solutions should be a big concern.  New York’s electricity system is de-regulated so the market is expected to provide the necessary resources.  However, uncertainty is a problematic issue with investors.  As a result, new technology may require guarantees for market investors to provide the support that market advocates believe will appear.

The resource mix subgroup presented three strategies:

        • Growth of renewable generation and Energy Efficiency
        • Effectively Transitioning away from Fossil Fuel Energy Generation
        • Deploying Energy Storage and Distributed Energy Resources (DERs)

The rational for the first strategy sums up the basis for my concerns very well:

“The CLCPA requires 70% renewable electricity by 2030 and 100% carbon free electricity by 2040. We anticipate demand growth of 65% to 80%, dependent on the scale and timing of electrification and whether there are clean alternatives for transportation and buildings, such as bioenergy. The level of electrification needed to achieve GHG reduction goals will increase overall electric load and shift the system peak from summer to winter. There remains a large amount of renewables that must be procured and developed to reach the goals and NYS needs to incorporate flexibility and controllability as we electrify these sectors in order to create a more manageable system.”

As noted before, a feasibility study for the technology is needed. A primary prerequisite is an official estimate of the projected loads when other sectors are electrified.   However, I have an even more basic feasibility concern. As a party to the Department of Public Services (DPS) resource adequacy matters proceeding, docket Case 19-E-0530, I have submitted comments (described here and here) based on my background as a meteorologist who has lived in and studied the lake-effect weather region of Central New York.  Both E3 and the Analysis Group have done studies of the weather conditions that affect solar and wind resource availability in New York.  However, to my knowledge (neither consultant has ever responded to my question on this topic), they have not considered the joint frequency distribution of wind and solar or used solar irradiance data from the NYS Mesonet. In my opinion, both parameters have to be considered together and using airport data or models for cloud cover are inadequate.  The Mesonet data set is the only way to have information that adequately represents the local variations in cloud cover caused by the Great Lakes.  In order to adequately determine the combined availability of wind and solar I recommend using that data set for the renewable resource availability feasibility study.

The second strategy, “Effectively Transitioning away from Fossil Fuel Energy Generation” could be used as the outline for all the strategies of the panel.  The rationale states: “As renewable penetration increases, how do we transition away from fossil fuels while maintaining reliability and safety standards?”  The normal convention for priority ranking is to put the most important issues first in the presentation.  It is discomforting that this is placed ninth of the ten strategies.  It brings up the question just what are the priorities of this panel if reliability and safety concerns are ranked so low?

The final strategy from this workgroup was “Deploying Energy Storage and Distributed Energy Resources (DERs)”.  In my opinion, there was insufficient emphasis on technological feasibility in the discussion of energy storage in this strategy.  As mentioned earlier, a major shortcoming in these strategies is the lack of any mention of the need for transmission ancillary services.  There is recognition that long duration storage will be needed but the fact that the few large battery systems currently deployed are being used for ancillary services and not storage is an obvious barrier that has not been included.  Another concern I have with this strategy is that the definition of DER has changed to exclude distributed generation using fossil fuels.  Has anyone thought to ask the hospitals with DER systems whether they can put up with the limitations of renewable DERS for their obviously critical need for constant electric power?  An ice storm that knocks power off for days will quickly over-tax the capabilities of any renewable and energy storage system to keep a hospital running.

Missing Points

I have mentioned previously that the major missing point in these strategies is that ancillary services are not mentioned.  Someone, somewhere has to address the frequency control and reactive power needs of the grid.  Obviously, that has to be included in the strategies.  It goes beyond simply adding it to a strategy because it is not clear how those services can be incorporated into the market signal to provide them.  For example, there are advocates for a carbon price on electricity generation.  In this approach any generator that emits CO2 will have to include a carbon price in their bid which serves to provide the non-emitting generators with more revenue.  However, solar and wind generators are not paying the full cost to get the power from the generator to consumers when and where it is needed.  Because solar and wind are intermittent, as renewables become a larger share of electric production energy storage now provided by traditional generating sources will be needed but there is no carbon price revenue stream for that resource.  Because solar and wind are diffuse, transmission resources are needed but solar and wind do not directly provide grid services like traditional electric generating stations.  Energy storage systems could provide that support but they are not subsidized by the increased cost to emitting generators.  When the carbon pricing proposal simply increases the cost of the energy generated, I think that approach will lead to cost shifting where the total costs of fossil fuel alternatives have to be directly or indirectly subsidized by the public.  This result is not in the best interests of low-income ratepayers.

Funding and affordability considerations received short shrift from this panel.  In light of the fact that the New York Independent System Operator has proposed a carbon pricing initiative for the electric sector it would seem that a strategy to address that approach or something else should be included.  There is another aspect of affordability that should also be addressed.  The Department of Environmental Conservation recently released its guidance on the value of carbon.  Because the electric sector has documented control costs, this panel should include a strategy to determine if the marginal abatement cost approach should be used for recommendations to the Climate Action Council.

Conclusion

This was the only panel that included specific strategies to address environmental justice concerns.  All the other panels incorporated those concerns within their strategies and it would have been appropriate to do the same here.  It appears that the idealogues on this panel are more concerned about those concerns than affordability and reliability.  In my opinion those should be the primary concerns of this panel because those factors will impact the disadvantaged people of New York the most.

Because of the importance of power generation to the electrification needed to reduce GHG emissions in all sectors, this panel should focus its attention on the challenges of a transition to an electric system that is dependent upon wind and solar resources.  I recommend that strategies include a feasibility study of technology needed for the transition, a resource availability study and a cumulative environmental impact analysis.  Until this feasibility studies are complete any strategies are simply guessing and the absence of a cumulative environmental impact assessment could mean that the impacts from the cure are worse than impacts from the disease.

 

Climate Leadership and Community Protection Act Energy Efficiency and Housing Advisory Panel Strategy Comments

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

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

 General Comments

I believe that the primary consideration of any implementation strategy should be affordability and reliability for the energy system of New York.  Energy use is largely inelastic so increased energy costs are hidden regressive taxes.  Our society needs dependable energy so current reliability standards must be maintained.  In general, each strategy must address potential costs and who would pay, whether there are co-benefits that would offset costs, any impacts on energy reliability, the feasibility of the proposed action, and the GHG reduction potential.

I believe that the CLCPA implementation strategies should consider cumulative environmental impacts of the renewable energy development proposed.  As far as I can tell the only related environmental impact analysis was the Department of Public Service (DPS) Final Generic Environmental Impact Statement and the Final Supplemental Environmental Impact Statement for CASE 14-M-0101 – Reforming the Energy Vision and six other cases.  The supplemental impact statement evaluated the potential environmental impacts of the Clean Energy Standard mandating that 50% of all electricity consumed in New York by 2030 be supplied by renewable resources.  Of course, the CLCPA upped the ante and now 60% of all electricity of all electricity must be supplied by renewable resources by 2030.  The important point is that the amounts and types of new renewable generation that may be needed to meet the CLCPA goals are much larger than anything evaluated by the State to date.   The supplemental impact statement evaluated a base case large scale renewable on-shore wind increment of approximately 29,000 GWh (9,508 MW) and a high-end case of approximately 40,000 GWh (14,504 MW) of large-scale on-shore wind energy would be necessary to meet the goal.  The Analysis Group “Climate Change Impact Phase II – An Assessment of Climate Change Impacts on Power System Reliability in New York State” draft final report released in October 2020 projected that New York would have to develop all of the projected National Renewable Energy Lab’s technical potential on-shore wind capability of 35,200 MW – three times what has been evaluated.  Similarly, no one has evaluated the environmental impact of the latest estimates of utility-scale solar and off-shore wind.

I have a general concern about the CLCPA mandates for investments.  It is entirely appropriate that there should be an emphasis on environmental and social justice but I have concerns about the State’s approach.  Given that all other jurisdictions that have attempted to reduce GHG emissions have increased the cost of energy, it is likely that will be the case in New York too.  I think strategies have to consider cost-effectiveness to reduce the regressive impact on those who can least afford those increased costs, regardless of location, who are living in energy poverty or already have a disproportionate energy burden.  This means that strategies that do not reduce costs or have low GHG reduction potential should be ranked very low for future consideration.

Comments on Proposed Strategies

The Energy Efficiency and Housing Advisory Panel had 16 strategies in five scoping categories.

The first scope was titled as “Mandates that require energy efficiency improvements and on-site emissions in building and appliance with dates as market signal” and included two strategies:

      • Expand State energy & building codes (with date signals) to drive the transition to electrification & building efficiency and
      • Modify State Appliance Standards (for example, ban fossil fuel appliances sales and installations). Consider building performance standards for large buildings to meet 2050 and interim targets with a focus on onsite emissions.

I don’t think the public is going to be willing to make the sacrifices called for in these strategies.  It would be best for all concerned to get out there with publicity now to gauge acceptability.  There are all sorts of issues. For starters, how will house trailers be considered.  For the rural poor this is often all they can afford and it is simply not possible to improve energy efficiency much.   There also is an implementation issue associated with housing sector date-certain efficiency standards.  What happens to someone trying to sell an old house after the certain date. Presumably, they will be on the hook to spend whatever is needed to get up to the efficiency standard to be able to sell and that means losing a big chunk of equity in their home or the house is priced out of the market and they cannot sell the house.

Three strategies were listed in the “Financing and incentives for building efficiency and electrification at scale” scope:

        • Inducing market/behavioral change (e.g., taxes, registration fees, carbon levies) that incentivize market providers (owners, developers, lenders etc.) and residents to reduce emissions and transition to electrification;
        • Shift lenders to quantify energy efficiency in single/multifamily/commercial (e.g. underwriting to savings); and
        • Financial incentives for owners, developers and residents (e.g. cash incentives, pay as you save, low-interest financing, more agile of existing programs to get to 2050 and interim targets, etc.), with emphasis on low and middle income owners.

The biggest hurdle for these strategies is cost.  In many instances the capital cost of the electric option is more expensive than the fossil fuel option.  Moreover, I see absolutely no reason to expect that the cost of electricity will go down because that has not been the case in any jurisdiction that has attempted to meet GHG reduction targets.  I also have reservations about taxes, registration fees or carbon levies and the proposed emphasis on disadvantaged communities.  In the first place the requirement for targeted investment benefits may have the perverse effect of increasing the overall cost of energy because those investments may not be the most cost-effective approaches to reducing CO2 emissions.  If that is the case then anyone who is not a direct beneficiary of financial incentive benefits is going to be hurt. The Climate Action Council needs to track energy poverty or energy burden and the effect of these policies on those who can least afford additional energy costs so that no one (whether or not they are in a dis-advantaged community) is literally left out in the cold.

The third scope was called “Training and education of building decarbonization to improve behavior and operations for health and comfort and build workforce (enabling strategy)”.  Three strategies were included:

        • Workforce development to provide skilled professionals to design, build, operate, & enforce decarbonized building stock;
        • Education -owners, developers, design professionals and other stakeholders: resources on capital planning, all-electric buildings, electrification-ready, etc. Mandatory energy performance disclosures and building consumption data (public facing); certified product declarations for materials/equipment; and
        • Education-residents/businesses: performance, economics., environmental quality, operation and maintenance for low-carbon technologies.

Clearly, we need to train professionals to design, build, and operate the decarbonized building stock but what is the meaning of enforce decarbonized building stock? When proposing building decarbonization strategies you have to prove that decarbonization will be affordable, maintain current levels of reliability, not lead to unintended environmental consequences that exceed the alleged impacts of climate change in New York, and actually have some sort of quantifiable effect on climate change.

The “Technology innovation and demonstration to drive better performance, reduce costs, and increase customer confidence” scope had four strategies:

      • Research and development to improve cost/performance of solutions for all-electric buildings (e.g., cold climate heat pumps, geothermal, etc.);
      • Research, development, and demonstration for hard-to-electrify buildings (e.g., on district steam, steam-heated, hydronic distribution) and advance scalable solutions and potential cost reductions (e.g., community geothermal, industrialized fabric/modular, virtual tools);
      • De-risking demonstrations to help critical customer groups who may lack access to resources and information (e.g., coops/condos); and
      • Approaches to reducing embodied carbon (e.g., new tech to reduce GHG emissions from materials/construction/transportation).

The American Council for an Energy-Efficient Economy published a paper that raises issues with air source heat pumps:  Field Assessment of Cold Climate Air Source Heat Pumps.  The 2016 report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps (ccASHPs ) were directly compared to propane and heating oil furnaces.  The study found these systems have the greatest potential for adoption in cold-climate regions where natural gas is not available for space heating; ccASHPs can offset the use of more expensive delivered fuels, and for homes with electric resistance heat, can result in a significant reduction in electrical use; that it is feasible for a utility energy efficiency program to receive credit for the energy savings achieved from ccASHPs through the reduction in fuel oil and propane;  and that during periods of very cold temperatures when ccASHPS do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.  These conclusions are not compatible with the CLCPA targets.

In addition to the feasibility of wide-spread use in New York there is another issue.  I did a simple case study that illustrates my concern that wide-spread implementation of air source heat pumps coupled with increased use of renewables will be difficult.  In my analysis the meteorological conditions on New Year’s Eve 2018 show that the proposed Horseshoe solar facility with a nameplate capacity of 180 MW and a wind farm with a nameplate capacity of 100 MW would have been just able to cover the conversion of 2,737 homes to air source heat pumps.  However, energy storage capable of at least 372 MW-hr also has to be available somewhere.  There already are 47,000 homes using electricity and another 15,000 homes that are supposed to be cost-effective candidates for conversion just in two neighboring counties to the facility.  Most importantly, this is just one component of residential electricity load which is one component of total load.

The strategies proposed by this Advisory Panel are appropriate but the details should make it clear that a similar study in New York on the latest air source heat pumps is required.  That should be coupled with an assessment of the renewable energy resources.  It is not clear to me that it is possible to meet the multi-day winter doldrum period while relying on wind and solar.  Analysis of the data shows that no amount of over-building solves this problem.  Extraordinary amounts of storage are needed.  In order to determine just how much of energy storage will be required much better estimates of the load expected for electrifying homes and transportation are needed.

The final scope “Resilience and climate adaptation strategies for all-electric building, hazard mitigation planning and building retrofits” had four strategies.

      • Supporting/coordinating improved resiliency solutions for all-electric building & resilient spaces for vulnerable pops.;
      • Grid and transmission resilience and independence;
      • Electrification paired with supplemental heating sources;
      • Improving building stock to withstand the impacts of climate change.

Resiliency is a buzz word employed to suggest that these policies will be improvements to systems so that they can better recover from difficult events.  What are the resiliency solutions for all-electric buildings when there is an ice storm?  According to Wikipedia (https://en.wikipedia.org/wiki/January_1998_North_American_ice_storm): “The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern Quebec, New Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months.  The only way those people survived is because they had alternatives to electricity.  When electricity is the only option available then what?

Conclusion

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

From what I have heard the consensus opinion on the advisory panels is that air source heat pumps are an unqualified solution to residential heating.  The Minnesota field study suggests otherwise.  It would be appropriate for the panel to include a strategy for New York to replicate that study to prove that this solution will work here. In addition, a strategy to assess the potential impacts to society when the inevitable next severe ice storm occurs should be included.