Draft Scoping Plan EV Cost Comment

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I was recently interviewed for a segment on the electric vehicle component of the Climate Act on Spectrum Cable’s Capital Tonight program hosted by Susan Arbetter. During the interview I suggested that one of the questions about electric vehicle costs she asked was appropriate for a comment. This article describes the comments I submitted on the issue raised in the interview.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

One of the reasons that Capital Tonight did an interview with me was to let their viewers know that the comment period is open until July 1.  During the interview she asked me what the costs for Zero-Emissions Vehicles were in the Draft Scoping Plan.  When I told her the numbers for 2022 in the Integration Analysis spreadsheet she said: “That is a lot more than a gas-powered car”.  Later in the interview she asked what I would recommend people should write comments about.  I said that people should send comments to the Council about anything that impacts them directly.  I used the example regarding her question about the car prices as an appropriate question.  This comment specifically addresses that concern and a couple of others we did not discuss due to time constraints. 

Summary

The Integration Analysis vehicle cost projections rely on a single vehicle type for light-duty vehicles.  In the first place the value for regular vehicles seems high and, relative to all electric-vehicle prices last fall, the battery-electric costs seem low.  In my comment I recommended that the Climate Action Council consider updating the Integration Analysis to better represent different types of vehicles.   I also urged the Council to consider including the costs of used cars into the analysis particularly because low and middle-income households purchase used cars rather than new cars.  Finally, I questioned the optimistic rate of battery-electric cost price decreases used in the Integration Analysis. 

Integration Analysis Vehicle Costs

Ms. Arbetter asked me to talk about the Draft Scoping Plan costs because she knows that I have dug into the Integration Analysis enough to be able to give her specific answers.  I based the numbers I presented    on the Integration Analysis spreadsheet IA-Tech-Supplement-Annex-1-Input-Assumptions.   In the Trans_Device Cost table (excerpt below) the 2022 diesel and gas vehicle costs are both listed as $31,787 and battery electric vehicle cost is given as $41,646. The following table from Inside EVs lists the costs of battery electric vehicles on September 18, 2021.  There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.

Source: https://insideevs.com/news/534027/electric-car-prices-us-20210918/

Given the relative importance of future light-duty vehicle costs to New Yorkers I think that this analysis of vehicle costs needs to be refined.  A single category for light-duty vehicles is unacceptable.  A quick search for rental cars finds the following vehicle types: full-size, economy/sub-compact, compact, intermediate, standard, standard sport, intermediate SUV, standard SUV, premium, and luxury.  Kelly Blue Book’s buying guide for electric vehicles has another list of vehicle types.  Somewhere, someone must have compared different vehicle types to come up with a single number. 

I have the following recommendations for this aspect of the Scoping Plan.  At an absolute minimum, the rationale used for the single value must be documented.  If it was a weighted average, then the assumptions should be shown.  However, I think it would be more appropriate to incorporate more vehicle categories in the analysis that encompass a broader range of vehicles used.  While the more categories the better, why not at least provide costs for compact, intermediate, full-size in both regular and SUV models?  I am sure a more refined analysis would improve the value of these cost estimates. 

Used Cars

Due to time constraints in the interview, I was not able to make the point that the Draft Scoping Plan EV cost analysis only considers new cars.  With all the Climate Act emphasis on equity for low and middle-income New Yorkers, the document is ignoring those who cannot afford a new vehicle and that is a major flaw in the EV analysis.  According to EDF Energy:

The battery on an electric car is a proven technology that will last for many years. In fact, EV manufacturers guarantee it. Nissan warrants that its electric car batteries will last eight years or 100,000 miles, for example and Tesla offers a similar guarantee.

Future Costs

During the interview I also noted that the Draft Scoping Plan predicts that costs for battery-electric vehicles will be less than regular vehicles by 2028.  Specifically, the Integration Analysis spreadsheet projects that battery electric vehicles will be cheaper than gas/diesel by 2028: diesel/gas cost is $32,514 and battery electric is $31,951.  That is an optimistic ~5% per year decrease in costs.  Although I concede that many reports support similar cost reduction trajectories many of those reports are biased because they are from organizations with a financial stake in electric vehicle adoption and/or written by authors whose career is dependent upon the clean energy transition. 

My primary future cost concern is the cost of battery raw materials.  PWC describes the automotive supply chain and notes that:

The lithium-ion battery pack alone can account for up to 50% of the value of today’s EVs. Battery prices have fallen steadily in recent years and that share will likely be much lower over time. But even so, these batteries are primarily made by companies outside the traditional auto supply chain, creating new competition for legacy suppliers.

I believe that the Climate Action Council should address New York’s ZEV plans in the context of other similar plans in other jurisdictions particularly in regards to the world’s supply of lithium.

Conclusion

The primary purpose of this article is to show by example how to take a particular concern and put it into a comment.  Both Ms. Arbetter and I believe that more New Yorkers need to get involved in the Climate Act.  The easiest way to do that is to submit comments where you can fill out a form and directly submit a 2,000-character comment or attach a file.  If you have technical issues with the form, you can email your comment to: scopingplan@nyserda.ny.gov.

If you can describe a problem, document issues with the Draft Scoping Plan treatment of the issue, and then ask a question or recommend a revision, then I think your comment will be effective.  If that is too complicated, then simply explaining that you have general concerns about the direction of the plan would help counteract the environmental lobbying organizations letter writing campaigns.  There is a tendency on the part of many members of the Climate Action Council to claim that the quantity of comments regarding a specific issue should be the final arbiter of policy decisions.

The bottom line for my specific comment is that the Integration Analysis does a terrible job dealing with the costs of zero-emissions vehicles.  For a topic that is one of the primary interests of New Yorkers the overly simplistic approach is unacceptable.  The Integration Analysis should be revised to consider multiple vehicle category costs to improve the results and give the public a better idea what implementation of the Climate Act will mean to them personally.

Capital Tonight Electric Vehicles

Here is the link to the interview.

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I was interviewed for a segment on the electric vehicle component of the Climate Act on Spectrum Cable’s Capital Tonight program hosted by Susan Arbetter.  This post provides documentation for the information I provided in the interview and expands on some comments that could not be covered completely.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  This blog emphasizes that pragmatic environmentalism is all about balancing the risks and benefits of both sides of policy issues.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Leadership and Community Protection Act (Climate Act) is New York’s response to climate change.  The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.  The deadline for submitting comments is July 1, 2022

Climate Act Transportation Sector Strategies

The Climate Action Council strategies to achieve net-zero are described in the Draft Scoping Plan document.  The overall plan to reduce greenhouse gas (GHG) emissions is to electrify as much as possible and produce the electricity using mostly wind and solar generation.  Electrification is also a key component of the transportation sector strategy.  Chapter 11 explains that the reductions in the transportation sector are important because the transportation sector emits 27% of the total GHG emissions, second only to buildings. 

According to Table 8 from the Plan, there are four themes to the transportation sector emission reduction plan.  The first, transitioning to ZEVs and equipment, was the focus of the interview.  Both the enhancing public transportation and mobility alternatives and smart growth and mobility-oriented development themes aim to lower emissions by reducing the use of personal vehicles.  The last theme, market-based solutions and financing, addresses paying for the strategies.  The interview discussed personal vehicles so I am going to focus on light-duty vehicles.

The transportation sector theme transitioning to ZEVs and equipment has two strategies.  The first, Light-Duty ZEV Adoption, proposes to transition light duty vehicles to battery electric or hydrogen fuel cell power.  Note that because hybrid vehicles still use some fossil fuel, they are not acceptable.  The second theme, Adoption of Zero-Emission Trucks, Buses, and Non-Road Equipment, is very similar to the light-duty vehicle strategy except for different kinds of vehicles.

The Integration Analysis developed three scenarios for meeting the Climate Act targets.  I recently did a post summarizing the differences between those scenarios and the reference or business-as-usual case for the transportation sector.  I based my analysis on the Annex 2: Key Drivers and Outputs Spreadsheet.  The spreadsheet Tab: Scenario Definitions lists specific programs in the Reference Case which I summarized in  Table 1.

The first question addressed in the interview is when is this supposed to happen.  There is legislation in place that mandates that all new vehicles sold in 2035 must be zero-emissions vehicles (ZEVs).  At this time only 5% of vehicles sold are zero-emissions.  The expected transition over time varies between the three mitigation scenarios but note that in 2030 the Integration Analysis projects that over 90% of the vehicles sold will be ZEVs.  The sales transition to ZEVs is expected to occur naturally.  In other words, the expectation is that enough people will be willing to purchase ZEVs that this won’t need to be regulated before 2035.  However, note that the mitigation scenarios expect that in 2025, 33% of all vehicles sold will be ZEVs.  Also note that two of the mitigation scenarios propose to accelerate the adoption of ZEVs and reduce emissions faster by mandating early retirements in 2030.  I believe that it is overly optimistic to expect that one of every three cars will be a ZEV in three years so it is possible that if not enough people are willing to shift to ZEVs that New York may believe it is necessary to eventually add early retirement regulations.

Another question addressed in the interview was how much will this cost.  I explained that the Integration Analysis documentation in the Scoping Plan says that in 2022 diesel/gas vehicle cost is $31,787 and battery electric vehicle cost is $41,646. Note that the Draft Plan projects that battery electric vehicles will be cheaper than gas/diesel by 2028: diesel/gas cost is $32,514 and battery electric is $31,951.  That is an optimistic ~5% per year decrease in costs.  The following table from Inside EVs lists the costs of battery electric vehicles on September 18 2022.  There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.

https://insideevs.com/news/534027/electric-car-prices-us-20210918/

There is another important vehicle cost issue.  I think there is an omission in the Draft Scoping Plan because they only talk about new car sales.  There is no discussion how the used car market will change.  Because batteries will have to be replaced in used cars and they are a major expense I think that will have a significant impact on the used car market.

Another component cost of electric vehicles is charger costs.  As shown in the Integration Analysis table below the 2022 cost for a light-duty vehicle is $2,176 and in 2035 the analysis expects costs to go down to $2,018.  There is a lack of detail about charger types.  I found a reference that describes two types of home chargers: Level 1 chargers that with a cost to install of $1800 can recover 4 to 5 miles of range per hour and Level 2 chargers costing $2200 that recover 25 to 30 miles of range per hour.  I assume that the Integration Analysis cost estimat is for Level 2 chargers that can fully charge vehicles overnight.   However, we also need to consider the costs for fast Level 3 chargers as part of overall costs even though they are not suitable for home use.  They are much more expensive $50,000+ but can recover 100 miles of range per hour.  Anytime an owner is on a long trip they are going to either need to find one of these chargers or interrupt their trip for an extended duration stop.  In my opinion, charging limitations would effectively preclude New Yorkers from driving south for spring break.

There is another massive omission in the Draft Scoping Plan relative to chargers. What about renters and people who park on the street?  Who is going to pick up the tab for all those chargers?  Chargers could be assigned in parking lots but on the street that would be problematic.  In both instances snow removal becomes an issue too.

In my opinion personal choice limitations are the biggest concern of the electric vehicle transition.  ZEVs have range limitations and I personally want the ability to travel long distances without range anxiety.  There is a safety issue buried in the necessity for longer fueling times.  In order to match the 2000 cars that a typical filling station can service in a busy 12 hours, a future station would require 600 Level 3 chargers at an estimated cost of $24 million and a supply of 30 megawatts of power from the grid.  Imagine the chaos if an evacuation was needed, everyone was driving a ZEV, and this limitation over-whelmed the capacity of available charging systems.

Discussion

There was insufficient time to fully address a couple of other issues.  Past transformative energy transitions occurred because the perception of the new technology was that it was better because it improved personal choice and opportunities as well as offering clear cost savings up front and over the lifetime of the vehicle.  This transition is different.  We are being forced to use technology that limits our ability to travel when and where we want and it costs more than what we are paying today.  The benefits are for a problem that New York cannot solve on its own and alleged impacts that we cannot question.  In my opinion that is a pretty hard pill to take.

We did not get a chance to talk about why aren’t hybrids good enough.  In brief, the Climate Act mandates zero-emissions and hybrids use fossil fuels.  The reality is that New York’s GHG emissions are so small relative to global emissions that there will not be any effect on the state’s climate and global climate change impacts to New York.  Global emissions have annually increased by more than one half of one percent per year and New York’s total share of global emissions is less than one half of one percent.  In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year.  If New York allowed hybrids as a control option even if it meant some emissions costs would be lower and many of the personal choice limitations would be addressed.

Conclusion

Ms. Arbetter and I agree that many people are unaware of the implications of the Climate Act.  She asked me to describe what the Draft Scoping Plan has to say about zero emission vehicles because that is one of the components that has the most impacts to New Yorkers.  I tried to describe what is included and what is not included in the Plan to help spread the word.

We both agree that New Yorkers should take the opportunity to provide comments so that the Climate Action Council gets engagement from as many people as possible.  I hope that readers will follow up and submit comments.  While you could try to wade through the Draft Scoping Plan itself, the document has been described as follows:

The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it. Here’s an example: “Regardless, any transition must be carefully planned, detailed, and clearly communicated to ensure that expectations are aligned across stakeholders.”

Instead of reading the document I suggest spending some time reading about issues and research things that are of particular interest to you at the Climate Act website and my Citizens Guide.  Once you have your thoughts together go to the comment website and submit your comment.   For your information I have summarized all my comments here. One final note, I submitted comments based on the interview discussion that are described here.

Draft Scoping Plan Carbon Pricing Strategies Comment

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  This article describes the comments I submitted to the Climate Action Council on Chapter 17: Economy-Wide Strategies.  I am not sure why they did not refer to these as policies that effectively price GHG emissions because that is what they are talking about.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

I prepared this comment because my extensive experience with the Regional Greenhouse Gas Initiative has shown that there is a major disconnect between the theory of a carbon pricing program and reality.  This disconnect is also evident in the NYISO carbon pricing initiative and the Draft Scoping Plan carbon pricing initiatives.

Summary

Based on the format of Section 17, it was written to address specific issues raised by the Climate Action Council.  As a result, it gets bogged down into details about specific issues raised by council members rather than looking at the big picture.  In theory, a price on carbon is a great idea.  The Council has not considered the theory relative to their perceptions. 

My overview comments explain why I believe carbon pricing will always be a regressive tax based on a post I did on carbon pricing.  I also think that there are a number of practical reasons that carbon pricing will not work as theorized.  Because a global program is impractical, leakage is always going to be a problem.  All carbon pricing proposals need to address the problem that as carbon emissions go down revenues go down relative to the fact that reductions get more difficult and expensive as control efficiency increases.  The Council members who support carbon pricing seem to be blissfully unaware of the realities of the energy market that are at odds to their theories. Based on observed results I think that indirect market signals are going to lead to less cost-effective reductions in the time frame necessary for the aggressive reduction rules.  To date, carbon pricing for the electric sector only considers generation costs which leads to cost shifting the additional costs to supply electricity when and where it is needed to be covered outside the carbon pricing framework.  Supporters under-estimate the very real problems of implementation logistics.  My concerns about carbon pricing are supported by the recently completed a relevant study done by Regulatory Analysis Project (RAP): Economic Benefits and Energy Savings through Low-Cost Carbon Management for Vermont.

In addition to my practical concerns “A Practical Guide to the Economics of Carbon Pricing by Ross McKitrick defines how carbon pricing is supposed to work in theory.  He explains that “First and foremost, carbon pricing only works in the absence of any other emission regulations.” The Guide goes to note “another important rule for creating a proper carbon-pricing system is to be as careful as possible in estimating the social cost of carbon”. He argues that “whatever the social cost of carbon is determined to be, the carbon price must be discounted below it by the marginal cost of public funds (MCPF) — that is, the economic cost of the government raising an additional dollar of tax, on top of what is already being raised”. The Draft Scoping Plan does not even recognize the importance of this aspect of carbon pricing.  Finally, he notes that: “it needs to be remembered that carbon pricing works because it is a market-based policy: it works with market forces, not against them. He concludes: “There may be many reasons to recommend carbon pricing as climate policy, but if it is implemented without diligently abiding by the principles that make it work, it will not work as planned, and the harm to the Canadian economy could well outweigh the benefits created by reducing our country’s already negligible level of global CO2 emissions.”

Affordable Revenues

I think the Climate Action Council has to define affordable.  In the absence of any numbers in the Draft Scoping Plan related to potential revenues I calculated my own estimates.  The total New York State GHG emissions in 2019 are 379.43 million metric tons of CO2 equivalent.  If the carbon price was set at the 2022 New York State Value of Carbon Guidance value of $129, then the economy wide cost would be $48.9 billion.  I submit that is not affordable for any New Yorkers and could not possibly be designed to avoid regressive impacts.

Clearly, setting a carbon price for all New York emissions is unaffordable so the Climate Action Council should consider setting a price on different sectors.  Table ES.2: 2019 New York State GHG Emissions is from the 2021 Statewide GHG Emissions Report and lists the emissions by sector. 

I used this GHG emissions information and the 2022 value of carbon of $129 to look at several emission scenarios in the next table.  Using the IA-Tech Supplement Annex 2 Emissions Key Drivers spreadsheet 2022 Gross State Product and population each scenario estimates the cost per month for each NYS resident and the cost as a fraction of the GSP.  If all the emissions were included in the carbon pricing scheme the cost per resident would be $262.50 and the costs are 3.36% of the GSP.  The Candidate scenario only includes the Energy and Industrial Processes and Product Use sectors reduces the costs slightly.  The Combustion scenario only includes in-state combustion emissions and drops the total revenues by more than half.  Finally, I excluded everything except the electric power sector.  Those costs are still pretty high: $12.05 per person per month and 0.15% of the GSP.

The estimates of current (2019) emissions coupled with the New York value of carbon yield very high revenues.  On October 26, 2021, the AP-NORC Center and the Energy Policy Institute at the University of Chicago (EPIC) released the results of a survey that claimed that a majority of Americans regard climate change as a problem of “high importance”.   It also included survey questions asking whether respondents would support, oppose, or neither support or oppose a law that imposed “a fee on carbon to combat climate change”.  The survey question asked “If the law passed, it would increase the average amount your household pays each month for energy, including electricity, heating gas, and gasoline or diesel for your car by a total of X dollars per month” where respondents were randomly assigned a $1, $10, $20, $40, $75, or $100 cost increase.  For a $1 per month increase, 45% would support, 30% would oppose, and 25% would neither support or oppose.  For a $100 per month increase, 20% would support, 62% would oppose, and 18% would neither support or oppose.  Only 45% support $1 per month per household and $1 per month per person only provides revenues of $237 million.  All of the projections in Table 2 estimate costs far higher than that level so I do not think the public perception of affordable will be met by any carbon pricing scheme that uses the New York value of carbon.

Another way to look at affordable costs is to set the costs per month per person and the costs relative to the GSP and see what revenues would be generated.  The following table provides that information.  All of the projected costs exceed the AP-NORC Center and EPIC survey category where 45% support $1 per month per household. 

The Draft Scoping Plan provides no details to recommend what is affordable.  Rather than getting bogged down in implementation issues, the Climate Action Council and the Climate Justice Working Group should address what is affordable.  That recommendation is going to drive the specifications for all three of these carbon pricing approaches.

Conclusion

The theory of carbon pricing is embraced by leading economists.  However, advocates for such a scheme in New York do not understand that the plans proposed are not like the theory.  My comments showed that there are implementation issues and that the Draft Scoping Plan proposed pricing schemes do not match the theory. Ross McKitrick sums it up: “There may be many reasons to recommend carbon pricing as climate policy, but if it is implemented without diligently abiding by the principles that make it work, it will not work as planned, and the harm to the Canadian economy could well outweigh the benefits created by reducing our country’s already negligible level of global CO2 emissions.”  Substitute New York for Canada and it describes the likely effect of the carbon pricing plans proposed.

Reconcile NYISO and Integration Analysis Electric Generation Projections Comment

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  This article describes the comments I submitted to the Climate Action Council describing the differences between the projections for future electricity generation by the New York Independent System Operator (NYISO) and those in the Draft Scoping Plan.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

The key point is that the Scoping Plan “shall inform the state energy planning board’s adoption of a state energy plan” but the Climate Action Council membership is generally lacking the background, experience, and education to decide technical matters such as the fuel mix of the future generating system. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”.  Therefore, my comments explained why I believe the differences between the Draft Scoping Plan and the NYISO have to be addressed in a public forum.

Summary

The New York Independent System Operator (NYISO) is currently (June 6, 2022) updating its System and Resource Outlook.  The last Outlook Study Status presentation (April 26, 2022) noted that the draft report will be issued in June 2022.  One of the supporting documents for this study is the Capacity Expansion Zonal Results Analysis spreadsheet.  The projected new generating resources in the preliminary modeling results are different than the capacity additions in the Draft Scoping Plan Integration Analysis.  The projection for future generation capacity and energy for the baseline case with a forecast for Climate Act is shown in the following table.

The Draft Scoping Plan Appendix G: Integration Analysis Technical Supplement “summarizes, reports, and documents the findings, results, and methodology of the Integration Analysis developed to support the Climate Action Council in its development of the Draft Scoping Plan pursuant to the Climate Act”.  For this analysis I relied on data in the  Appendix G: Annex 2: Key Drivers and Outputs spreadsheet.  The following two tables list the installed capacity and annual generation for the three mitigation scenarios in the Draft Scoping Plan.

The capacity (MW) and generation (GWh) for the NYISO outlook study baseline with CLCPA case forecast scenario and integration analysis mitigation scenarios were combined in a spreadsheet and a table that is too large to include in this article.  The point of my comment was that although the total generation capacity is pretty close between the analyses, the Climate Action Council and the NYISO have to reconcile four significant differences in the projections.  The NYISO analysis projects dispatchable emissions-free resources capacity on the order twice as much as the three Integration Analysis mitigation scenarios.  The NYISO analysis projects land-based wind capacity development about three times larger than the three Integration Analysis mitigation scenarios.    The NYISO analysis projects off-shore wind capacity about 50% less than the three Integration Analysis mitigation scenarios.     The NYISO analysis projects that solar will provide about one tenth the projected capacity of the three Integration Analysis mitigation scenarios.

Conclusion

The NYISO presentation notes that their study should be finalized this summer: “July 2022: Seek Board of Directors review and approval”.  I believe that it is important that when the NYISO report and projections are finalized the differences between the Integration Analysis and this report are reconciled.

At one of this year’s Climate Action Council meetings, I believe the idea of workshops to consider specific issues as suggested.  I think this would be an ideal candidate topic for just such a meeting.  In the first place there is a clear need to determine which analysis should be the primary driver for the ultimate energy plan.  In addition, this workshop could also include sessions to address other reliability issues.

Climate Action Council Requirements in the Climate Act

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  This post describes Climate Act requirements for the Climate Action Council responsible to develop the plan to meet that goal.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until July 1, 2022.

This post was drafted as part of my analysis to determine how the comments will be considered by the Climate Action Council.  As shown below there are specific mandates for the Scoping Plan and public comments in the Climate Act itself.

Climate Action Council in the Climate Act

The Climate Act defines the composition and responsibilities of the Climate Action Council in § 75-0103.

In this section I will summarize the sections of the law related to the Council and provide comments.

Section 1 establishes the Climate Action Council and describes its membership. Up until last month there were 22 members, but now another member has been added.  Twelve members are agency heads appointed by the Governor.  The remaining “at large” members are non-agency “experts”, two appointed by the governor, three each appointed by majority leaders of the Assembly and Senate and one each appointed by the minority leaders of the Assembly and Senate.  It is not clear who decided to add a position and who chose the new member who represents labor unions. Naïve me would think it would require a change to the law.

Note the member responsibilities.  All but three are high-ranking administrators which presumably means that in order to provide any meaningful responses they have to rely on their staff to provide synopses of the material presented to the Council so that they can make comments and keep up with their other responsibilities.  Frankly I would be shocked if most of the agency heads do anything other than what they are told to do by the Administration.  There are only three staff level people who I expect would have to provide comments based entirely on their own work.

I prepared a summary table of Council membership. Of the 23 members of the Council only 8 come from energy sector organizations or have some background in the energy sector.  Four of the energy sector members are agency heads and two others represent renewable energy organizations.  Gavin Donohue represents the Independent Power Producers of New York an organization that represents both renewable and traditional energy organizations.  The only member from the traditional energy sector is Donna DeCarolis, President of National Fuel Gas.  She is the only member outside of state agencies that has any responsibility for keeping energy available to customers and who has no ties to the zero-emissions agenda.  On the other hand, there are four appointees and one agency head that are primarily interested in environmental interests.  One of these members also represents environmental justice interests. 

Section 2 notes that “at large members shall include at all times individuals with expertise in issues relating to climate change mitigation and/or adaptation, such as environmental justice, labor, public health and regulated industries.”  It isn’t clear to me what this language intended.  Does “include at all times individuals with expertise in issues relating to climate change mitigation and/or adaptation” mean they are all supposed to have climate change expertise representing environmental justice, labor, public health and regulated industries?  I have not seen indications that many at large members have any particular expertise in climate change mitigation and/or adaptation albeit those terms are so loose to not have a lot of meeting.  It is extremely telling that energy sector expertise is not mentioned as a specific criteria unless you assume that regulated industries refers to the energy utilities.

Sections 3 and 4 state that members will not be compensated and defines that the Commissioner of the Department of Environmental Conservation and head of the New York State Energy Research & Development Authority will be co-chairs.

One reason for this post is to try to understand how the Council will make decisions about the Scoping Plan.  Section 5 states that “each member of the council shall be entitled to one vote”, and that “The council’s approval and adoption of the final scoping plan pursuant to this section, and any subsequent interim updates thereto, shall require a supermajority of the council.”.

Section 6 explains how to replace vacancies.  It is not clear to me that at-large members would change if the ruling party in the assembly or senate changes.  I think it is important to note that the Governor directly chose two members and indirectly chose 12 others through the agency heads.  Consequently, the administration controls the actions of the Council and that could change with a different governor.

Section 7 describes the Advisory Panels that provided “recommendations to the council on specific topics, in its preparation of the scoping plan, and interim updates to the scoping plan, and in fulfilling the council’s ongoing duties”.  They no longer are active so I am not going to discuss them here.  I did a posts on the Power Generation Advisory Panel and their enabling initiatives last year if you are interested.

Section 8 convenes a just transition working group. In my opinion, this was a political ploy to garner support from specific constituencies.  With regards to my primary concerns related to the Scoping Plan this group has little influence.

Section 9 basically mandated that NYSERDA will provide the support necessary to complete the Scoping Plan.

Section 10 states that “The council shall consult with the Climate Justice Working Group (CJWG) established in section 75-0111 of this article, the Department of State Utility Intervention Unit, and the federally designated electric bulk system operator.”  I believe that there is inordinate deference paid to the CJWG but will address that in a separate article.  It is not clear to me whether the federally designated electric bulk system operator refers to the New York Independent System Operator (NYISO).  If so, I have not seen many signs of that consultation.  If not then excluding NYISO is an egregious error.  In any event the New York State Reliability Council should have been included.

Section 11 defines the Scoping Plan and schedule for reporting:

The council shall on or before two years of the effective date of this article, prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule established in section 75-0107 of this article, and for the reduction of emissions beyond eighty-five percent, net zero emissions in all sectors of the economy, which shall inform the state energy planning board’s adoption of a state energy plan in accordance with section 6-104 of the energy law. The first state energy plan issued subsequent to completion of the scoping plan required by this section shall incorporate the recommendations of the council.

The New York Energy Plan is the “comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”.   When I started working in the New York electric utility sector the emphasis was on reliability and affordability and the energy plan was developed by energy experts.   The last Reliability Study was in 2012.  Since then, the emphasis has shifted such that now politically correct “clean” energy is the top priority.  In addition, the energy plan is no longer drafted by energy sector experts.  Instead it is supposed to “incorporate the recommendations of the council” with minimal Council member energy system expertise.  There is no question in my mind that reliability and affordability are at risk with this approach.

Section 12 sets the logistical requirements.  It specifies that the draft scoping plan will be developed in “consultation with the environmental justice advisory group, and the climate justice working group”, hold regional public comment hearings, and provide “meaningful opportunities for public comment from all segments of the population that will be impacted by the plan”.  Finally, it mandates that “On or before three years of the effective date of this article, the council shall submit the final scoping plan to the governor, the speaker of the assembly and the temporary president of the senate and post such plan on its website.”

In my opinion, the Climate Act and the scoping plan process have focused too much on specific aspects and not enough on the big picture.  In Section 13 there are specific requirements to “ensure the attainment of the statewide greenhouse gas emissions limits”.  The measures and actions considered in such scoping plan shall at a minimum include:

a. Performance-based standards for sources of greenhouse gas emissions, including but not limited to sources in the transportation, building, industrial, commercial, and agricultural sectors.

b. Measures to reduce emissions from the electricity sector by displacing fossil-fuel fired electricity with renewable electricity or energy efficiency.

c. Land-use and transportation planning measures aimed at reducing greenhouse gas emissions from motor vehicles.

d. Measures to achieve long-term carbon sequestration and/or promote best management practices in land use, agriculture and forestry.

e. Measures to achieve six gigawatts of distributed solar energy capacity installed in the state by two thousand twenty-five, nine gigawatts of offshore wind capacity installed by two thousand thirty-five, a statewide energy efficiency goal of one hundred eighty-five trillion British thermal units energy reduction from the two thousand twenty-five forecast; and three gigawatts of statewide energy storage capacity by two thousand thirty.

f. Measures to promote the beneficial electrification of personal and freight transport and other strategies to reduce greenhouse gas emissions from the transportation sector.

g. Measures to achieve reductions in energy use in existing residential or commercial buildings, including the beneficial electrification of water and space heating in buildings, establishing appliance efficiency standards, strengthening building energy codes, requiring annual building energy benchmarking, disclosing energy efficiency in home sales, and expanding the ability of state facilities to utilize performance contracting.

h. Recommendations to aid in the transition of the state workforce and the rapidly emerging clean energy industry.

i. Measures to achieve healthy forests that support clean air and water, biodiversity, and sequester carbon.

j. Measures to limit the use of chemicals, substances or products that contribute to global climate change when released to the atmosphere, but are not intended for end-use combustion.

k. Mechanisms to limit emission leakage as defined in subdivision eleven of section 75-0101 of this article.

l. Verifiable, enforceable and voluntary emissions reduction measures.

Section 14 specifies how the Council will develop the Scoping Plan.  The Council is supposed to “Consider all relevant information pertaining to greenhouse gas emissions reduction programs in states in the United States Climate Alliance, as well as other states, regions, localities, and nations.”   Unfortunately, I haven’t seen much sign in the draft plan that discusses the experience of other jurisdictions.  I cannot help but wonder if that is related to the fact that experiences elsewhere have seen affordability and reliability issues.

Section 14 also states:

b. Evaluate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available. In conducting this evaluation, the council shall quantify:

i. The economic and social benefits of greenhouse gas emissions reductions, taking into account the value of carbon, established by the department pursuant to section 75-0113 of this article, any other tools that the council deems useful and pertinent for this analysis, and any environmental, economic and public health co-benefits (such as the reduction of co-pollutants and the diversification of energy sources); and

ii. The costs of implementing proposed emissions reduction measures, and the emissions reductions that the council anticipates achieving through these measures.

c. Take into account the relative contribution of each source or source category to statewide greenhouse gas emissions, and the potential for adverse effects on small businesses, and recommend a de minimis threshold of greenhouse gas emissions below which emission reduction requirements will not apply.

d. Identify measures to maximize reductions of both greenhouse gas emissions and co-pollutants in disadvantaged communities as identified pursuant to section 75-0111 of this article.

In my opinion, the Draft Scoping Plan does not include “the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases” so it does not “make such evaluation publicly available”.  In order to meet that requirement, I believe that all control measures should be listed, with the assumptions used, with the costs and expected emission reductions for each one provided.  The Draft Scoping Plan does include cost and benefit analyses.  Unfortunately, even though specific cost numbers are not available my analysis disagrees with theirs.

In Section 15 there is a requirement to update the plan at least once every five years and “make such updates available to the governor, the speaker of the assembly and the temporary president of the senate and post such updates on its website”.

Section 16 includes another mandate to consider efforts at other jurisdictions.  It states:  “The council shall identify existing climate change mitigation and adaptation efforts at the federal, state, and local levels and may make recommendations regarding how such policies may improve the state’s efforts.”

Finally, Section 17 requires the council to “maintain a website that includes public access to the scoping plan and greenhouse gas limit information”. 

Update on Public Hearings and Comments

At the May 26, 2022 Climate Action Council meeting there was an update on the public hearings held and a discussion on the plan to deal with the comments.  The following slide notes the highlights.  At the time of the meeting, they had received nearly 18,000 written comments.  Obviously, those will take an enormous effort to review.  The comment response plan presented says that every comment will be reviewed.  The comments will be categorized by staff reviewers.  The Council will get a summary of the comment categories and “synthesis” of the comments.  Then the Council and sub-groups will be consider comments.  Staff will provide “proposed approaches to incorporate/respond to feedback”.  They promised that the comments will be posted on the Climate Act website.

My reading of this and the impression I got from the meeting is that the Climate Action Council is going through the motions of the public comment process.  From what I have seen the review process has not started in earnest.  If the public comments were truly going to be considered then I think it would be appropriate to make comment distillation an on-going process from the get go.  I also don’t see why the comments have not been posted to the website.  It would be relatively easy to just provide a list of comments as they have been received and there is no reason why they couldn’t also list the comments in some broad categories.  At the meeting there was some discussion asking why there hasn’t been any information about the comments provided to the Council.  The response was that because past experience showed there are a lot of submissions received at the end of the comment period that they didn’t want to deal with that.  That does nothing to dissuade my impression that the comment process is all for show.

Discussion

This post was drafted as part of my analysis to determine how the comments will be considered by the Climate Action Council.  It is impossible for any individual to review even the 18,000 comments received to date.  Therefore, I agree that the only way to handle this is for staff reviewers to categorize and summarize comments.  Even with that approach the sheer number of comments that have to be addressed is daunting.  As a result, there will be a lot of judgement on the part of staff relative to the comments that rise to the level where review by the Climate Action Council is deemed necessary.

This is where my concerns about expertise come to the fore.  A fraction of the comments will obviously not require Council consideration for a variety of reasons like being outside the scope of the Draft Scoping Plan.  The response will simply be “thank you but your comment is outside the scope”.  Comments that support particular points also fall into the no controversy category.  The problem is that when it comes to controversial issues only eight members have energy sector expertise so it is not clear how energy controversies will be resolved correctly. I am particularly concerned that comments could be summarily dismissed in the screening process either by staff or in initial discussions by Council members that simply don’t have enough background and experience to understand the issue raised.

For example, consider my comments regarding the claimed benefits of the social cost of carbon.  I raised a technical issue that affects the claim that the “cost of inaction exceeds the cost of action by more than $90 billion”.  I showed that the methodology used inflates the numbers but most importantly, it is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. The Draft Scoping Plan claims benefits of between $235 and $250 billion but my calculation shows that the true benefit should be less than $60 billion.  I am pretty comfortable saying that no one on the Council understands this issue so how are they going to be able to knowledgably vote on how to respond to this comment?

Finally, the voting process is mostly for show anyway.  Because the Governor directly or indirectly appointed 14 members to the Council, those beholden to the Administration will vote as they are told. This is where it is going to get interesting.  There are some vocal at large members who hold some extreme views on future strategies.  For example, there are those that believe that the Climate Act has a mandate for no combustion because that is the only zero-emissions “solution”.  Realistically, however, that precludes a lot of things that have no practical alternative (aviation is at the head of that list) or are strong personal preferences.  Strictly speaking no combustion means no wood burning and that is simply unacceptable to many in rural areas who cannot afford any other alternative.  Given the political pushback from rural areas I cannot imagine that Administration votes for the Scoping Plan would endorse the no combustion approach. 

Conclusion

There are three aspects of the final Scoping Plan that have to be considered by the Climate Action Council according to the Climate Act.  Unfortunately, I don’t think they will necessarily be addressed based on the the composition of the Council membership.

The Climate Act specifically states that the costs and benefits analysis must: “Evaluate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available.”  That information is not in the Draft Scoping Plan and the Council has not raised the issue.

The Climate Act includes a mandate to consider efforts at other jurisdictions: “The council shall identify existing climate change mitigation and adaptation efforts at the federal, state, and local levels and may make recommendations regarding how such policies may improve the state’s efforts.”  That information is not in the Draft Scoping Plan and the Council has not raised the issue.

Some of the at large members have taken the position that implementation is necessary without restrictions because the Climate Act has specific emission reduction targets.  However, § 66-p. “Establishment of a renewable energy program” includes a safety valve:  “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.  I believe that requires the final Scoping Plan to consider reliability (safe and adequate electric service) and affordability (significant increase in arrears or service disconnections).

In my opinion, the Climate Act and the scoping plan process have focused too much on specific aspects and not enough on the big picture.  For example, one council member said that staff should look into community ground-based heat pumps initiatives and the final draft addresses that concern.  That is an in the weeds initiative that is well within the noise of emission reduction projections.  The big picture is maintaining reliability and affordability. What the Council should be addressing is the standards for safe and adequate electric service and the criteria for significant increase in arrears or service disconnections.  The current reliability acceptability standard is a loss of load expectation one day in ten years.  When the electric system is dependent upon variable sources of wind and solar is that stringent enough?  Will another reliability criterion have to be developed?  A recent legislative proposal included a requirement for state agencies to identify policies to ensure affordable housing and affordable electricity (meaning that electricity costs no more than 6% of a residential customer’s income) for all-electric buildings.  The Council should address whether that is the appropriate metric for the Climate Act and insist that the current status of that parameter be included in the final Scoping Plan.

Guest Post Draft Scoping Plan Comments on Practicality and Others

This post describes the comments submitted on the Climate Leadership and Community Protection Act (Climate Act) Draft Scoping Plan by Gary R. Schoonmaker. If I knew how to do guest posts on this site, I would have made this a guest post.  My apologies but I am going to have to wing it.

Gary R. Schoonmaker is a lifetime citizen of New York State; a licensed Landscape Architect with over 18 years experience at an electric and gas utility in New York State; and involvement in many environmental organizations in Central New York. He designed and built an energy efficient home in 1978 which had an air-to-air heat pump and now has solar panels; and has over 40 years experience in real estate development.

Schoonmaker Verbal Comments

On April 26, 2022, Schoonmaker used his two minutes at the public hearing at the College of Environmental Science and Forestry in Syracuse (3:22:15 of the video recording) to present his credentials and raise serious concerns about the practical limitations on implementing the plan as proposed in the draft scoping plan.  If you want a good overview of the comments then I recommend his comments in no small part because of his effective presentation.

He described his verbal comments as follows:

In my testimony, I questioned the reasonableness of coercing compliance from state residents instead of offering people a solution similar to previous energy transitions where people chose the change themselves, e.g. kerosene or whale oil to electricity, or horses to automobiles. One could add any number of other transitions: pony express to telegraph, telegraph to radio, radio to television; crank telephone to corded telephone to wireless to cell phones; coal or wood to other fossil fuels for space heating; open windows to air conditioning; the list goes on and on! The commonality for all of these is that people chose to adopt these changes for themselves because they believed the new technologies bettered their lives and were in their own best interests. The government did not dictate or coerce the whole of society to change based on their assumed wisdom. They trusted the people to make the best decisions for themselves.


In the present situation however, the government, in the form of the State Legislature, the Governor, the Climate Action Council, and other agencies (including the Public Service Commission), have now decided they know best and are proposing to use the power of the State to coerce change because they think they know best. No gas connections after 2024; no gas appliances after 2030; no fossil fueled vehicles after 2035……. And on and on with little regard for the desires of the citizens or their freedom to live their lives as they see fit.

I also addressed the impracticality of doubling the capacity of the electrical system: generation; transmission; distribution, in the next eight years as proposed. Ask anyone in the utility industry with experience in constructing new facilities how long it takes to design, get approval for and construct new or even upgraded facilities and they will tell you that doubling capacity in eight years (or less) is not only impractical, but impossible. Even if by fiat the State was to order such a change, there is little recognition in the plan for the social upheaval that would result from constructing hundreds of miles of new transmission lines and digging up every urban area and suburban neighborhood with underground utility services for years in order to implement the upgrades.

Written Comments

I have posted the complete set of comments for your information.  Because they are so extensive, I am not going to provide them all here.  Instead, I will provide some highlights of the main points presented.

The comments pointed out the practical problems converting the entire energy system to electricity.  The schedule is impractical solely due to the number of conversions of homes, businesses, and vehicles.  Throw in supply chain, technology development needs, and supporting infrastructure requirements he notes that the level of this transition on the proposed schedule just can’t work as proposed.

He raises philosophical concerns.  He asks “how sure are we that climate change is real; that man is the principal driver of climate change; that man’s actions can be modified to effect a meaningful change; and that such change would actually benefit mankind?”  I particularly like his discussion of “settled science”:

Man-induced climate change is not “settled science” no matter what we are told. In fact “settled science” is an oxymoron to science itself. Science is the continual process of questioning everything. When someone tells you not to question, they have stopped being scientists and become politicians with an agenda. In fact, there are many highly qualified scientists who question the theory of man-induced climate change and the practicability of man being able to control the climate in meaningful ways. Honestly, the idea that men can control climate is egotistical at best and ridiculous at worst. Man is much more capable of adapting to, rather than controlling climate or weather.

He also raises technical issues with climate modeling.  I like this comment:

They are trying to project the climate for the next hundred years. Really!?! There are so many data points and interactions, that such an effort is futile. Considering that the input data is from a couple of hundred of years at best, the period of record seems horrifically short considering that climate has been changing for thousands of years. Then they want us to believe that they understand and have programmed the models to accurately predict the interactions of the millions of variables.

He also raises two legal issues: 

When is the New York State Environmental Quality Review Act (SEQRA) triggered and the plan subjected to that review?

The plan appears to violate the “taking” provision of the United States Constitution’s 5th amendment and the New York State Constitution.

In my opinion the response to the SEQRA question raised will be that they did do an analysis.  However, to my knowledge they have not evaluated the current projections for wind, solar, and energy storage development.  Also note that there is a generating type called dispatchable, emission-free resource that is projected to have a capacity (MW) approximately equal to the current fossil-fired capacity.  They cannot possibly determine environmental impacts without knowing what that resource will be.

The legal question about the taking” provision of the United States Constitution’s 5th amendment and the New York State Constitution is an interesting point.  As he points out “the forced abandonment of natural gas systems, fossil fired generation facilities, natural gas appliances, personal and commercial fossil fueled vehicles, and perhaps other privately held property, would constitute a “taking” and therefore require compensation”.  There is no indication in the Draft Scoping Plan that those costs have been considered.

Schoonmaker also raised ethical issues:

At what point does the concept of individual freedom become subservient to the State’s coercive powers? This is something that is questioned in far more than the subject at hand, but in this case, as in earlier energy transitions, people should not be coerced under an arbitrary and unsubstantiated timeline, but allowed to choose for themselves as the change actually benefits them at the proper time. In the meantime, we can all adapt as we see fit.

He concludes:

Instead of the heavy-handed coercion of the present plan (and even legislation), we should slow down and let people choose for themselves as the technology matures and provides the incentives for people to change if it benefits them. I have a friend who just bought a hybrid pick-up truck and he is very happy with it. Perhaps that is a better way to go than pure electric. This draft plan doesn’t allow for that option.

Natural gas is a relatively clean fuel as is nuclear, but both are excluded.

Hydrogen and fuel cell technology also hold significant promise for working towards the goals of the plan, but would be excluded if the plan was to be implemented as scheduled. People at the hearings made strong arguments for winterizing older homes as an initial step towards reaching the goals of the plan, but they were apparently dismissed for not being aggressive enough. Actually, aggression is a good word to describe the proposed plan: aggressive and confrontational and offensive to the American principles of individual freedom, free choice and justice.

My Thoughts

I had not thought of the transition in the way Schoonmaker described it in his comments before I heard him speak.  His point that this transition is different is spot on.  In the past energy transitions occurred because it was in the best interests of society because of cost and quality of life improvements.  In this transition we are expected to swallow more expensive, less convenient energy options because we are told the science says we have to do it.  However, when we ask questions about that science, we are told it cannot be questioned and that we are deniers for even considering that maybe the rationale is not as strong as we have been told.  Schoonmaker questions the climate science but notes that he is not a climate scientist.  Neither am I but at its core the belief that anthropogenic greenhouse gas emissions will cause an inevitable climate crisis is an air pollution meteorology problem.  I have 45 years experience in that field and I know the air pollution science does not support the energy transition proposed.  The climate science part of this is only a portion of the whole issue and very few climate scientists have the air pollution background necessary to understand the limitations of their approach.

The same tactic is being used for the energy transition.  Schoonmaker has enough experience in the electric energy sector to know that transitioning away from the current system to one dependent upon wind and solar generation poses real risks to affordability and reliability.  The Climate Action Council’s last meeting included one member claiming that raising that concern is “misinformation”.  With all due respect, he simply does not understand if that is what he believes.  The Council has not adequately addressed the reliability concerns raised by people who understand the issues.  If the Administration does not step in and insist that the Final Scoping Plan reconcile their concerns, then it will lead to unaffordable electricity and catastrophic reliability problems.

Draft Scoping Plan Comments on Electric Vehicles

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The plans for this transition are described in the Draft Scoping Plan. This post discusses the comments I submitted on electric vehicles in the transportation sector discussion of the Plan.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until July 1, 2022.

I prepared the comments described here because I found that the Integration Analysis is simply making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  I am convinced that the Integration Analysis future energy system modeling did not consider feasibility in any of its projections.  Instead, the analysts simply tweaked projection assumptions until they got the reductions they needed. 

Cost Issues

The Integration Analysis projections for electric vehicle costs start in 2020.  Note, however, that 2020 is a modeled year,” reflecting historical trends”.  I don’t think that the observed data in 2020 and 2021 is consistent with the model projections. For one thing the analysis projects a decrease in the EV costs and this was not observed.  In my comments I recommended that the final Scoping Plan address those discrepancies. 

As far as I can tell, the electric vehicle costs are based entirely on new vehicle sales. There is no acknowledgement that the used car market will likely change because of the cost of battery replacement.  Sellers will likely get less relative to new cars in the battery electric vehicle market.  Buyers may get a relative deal but will lose in the end when the batteries have to be replaced.

My comments analyzed the Integration Analysis spreadsheet documentation.  The total costs for vehicles and a charging system for each new zero-emissions vehicle for the Reference Case are shown at the top of the Light Duty Vehicles Total New Vehicle Costs of Vehicles and Chargers table.  The cost from 2020 to 2050 is $619.6 billion.  The scenario minus reference case costs are listed for each scenario in the lower section of the table.   The biggest problem is that the device costs for zero-emissions charging technology and the vehicles themselves is presumed to decrease significantly over time.  Home EV chargers and battery electric vehicles both are claimed to go down 18% between 2020 and 2030.  The cost decreases are so large that the total costs for the zero-emissions vehicles adoption is cheaper than using existing technology by $44 billion for Scenario 2 and $37.8 billion for Scenarios 3 and 4.

One issue I have with the Integration Analysis spreadsheets is that the data provided cannot be used to reproduce the total numbers.  For example, the device costs for different types of medium-duty trucks, heavy-duty trucks, and buses are listed.  To get those cost, device prices have to be multiplied by the sales for each category.  The Integration Analysis spreadsheet provides the sales for combined medium and heavy-duty vehicles.  Without knowing how those totals are broken down by the device cost categories it is impossible to estimate the total costs.

Even without being able to calculate the costs for those vehicles there is an apparent inconsistency with the recently released net present value of system expenditures.  The transportation investment cost for the Reference case in Figure 48 is $1,056 trillion and the costs for the mitigation scenarios are higher by between $3 and $40 billion.  As shown above light-duty vehicle costs relative to the Reference Case are lower by $38 to $40 billion.  As noted above, I cannot provide precise numbers for the medium-duty trucks, heavy-duty trucks, and buses category but the device costs decrease similarly to the light duty vehicles.  I guess the costs would be an order of magnitude less.  Consequently, I am comfortable saying that the mitigation scenarios are projected to be $40 billion less than the Reference Case.  I could find no cost numbers for the other components of the transportation category such as aviation, public transit and railroads.   Light-duty vehicles account for two thirds of the total transportation sector emissions and the total costs for the light duty vehicles in my estimate of costs is about the same fraction. As a result, I don’t expect that the costs for the other sectors will be so large to account for the difference between reference case in Figure 48 $3 to $40 billion and my estimates which are negative $40 billion.  Simply put, the costs are included in the Reference Case for the cost benefit analysis in Figure 48 and the Integration Analysis spreadsheets costs are inconsistent.

Implementation Issues

There is no bigger disconnect between the ZEV proposed strategy and reality than the ZEV charging infrastructure requirements.  The biggest problem is the millions of cars will have to rely on chargers that cannot be dedicated for the owner’s personal use because the owners park on the street or in parking lot.  In order to provide a credible ZEV strategy, the final Scoping Plan has to describe a plan how this could possibly work.  The Integration Analysis simply presumes that it will work.

The Draft Scoping Plan assumes without documented analysis that zero-emissions trucks will be viable alternatives to current equipment.  It is not enough to say they are viable because they have started to appear on the market.  They must be tested.  Moreover, there is no recognition that the trucking industry is nation-wide.  If the proposed zero-emissions technologies costs are cheaper and don’t impose marked changes to operations then everyone will convert because it is a better solution.  However, if it is not a better, cheaper solution that drives adoption of zero-emissions vehicles everywhere what is the plan for out-of-state vehicles?   I cannot imagine that trucks will have to meet New York registration requirements if they are just passing through the state.  If deliveries to New York must use zero-emissions vehicles that would mean swapping the motive power and that would markedly increase costs.  Because of its importance to the viability of the Integration Analysis the final Scoping Plan should account for these issues.

My analysis of the Integration Analysis spreadsheet documentation showed another issue.  The analysis presumes an unprecedented adoption rate for light-duty electric vehicles but provides no reason why this is possible.  Anecdotally, I don’t want to accept the downsides of an electric vehicle for my lifestyle and the vast majority of my friends feel the same way.  Where is the evidence that people will willingly choose zero-emissions vehicles?

Public Engagement

A common theme in the Draft Scoping Plan is that any doubts that the public has about any aspect of the net-zero transition can be simply addressed by convincing them with appropriate information.  I guess the Draft Scoping Plan assumes that this will drive the adoption rate.  The problem is that the draft Scoping Plan only tells one-side of the story instead of presenting all the issues and making a case for their preferred approach.  Simply put, that is propaganda and it has no place in the Scoping Plan.

There is another disconnect between the public and the Climate Action Council when it comes to grid-interactive assets. This refers to using electric vehicle batteries as storage for the grid at times when the grid needs the power.  I am positive very few people know about this component of the plan and cannot imagine public acceptance when they are told about it.  The concept is that their vehicles will be grid-interactive assets and that means that they will lose control of their vehicle’s range because someone, somewhere decides that the power they have stored in their car for their own use is needed somewhere else.  The personal inconvenience of that loss of control is a losing proposition in my opinion.

There are many specific issues with zero-emissions vehicles that are not addressed in the Draft Scoping Plan.  As the United Kingdom implements their own EV mandates electric system upgrade costs have become obvious.  California is leading New York in EV adoption but there are warning signs that implementation is not working out as expected.  None of the apparent unintended consequences are addressed.  Safety issues related to fires are becoming an issue but the Draft Scoping Plan does not recognize the issue. 

Conclusion

I think that the transportation sector strategies in the Draft Scoping Plan are mostly wishful thinking.  As the technology stands now it will be a long time before there isn’t a cost premium to get comparable vehicle capabilities for both new and used vehicles.  The Integration Analysis projected deployment rates and device costs are both overly optimistic.  The final Scoping Plan should present bounded estimates of costs and impacts and provide documentation that describes the positive and negative issues associated with electric vehicle deployment.  The documentation has to make its case relative to the other side of the story and not simply ignore that there are any downsides or uncertainties.  I am particularly concerned that the feasibility of the planned transition relative to affordability and reliability has been ignored.

Climate Act Draft Scoping Plan Transportation Sector Scenarios

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The comment period for the Draft Scoping Plan is open until June 10, 2022.  The Council requested feedback on the components of three mitigation scenarios.  My overview summary of the components described the scenarios and I previously described the building sector scenarios.  This post discusses the control measures in the transportation sector and supplements an earlier article addressing transportation costs.

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until July 1, 2022.

Integration Analysis Reference Case and Scenarios

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates in December 2021.  I refer you to my building sector scenario post for more details.  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)”.  Subsequently, the consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   The three mitigation scenarios are described in Section I on page 14.  This article describes the transportation sector actions.

Table 16. Level of Transformation by Scenario: Transportation from Appendix G Section I page 118 lists the transformation strategies for the transportation sector.  It would take an extraordinary amount of work to debunk these wishful thinking strategies that may sound good for the Draft Scoping Plan but will not necessarily work in the real world.  I will give just one example: rail transportation. 

I previously addressed one particular aspect of transportation sector costs: the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 relative to Scenario 4.  The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion.  I estimate that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a reduction of 64.7 million miles.  While my estimate is for 2035, consistent with the Empire Corridor evaluation, and the Draft Scoping Plan is for 2050, I don’t think there is any question that the numbers are inconsistent.

Within the non-road transportation category in Table 16, the rail component for all three scenarios states “90% electrification, 10% hydrogen use in 2050”.  There is no detail of how those categories are broken out.  According to Appendix G, Scenario 4 would get additional vehicle miles traveled reductions by using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS”.  That alternative calls for an electrified passenger rail line from New York to Buffalo, including a completely new line between Albany and Buffalo.  I cannot say if the plan is to add catenary to electrify the railroads or use battery-electric locomotives.  Hydrogen (via electrolysis) is listed under the low-carbon fuels category and is supposed to be used for medium and heavy-duty vehicles and freight rail.  Because freight transportation energy use exceeds passenger energy use, I assume that freight locomotives will be a mix of hydrogen and electric power.

There are two issues.  The Appendix G Scenario 2 transportation investment category is only $3 billion more than the Reference Case, $15 billion for Scenario 3 and $40 billion for Scenario 4.  In the absence of documentation, I can only guess that the different railroad transportation strategies in Scenario 4 reflect the added costs.  Secondly, my interpretation of this strategy is that the Draft Scoping Plan expects that within New York State, railroad locomotives will have state-specific limitations.  The problem is that the major railroads operate their locomotives over much greater distances than New York State.  A train carrying containers from the West Coast might change locomotives once or twice but certainly runs through from the Midwest.  Is the Scoping Plan expectation that there will be a change of locomotives at the state line?  Theory may be fine but the practical implementation introduces a whole host of logistical issues and hidden costs.

Electric Vehicles

The Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions table lists specific programs in the Reference Case.  Table 1 extracts assumption data from that spreadsheet so that the Reference Case and mitigation scenarios can be compared. 

Consider the light duty vehicle strategies.  For all motor vehicle registrations in New York in May 2022 there are only 62,123 electric vehicles statewide.  The Integration Analysis projects that there will be 138,156 light-duty electric vehicles in 2025 in the Reference case.  Scenario 2 projects 257,718 LDEV in 2025 and both Scenarios 3 and 4 project 275,417.  In order to reach those levels, there will have to be a significant increase in electric vehicle sales. 

My concern is that this increase in EV sales is based on no documented references.  As Christian Twiste writes the current reality is very much different:

The average electric vehicle cost $65,977 as of March, compared to an average price of $45,927 across the entire industry, and a much lower price of $26,052 for a compact car, meaning going electric will cost a frugal family over 250% more than opting for a small car mainstay like a Toyota Corolla or Honda Civic.  Even if you have the funds and are willing to spend them, Politico reported last weekend that most models are sold out until next year.  Ford and Volkswagen both anticipate no new vehicles being available until 2023.  Tesla’s least expensive model won’t be available until December, and Rivian, a new entry in the market, was forced to cut production in half this year due to supply chain issues. 

The unprecedented buildout proposed in these Draft Scoping Plan scenarios has to be documented to be considered viable.

EV Charging

The LDV charger cost comparison table extracts data from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet related to charger systems.  The Electric Vehicle Supply Equipment: Per-Vehicle Costs section at the top of the table lists cost directly from the Integration Analysis spreadsheet.  In a previous article I found a reference bus charging infrastructure.  The Center for Transportation and the Environment (CTE) Charging Infrastructure webinar listed costs between $5,000 and $7,000 for an AC level 2 charger and between $50,000 and $70,000 for a DC level 3 charger.  There is an obvious disconnect between those numbers and the $24,000 value for 2020 in this table.  More disturbing are the cost projections over time.  The Integration Analysis projects a cost decrease of 18% for light duty vehicle battery chargers between 2020 and 2030, a 41% decrease between 2020 and 2040, and a 61% decrease between 2020 and 2050.  The first ten years the price decreases by 18%, the second ten years the price decreases another 27% and the last ten years the price decreases another 34%.  Sorry I am not buying this incredibly optimistic assessment of future cost reductions without documentation.  The fact that the battery charging cost reductions are identical to the hydrogen fuel cell cost reductions suggests that some analyst simply made an assumption.

The total costs of course reflect these optimistic charger costs.  Assuming that every new car needs a new charger, I multiplied the number of new battery electric light duty vehicles by the charger cost.  Relative to the Reference Case the projected costs of battery electric light duty vehicles is projected to be $15 billion for Scenario 2 and $18.5 billion for Scenarios 3 and 4.  Note that if the cost for chargers stays the same then the the projected cost is $37 billion for Scenario 2 and $42 billion for Scenarios 3 and 4.  There is an associated issue that I could not address due to the poor documentation.  The expected lifespan of an electric vehicle charging system is ten years.  I don’t know if the final costs in the Draft Scoping Plan incorporate the lifespan adjustment that is going to increase costs markedly.  That adjustment means that the real charger cost has to account for all the cars in the New York fleet.  The final Scoping Plan should clarify whether those costs were included.

Light-Duty Vehicle Costs

The LDV Zero-Emission Vehicle Costs table extracts data from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet related to the costs of light-duty vehicles themselves.    The Transportation – Vehicle Cost by Technology: Reference Trajectory section at the top of the table lists cost directly from the Integration Analysis spreadsheet.  Note the cost of zero-emissions battery electric $43,794 and hydrogen fuel cell vehicles $58,392.  The following table from Inside EVs lists the costs of battery electric vehicles on September 18 2022.  There are 63 car models listed and there are only 13 models less than the Integration Analysis estimate.

https://insideevs.com/news/534027/electric-car-prices-us-20210918/

Similar to the car charging the cost projections over time are disturbing.  The Integration Analysis projects a cost decrease of 35% for light duty battery electric vehicles between 2020 and 2030, a 42% decrease between 2020 and 2040, and a 44% decrease between 2020 and 2050.  The first ten years the price decreases by 18%, the second ten years the price decreases another 11% and the last ten years the price decreases another 3.4%.  Sorry I am not buying this optimistic assessment of future cost reductions without documentation. 

I also calculated the total costs for vehicles over the period 2020 to 2050 in the LDV Zero-Emission Vehicle Costs table.  The total cost for new vehicles in the Reference Case is $619.6 billion.  Scenario 2, Strategic Use of Low-Carbon Fuels, total costs are $575.6 billion so the Draft Scoping Plan claims that converting to zero-emission vehicles will cost less than the Reference Case by $44 billion.  The assumptions for Scenarios 3 and 4 must be identical because they both have a total cost of $581.8 billion for a difference of $37.8 billion.  The massive cost reductions projected for zero-emissions vehicles is most of the reason that converting to zero-emissions is cheaper.  Note that the apparent difference between the scenarios is the use of hydrogen fuel cell vehicles in Scenario 2.

Conclusion

In order to provide meaningful comments, the documentation has to be improved.  In the first place, I recommend that all control measures should be listed, with the assumptions, costs and expected emission reductions provided.  That information could clarify the questions about the differences between scenarios for the railroad projections.  Without it I can only note that the projections seem inconsistent with the primary source mentioned.

Both the charger cost and zero-emission vehicle cost projections are overly optimistic about the future.  The final Scoping Plan must update the analysis to incorporate what has happened since the Integration Analysis projections were completed.  Costs have not been going down as projected for 2022.  If they cannot forecast a couple of years ahead correctly then estimates out to 2050 are not credible.

The purpose of this analysis was to compare the transportation scenarios for the three mitigation scenarios.  There is insufficient documentation to determine if the differences are meaningful.  I cannot make any comments on the transportation sector scenario differences.

Draft Scoping Plan Comments Submitted in May

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. The Draft Scoping Plan that describes how to meet those goals was released to the public at the end of 2021 and the comment period is open until June 10, 2022.  This post describes comments that I submitted in May 2022 for your information and in hopes that others will be encouraged to submit their own comments. 

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

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

The remainder of the article lists the summaries of comments that I submitted in May 2022.

Caiazza Comment Electric Service and Distribution System Upgrades Needed for Electric Heating

I submitted these comments on May 15, 2022.  They are based on the work of Kip Hansen.  He estimated costs associated with the distribution network for upgraded residential electric service; electrical distribution system improvements so that all homes can heat with electricity and use the more usual and affordable” overnight electric vehicle chargers; and disconnecting natural gas supplies.  I applied his reference information to New York and found that these costs range from $16.8 to $43.1 billion.  These costs don’t include “the costs to homeowners, who must pay for the service upgrade, service entrance wires, and circuit breaker panel box. And, of course, does not include the purchase new appliances or the installation of EV chargers.”  This cost estimate also does not include disconnection costs for fuel oil or propane heated homes.  Finally, these estimates only apply to single family homes and not the 4.2 million housing units that are in multi-family buildings.

I believe the Draft Scoping Plan should describe all the control measures, provide references for assumptions, list the expected costs for those measures and list the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  This information is not available so I could not confirm that these costs are included in the Integration Analysis or provide the opportunity to provide meaningful comments. 

Caiazza Personal Comment on the Benefits Greater than Costs Claim 

I submitted these comments on May 30, 2022 to incorporate the cost data that was released last week. The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   In my verbal comments at the Syracuse Climate Act public hearing I said that statement is inaccurate and misleading.  This comment explains why that the Draft Scoping Plan must address this issue and makes recommendations for changes to language to clarify the caveats associated with the claim.

These comments show that the trick used to deceive the public into hearing that benefits out-weigh costs excludes legitimate Climate Act costs by mis-categorizing initiatives such as the 2035 zero-emission vehicle mandate as part of the business-as-usual Reference case.  In addition, the Plan uses incorrect guidance to inflate the societal benefits of avoided emissions.  The final Scoping Plan should describe all the control measures, provide the assumptions used for the strategies, and list the expected costs and expected emission reduction for each measure for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios so the public can decide for themselves which costs associated with “already implemented” program are appropriate. 

Caiazza Personal Comments on Benefits of Climate Action

I submitted these comments on May 31, 2022 to include the information on my Citizens Guide Climate Act Effects on Global Warming Page into the record. The Draft Scoping Plan asserts that there will be benefits from the implementation of the Climate Act but provides no documentation to support that claim.  These comments highlight the claims that must either be substantiated by analysis and documentation or removed from the final Scoping Plan.

These comments include my personal analyses of the potential effect of the Climate Act on global warming and global emissions both as an example of the analysis necessary to make claims and as a cautionary tale.  The fact is that any expectation that the Climate Act will have any detectable effect on the severity of current or future climate change is mis-placed because the expected impact on global warming is an immeasurable 0.01°C by the year 2100.  If you cannot measure the change in temperature there is no way you can detect a change in the purported effects of that temperature change.

In addition, when New York’s emissions are considered in the context of global emissions it is unreasonable to expect that other jurisdictions will be encouraged to implement similar restrictions.  In the first place, New York’s emissions are less than one half of one percent of global emissions.  At the same time, New York’s 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world.  That ranking was achieved in no small part because New York has had access to abundant, reliable, and affordable energy for many years.  Expecting that countries without our wealth will be encouraged to develop costly zero-emissions energy resources is naïve and immoral.

Conclusion

There are not many days left until the end of the comment period.  I am planning to submit as many comments based on the work done in my blog as possible in that time.  If time were not so short, I would spend more time writing stand-alone articles for the blog.  As an alternative I am just going to copy the summary from comments submitted as a blog update every few days for the next couple of weeks.

If you are a New Yorker, I encourage you to submit comments at the Climate Act comment page.  I fear the only thing that we can count on from the comments submitted is a tally of how many people support the Draft Scoping Plan versus how many people don’t.  In New York’s political climate it is all about the numbers and not the science, technology, or expert opinion.  Just go to the page and you can enter 2000 characters of text as a comment.  If nothing else just explain that you have concerns about reliability, affordability, safety and lack of personal choice associated with the transition to net-zero.  Feel free to copy as much of my material as you want and do not feel obligated to mention the source.

Climate Act Benefits Greater than Costs Claim Numbers Update

One of the key claims in the Draft Scoping Plan documentation is that “The cost of inaction exceeds the cost of action by more than $90 billion”.  Last month I consolidated documentation that had been presented in multiple earlier posts that supports my statement that the costs far exceed the benefits.  The single most glaring omission of the Draft Scoping Plan is the near complete lack of cost documentation but with two weeks left in the comment period some of the numbers that were used in the Benefits and Costs chapter of Appendix G were made available.  This post uses the new information provided to evaluate the benefits claim.

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

Climate Act Background

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

At a recent meeting there was an opportunity for the public to ask questions about the New York State Energy Research & Development Authority (NYSERDA) work supporting the Draft Scoping Plan.  I asked about the missing cost information and John Williams, Vice President, Policy and Regulatory Affairs, responded:  “In response to your inquiry for additional cost information, we have added clarifying information to the existing Excel document, ‘Appendix G Annex 2: Key Drivers and Outputs,’ which can be found on the Climate Action Council Draft Scoping Plan website.”  I extracted all the new tables to a separate spreadsheet.  The spreadsheet table summarizing the cost methods is difficult to read so I have also extracted that information in a document. Also note that more detailed documentation for my cost-benefit analysis is available here and here.

Benefits Exceed the Costs Claim The Draft Scoping Plan claim that “The cost of inaction exceeds the cost of action by more than $90 billion” is presented in Figure 51 in Appendix G Integration Analysis Technical Supplement. The Climate Act overview presentation for the public hearings included a similar figure and made the claim.  However, there is a caveat or in this case, a trick.  In the following figure I have highlighted the description that notes that the benefits are “relative to Reference Case”.  By the way, that caveat is usually not noted when these results are presented.  The clarifying data in the updated spreadsheet lists all the values in the table.  Because the values are exactly the same, I believe the updated spreadsheet numbers were simply pulled from the figure and not from the analyses themselves.

Reference Case Costs

The next figure I evaluated in my analysis of the benefits claim was the total system expenditures shown in Figure 48.  My biggest gripe was that the values in the Figure were not quantified.  Thankfully the clarifying data in the updated spreadsheet provides numbers.  The Reference Case total in the following table lists the net present value of system expenditures as $2,665 billion.  Scenario 2, low-carbon fuels expenditures are $2,974 billion; Scenario 3, accelerated transition expenditures are $2,953 billion; and Scenario 4, beyond 85% reductions expenditures are $2,972 billion.  More importantly the category costs are now available.  Note that these numbers are not rounded in any way so I believe that they were copied from a different spreadsheet or model.

I have frequently heard Climate Action Council member refer to the net cost totals in Figure 47 as the costs of Climate Act implementation.  However, these costs are relative to Reference Case for the three mitigation scenarios.  In other words, the numbers presented subtract out the Reference Case costs. As explained in the previous post, the rationale for this approach is those estimates include not only the business-as-usual programs but also programs that are already implemented.  This new cost information can be used to see if these already implemented programs are really business-as-usual strategies.

Category Cost Implications

The clarifying information update provides numbers associated with each category in Figures 47 and 48.   In this section I will address three of the more impactful categories. 

The “Buildings Investment” category “Includes capital and operating expenses for building equipment and appliances (e.g., space heaters, air conditioners, water heaters) and investments for building shell upgrades”.  The net present value of system expenditures from 2020 – 2050 is $565 billion for the Reference Case.  The building sector costs for the mitigation scenarios only range from $235 billion to $240 billion (42% increase) but the emission decreases relative to the Reference Case are 95% greater.  In my opinion, that seems inconsistent with the Reference Case costs.  It appears that Reference Case cost reductions per ton are double the mitigation scenarios.  This anomaly could be caused by excluding the costs but including the emission reductions from the presented numbers.

The ”Transportation Investment” category “Includes capital and operating expenses for light-duty vehicles, medium- and heavy-duty vehicles, and buses, in addition to charging infrastructure costs”.  The net present value of system expenditures from 2020 – 2050 is $1,056 billion for the Reference Case.  Previously it appeared that the bar chart components difference to add charging infrastructure and the additional costs of electric vehicles relative to current alternatives seemed unacceptably low.  According to the Integration Analysis, Scenario 2 transportation initiatives will reduce emissions 79% relative to the Reference Case at a cost of only $2.97 billion.  Obviously, this does not pass the smell test.  Something is overlooked or deliberately manipulated to make this claim.

The Figure 47 category label is Electricity but the description in the cost methods overview table is Electricity Incremental.  I assume they are the same.  The description of this category states that it “Includes capital and operating costs for electricity generation, transmission, costs to upgrade existing distribution system, and in-state hydrogen production costs.”  The net present value of system expenditures from 2020 – 2050 is $424 billion for the Reference Case.  The Integration Analysis described in the Draft Scoping Plan projects that the additional costs necessary to transition the electric grid to zero-emissions ranges between $89 and $111 billion.  According to the Integration Analysis that covers the cost of between 5,659 and 7,265 MW on additional land-based wind, 7,393 and 9,310 MW of additional off-shore wind, 40,648 and 45,254 MW of additional solar, and 10,987 and 14,731 MW of additional energy storage beyond the capacity expected in the Reference Case.  The additional costs necessary to the transition the electric grid to zero-emissions range between $89 and $111 for incremental electricity.  Many things are overlooked or deliberately manipulated to make this claim.  A US Energy Information Agency (EIA) report “Capital Cost and Performance Characteristic Estimates for Utility Scale Electric Power Generating Technologies” published in 2020 estimates that a 200 MWh battery energy storage system has a capital cost of US $65.9 million.  Assuming that the average of the additional energy storage capacity provides four hours of energy for every MW and using the EIA cost number, energy storage costs alone are $213 billion. 

Discussion

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

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

The newly released categorial cost data provide evidence of similar manipulation of the data for other categories to provide the desired result.  The building sector costs for the mitigation scenarios only range from $235 billion to $240 billion (42% increase) but the emission decreases relative to the Reference Case are 95% greater.  The numbers also confirm my initial transportation initiative concerns.  According to the Integration Analysis, Scenario 2 transportation initiatives will reduce emissions 79% relative to the Reference Case at a cost of $2.97 billion.  The Integration Analysis projects that just the cost of battery electric vehicle chargers will be over $15 billion for Scenario 2 relative to the Reference Case.  Finally, the claim that the additional costs necessary to transition the electric grid to zero-emissions range between $89 and $111 for incremental electricity are ludicrous.  I estimate that the additional energy storage costs alone are $213 billion more than the Reference Case costs.

Conclusion

In my opinion the Climate Act claim that the benefits out-weigh costs is obviously incorrect.  I have shown the recently released numbers confirm my earlier analyses.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.   In order to fulfill this obligation, the Draft Scoping Plan must describe all control measures, assumptions used, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  Given the overt manipulation of the data used to erroneously claim that “The cost of inaction exceeds the cost of action by more than $90 billion”, I have no faith in any cost numbers presented without that documentation.