It seems that every day we are faced with another claim that we are facing an existential threat from climate change and the proof is right in front of us. So simple, so obvious and so wrong. I do not have time to do my own analysis so I am going to use the work of others to rebut the fear mongering stories about these events tied to climate change in July.
July was the Hottest Month Ever
The story that July was the hottest month in 120,000 years is the best example of the media glomming on to a story that does not stand up to scrutiny. A post at Watts Up With That explains:
Via The Australian: Cliff Mass, professor of Atmospheric Sciences at University of Washington, said the public was being “misinformed on a massive scale”: “It‘s terrible. I think it’s a disaster. There’s a stunning amount of exaggeration and hype of extreme weather and heatwaves, and it’s very counter-productive,” he told The Australian in an interview. “I’m not a contrarian. I‘m pretty mainstream in a very large [academic] department, and I think most of these claims are unfounded and problematic”. …
Professor Mass said the climate was “radically warmer” around 1000 years ago during what’s known as the Medieval Warm Period, when agriculture thrived in parts of now ice-covered Greenland. “If you really go back far enough there were swamps near the North Pole, and the other thing to keep in mind is that we‘re coming out of a cold period, a Little Ice Age from roughly 1600 to 1850”.
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John Christy, a professor of Atmospheric Sciences at the University of Alabama at Huntsville, said heatwaves in the first half of the 20th century were at least as intense as those of more recent decades based on consistent, long-term weather stations going back over a century. “I haven‘t seen anything yet this summer that’s an all-time record for these long-term stations, 1936 still holds by far the record for the most number of stations with the hottest-ever temperatures,” he told The Australian, referring to the year of a great heatwave in North America that killed thousands.
Professor Christy said an explosion of the number of weather stations in the US and around the world had made historical comparisons difficult because some stations only went back a few years; meanwhile, creeping urbanization had subjected existing weather stations to additional heat. “In Houston, for example, in the centre it is now between 6 and 9 degrees Fahrenheit warmer than the surrounding countryside,” he explained in an interview with The Australian.
Professor Christy, conceding a slight warming trend over the last 45 years, said July could be the warmest month on record based on global temperatures measured by satellites – “just edging out 1998” – but such measures only went back to 1979.
Phoenix Heat Wave
Phoenix Arizona had a streak of 31 days when the high temperature was 110 degrees or higher. The article, “Explaining The Heat Wave: Separating Weather From Climate Change,” claims that recent warming trends in Phoenix, Arizona are due primarily to increasing atmospheric carbon dioxide levels in the atmosphere. However, this is false because data show that the high levels of warming, especially at night and as measured at an airport, are primarily due to urbanization over time, with the modest warming of the past hundred-plus years playing a very small part in comparison. Another rebuttal notes:
But, it must be climate change, look how hot it was!” My dear readers, that’s why they named it Death Valley. The Monthly Report from the U.S. National Weather Service for the Death Valley station shows that every day during July this year, the average daily temperature (Daily Maximum + Daily Minimum divided by 2) was in excess of 100 °F (37.7 °C). That’s the average! The daily highs were above 110 °F (43 °C) every single day, above 120 °F (49 °F) twenty of the days.
Is this unusual? Is this “extreme”? No, the U.S. National Park Service reports on the general the Weather in Death Valley: “Death Valley is famous as the hottest place on earth and driest place in North America. The world record highest air temperature of 134°F (57°C) was recorded at Furnace Creek on July 10, 1913. [ emphasis mine – kh ] Summer temperatures often top 120°F (49°C) in the shade with overnight lows dipping into the 90s°F (mid-30s°C.) Average rainfall is less than 2 inches (5 cm), a fraction of what most deserts receive. Occasional thunderstorms, especially in late summer, can cause flash floods.” All of those conditions, except the record high temperature of 1913, occurred this summer in Death Valley, just as the National Park Service advised visitors to expect. There was not any extreme weather, it was usual weather for Death Valley.
Climate Fact Check
If you want short rebuttal summaries to these and other false climate change stories for July check out this fact check report. It covers the following stories: monthly average temperature is the hottest, the UN proclamation that we are in an era of global boiling, the hottest day in 125,000 years, Atlantic current to collapse by 2025, record for hot days in Phoenix, hottest day in Death Valley, emissions causing hot oceans, hottest seawater ever, and more.
Heat Health Impacts
The rationale for alarm for the excessive heat stories is the argument that heat results in more deaths than any other weather-related event. Five years ago I explained why there are analyses that find “most of the temperature-related mortality burden was attributable to the contribution of cold”. Studies that show that extreme heat results in more deaths than any other weather-related event use a data base that only includes direct deaths. An epidemiological study that does include indirect deaths concludes most deaths are associated with moderate cold weather. Roger Pielke Jr. reports how this information can be presented to support the alarmist version:
The Lancet was caught red-handed publishing a figure that, to be as fair as possible, lent itself to misinterpretation (it was first called to my attention by Bjorn Lomborg and is in a paper by Masselot et al. 2023).
Take a look and decide for yourself. Here is the original figure comparing mortality from cold (blue) and heat (orange) in Europe from 2000-2019.
And here is how it looks when the data is graphed using a consistent scale.
Another Examples of Propaganda
We have all seen the graphs that show inexorable global warming. However this article describes how “alarmist scientists have scared the bejesus out of people by turning a very small temperature change into a monster.” Jim Steele writes:
Dr. Lindzen graphed the average seasonal anomalies for each weather station in the BEST temperature data base from 1900 to the present. A station’s anomaly is defined as any deviation from its 30-year mean. The results are not very scary. On any given day about half the weather stations experience warm anomalies while half experience cooling anomalies.
Most anomalies cluster between ± 4°C (+/- 7.2°F) causing each data point to merge into the thick black band of the graph. Still, larger anomalies are not uncommon, so the y-axis of the above graph scales between ± 12°C (+/- 21.6°F). The yellow dots represent the average for those anomalies on any given day. We see a small trend that is relatively tiny compared to the variation in actual temperatures. Not very scary either.
So, the showtime graphs isolate the average anomalies from reality, as done in the bottom graph. Now the scale on the y-axis only spans from -0.8°C (-1.4°F) to 1.2°C (2.2°F), turning a small 1°C (1.8°F) rise over 120 years into the illusion of a monster increase. That allows click-bait media, alarmists scientists and politicians to claim that climate change could lead to mass extinctions.
Reporting Issues Influence Results
Roger Pielke Jr. is an expert on the topic of global disaster accounting. He recently posted an article that makes two relevant points to this post:
Below is the updated time series of global hydrological, climatological and meteorological disasters in the EM-DAT database, along with the linear trend, over the period 2000 to 2022.
You can see that there is no upwards trend. This lack of trend has not been reported by anyone in the legacy media (and I would be happy to be corrected). However, the completely false notion that global weather and climate disasters have increased and will continue to increase is commonly reported in the legacy media, buoyed by the promotion of false information by organizations that include the United Nations. In 2020 the U.N. claimed falsely of a “staggering rise in climate-related disasters over the last twenty years.”
The second point he makes is careful examination of the disaster data clearly shows that “the increase in disasters in its database to 2000 is due to better reporting, and not changes in underlying counts of actual disasters.” He concludes: “Regardless what happens with trends in disaster counts, it is absolutely essential to remember that if you are looking for a signal of changes in climate — always look directly at weather and climate data, not data on economic or human impacts.”
Conclusion
There is a constant barrage of doom and gloom articles connecting any extreme weather event or disaster to the existential threat of climate change. In my opinion they all are more propaganda than unbiased reporting. Every time I have checked a weather event attributed to climate change claim on my own, I have found that the issue is more complex and less threatening than portrayed. Don’t get scared by these stories!
Last month I published several articles about the experiences of Washington State as they implement their cap-and-invest program because I think it is likely that New York’s experiences will be similar. In one I elevated a comment from Washington resident Paul Fundingsland into a post. He recently did “a bit of research with some comments, thoughts and a more or less rough idea of what seems to be going on in the Washington State cap-and-invest scheme” that I have converted into a guest post.
Paul describes himself as “An Obsessive Climate Change Generalist”. Although he is a retired professor, he say he has no scientific or other degrees specific to these kinds of issues that can be cited as offering personal official expertise or credibility. What he does have is a two decades old avid, enthusiastic, obsession with all things Climate Change related.
In this post Fundingsland provides an update after doing a bit of research. I provide his thoughts with my commentary below.
Initial Thoughts
The focus of my articles was the increase in gasoline prices. Not surprisingly that has become a hot topic in Washington. Paul explains:
Pushback on the rise in gas prices associated with the “Cap-and-Invest” scheme (hereafter referred to as “Tax-and-Reallocate” because that is essentially how it works) has caused our Governor to publicly blame the oil companies for price gouging apparently thinking they should absorb the loss of revenue and not pass their state mandated added costs for doing business on to their customers. Apparently he thought these companies should unrealistically absorb the loss of revenue and not pass their state mandated added costs for doing business on to their customers.
The idea that the costs of the program should not be passed on is also present in New York. When the prices necessarily go up it is a shock to many. Why I do not know. It is obvious that the tax-and-reallocate scheme is dealing with a lot of money and not working as planned.
One of our state legislators claims Washington State is now making more money from the sale of a gallon of gas or diesel than the oil companies. Our Department of Ecology (which is running this scheme) scrubbed the website original language indicating this scheme would have a minimal effect on gas prices. The Washington Policy Center claims the proposed climate funding budget is spending 56% of the initial $306 million on expanding government. No real surprise there.
I have concluded that the underlying motive of most of the proponents of these schemes is money. Legislator Reuven Carlyle was a sponsor of the cap-and-reallocate law and provides an example.
Carlyle who chaired the Washington State Senate Environment, Energy & Technology Committee and was a member of the Ways and Means Committee, lead the charge in the Senate for passage of the Climate Commitment Act, Clean Energy Transformation Act, Clean Fuel Standard, hydrofluorocarbon standards, building standards and much more. He left the legislature this year to cash in on his legislative work founding a startup called Earth Finance to “help businesses hit climate goals” based on his legislative accomplishments.
Program Evolution
Fundingsland’s experience with the researching the program is similar to mine:
A cursory review of how this “tax-and-reallocate” scheme is evolving in Washington and what kinds of claims and actual emissions reductions result going forward reveals a quagmire of incredibly convoluted intertwined moving parts. Trying to unravel the threads is proving to be very difficult and quite frustrating.
He notes that descriptive information is not available. That is a common trait in cap-and-invest programs in my experience:
For example under the Department of Ecology one can find a list of the companies who participated in the 2nd auction under “Washington Cap-and-Invest Program Auction #2 May 2023 Summary Report” but no data on how many allowances each company bought or what their total costs were. Interestingly, high profile Washington businesses missing from this list include Boeing, Microsoft, Amazon and Starbucks to name a few.
As to how the monies received from the program are going to be distributed, as of the moment one can find only broad generalized categories with aspirations as to how they will be applied subject to future legislative decision making. For example: “these proceeds will be used to increase climate resiliency, fund alternative-transportation grant programs, and help Washington transition to a low-carbon economy” (my bold).
“Cap-and-Invest Auction Proceeds, consists of these generalized categories with percentages and sub accounts filled with somewhat more specific wish lists of where and how the monies are supposed to be spent. Under “Auction Public Proceeds Report” there is only broad information as to how much money was received.
Nowhere is there documentation of how much CO2 has been or is projected to be reduced by this plan in comparison with past years or how much less warming this plan has resulted in or is projected to result in.
Paul notes that he is “somewhat new at sorting through government bureaucratic documents”. He caveats the following as what “might be better viewed as a rough approximation, subject to revision once more detailed and specific information is obtained.” He does think the following is approximately correct.
According to the Washington State Department of Ecology, the 2019 breakdown of Washington State greenhouse gas emissions is: Residential, Commercial, Industrial heating 25%, Transportation 39%, Electricity 21%, Other 14%.
Electrical power is 64.6% hydro supplied by eight hydro plants owned and operated by the Federal Government. Natural gas is currently at 14.4%, nuclear at 7.8%, wind 8.7%, coal at 2.9%, biomass at 1.3% and a small contribution of solar.
Washington’s natural gas utilities and electric utilities receive a determined (revisable) amount of their required emissions allowances for free. Washington’s only coal fired plant’s emissions are grandfathered in as it will be fully decommissioned in 2024.
So, unlike the lower emissions resulting from a coal to natural gas switch as fortuitously happened during the initial years of the east coast RGGI scheme, there is not a lot of low hanging CO2 emissions fruit to begin with to harvest or claim as a success from the electricity sector in Washington. And with the free emissions allowances the emissions reduction pool from this sector is even further diluted.
When I skimmed through the Washington regulations one of the things that jumped out to me was the following figure. The 2030 limit is a 45% reduction below 1990 levels. The chart indicates that 2020 emissions were equal to or slightly more than the 1990 emissions. A 45% reduction in ten years seems ambitious. Based on the information from Fundingsland, I cannot imagine this target will be achieved.
In addition, the “tax-and-reallocate scheme” contains all sorts of other emissions exemptions. One classification is termed “EITEs” consisting of over 40 facilities and businesses that qualify as Emissions-Intensive, Trade-Exposed industries even though they qualify for mandated participation in emission allowance auctions.
There are also ”tax-and-reallocate-offsets” being run thru what is designated as an Offset Project Registry that looks to be a California based company called Climate Action Reserve.
That leaves the bulk of the emissions reductions to be garnered from the other three sectors (transportation, residential-industrial-commercial heating, and “other”). At this time, it is difficult to determine how the actual 25% breakdown within the residential-industrial-commercial heating sector works. For instance, residential energy use has been reported as being 60% electric.
I have long argued that a basic flaw in the New York net-zero transition plan is that there was no feasibility analysis. Given this information about Washington I think New York is comparatively better off. Both states need to document how they plan to get where they want to go but the reduction trajectory for New York is lower than Washington.
New York is starting to come to grips with similar sector target issues. If the cap-and-reallocate scheme is supposed to provide significant funds for implementation but there are a limited number of affected sectors, then the price impacts on those sectors is going to be magnified. That is exactly what happened in Washington. It is not price gouging when that happens, it is simply supply and demand.
Assuming the industrial-commercial may be mostly gas, the amount of emissions by individual businesses will be affected by whether they are in the EITEs classification or not, whether they have “offsets” and how many tons of CO2 they emit (250,000 tons being the “trigger” amount for mandatory participation in the tax-and-reallocate emissions auctions). So the number of emissions reduction areas possible in this sector are rather “squishy” and difficult to determine. They most probably will land on the low side of 25%.
The political origins of these rules should not be overlooked. The Progressive backers of both plans cater to the labor union constituencies so both New York and Washington carve out EITE exemptions. Because the net-zero transition plans will necessarily increase the cost of energy I expect that the inevitable result is that the increase will make industries in both states uneconomic relative to other locations whatever the intent of these efforts.
The “other” classification of this sector consists of: agriculture (manure, fertilizer, livestock digestion), industrial processes (aluminum, cement), waste management (landfills, waste water treatment), and natural gas distribution. Of these, waste management and natural gas distribution are negligible.
Agriculture represents a very difficult to find pathway toward lowering emissions without adversely affecting the food supply. That leaves cement and aluminum production which are essential to modern society, are both part of the EITEs exemption legislation and have, as of yet, no known practical, workable, scaleable emission free alternatives.
So the residential-industrial-commercial-heat and “other” sectors also look not to bear much in the way of emissions reductions for various mitigating reasons.
Again, the political calculus affects the treatment of these sectors. I think the decisions are based more on what they think they can get away with than a pragmatic emission reduction plan.
At 39%, transportation is the largest emissions sector. It has been reported that in the latest emissions allowances auction held last May, energy and utilities purchased the bulk of the allowances. With utilities (probably the gas plants) garnering a certain amount of unspecified free allowances from the State, that leaves the energy companies supporting transportation to shoulder the bulk of the latest allowance purchases.
There are five refineries located in our state that serve Washington, Oregon and to a small degree California. Their products include on-road gasoline and diesel, marine fuel, jet fuel and aviation gasoline, railroad fuel, and natural gas used in transportation. However, there are some big allowance exemptions that cover fuels involving watercraft (shipping, cruise ships, navy etc.), agricultural, aviation and exported fuels.
Personal car and truck fuels in Washington have no exemptions and make up over half of the total fossil fuel emissions in this category. With the energy companies probably buying the bulk of emission auction allowances, and with all the exemptions in the other fuel use areas, it’s not a stretch to see why the costs of the allowances were passed along to the personal car and truck consumers causing the rather massive jump in gas prices at the pump.
Overall, a good guess is the Legislature will be more than satisfied for some time with the amount of monies coming in that can be used to fund the expansion of the State bureaucracy and all their manufactured future wondrous climate mitigating projects to help save the world from future computer modeled bad weather. So they will feel they are basically doing their job. It’s doubtful they will want to cause gas prices to accelerate much more in the near future for fear of garnering the wrath of the electorate.
Often the simplest answer is correct. Fundingsland makes a good argument that this is just the start of the cost impacts to transportation in Washington. The mix of sector reductions in New York is different but not enough that fuel prices won’t spike when the New York auctions begin. I agree that the revenue target is entirely a political decision.
If and when a transparent “project report” comes out, it will no doubt tout all the money received (the easy headline grabbing part), be filled with all the virtuous climate change related project accomplishments the monies were or are going to be used for (the hyped glossy political part), with the actual emissions reduction data either completely missing, obscured, massaged, tortured, or glossed over and probably relegated to some vague or indeterminant area of the document with accompanying convoluted language (the important forgotten and reason for the scheme in the first place part).
Based on current Ecology Department documents available and reports from various sources, this already seems to be the case.
New York’s participation in the Regional Greenhouse Gas Initiative (RGGI) portends what will happen in Washington and his description is apt. I have been evaluating the RGGI reports for years and can confirm that the wording and information provided is designed to claim unqualified success. Digging into the numbers shows a much different story.
Questions
Fundingsland lists the following bottom-line questions.
*How much did each “qualified” company pay for the allowances?
*What were the financial consequences to the constituents of these added costs to the companies?
*Which areas and projects did the monies actually go to and how much did each receive?
*What was the overall cost per ton of CO2 reductions (total allowance participant proceeds versus total reduction in CO2 tons).
And the four most important questions:
*How much reduction in emissions compared to recent years has resulted from this scheme?
*How much less global warming has been projected to occur by these emission reduction results?
*How much is this scheme going to cost the residents to completion or are the costs never ending?
*What metric has been identified that will be used to indicate this program is no longer needed because it has done it’s job?
I agree with his take on responses to the questions:
It will be surprising if any of these kinds of questions are going to be addressed. It is looking more and more like just another never ending, forever growing government bureaucratic convoluted way to extract more funds from their constituents for some worthwhile, some okay, and some questionable projects that may or may not have a quantifiable bearing on reducing CO2 emissions.
Summation
Fundingsland summarizes the likely results of the program:
It’s going to be extremely difficult and may not even be possible for Washington State to be able to claim any meaningful or significant emission reductions based on this tax-and-reallocate scheme given the state’s overall energy use configuration combined with all the various emission allowance exemptions.
In fact, there is a very high probability there will be next to zero emission reductions and perhaps even an increase.
The easiest and most efficient way for the 54 companies/businesses listed under the auction #2 May 2023 summery report that have been forced to participate (“qualify” in bureaucratic terminology) in the allowance auctions or face a $10,000 per day fine, is for them to just purchase the allowances, add it to their cost of doing business and pass the increase along to their customers. So in effect they won’t be reducing their emissions at all. And all will be adding their additional State forced costs for doing business on to their customers.
This the ultimate flaw in the cap-and-reallocate plan. The costs to implement emission reductions are greater than the costs of allowances. Moreover, emission reductions may only be possible by displacing fuels. The transportation fuel providers have limited means to reduce their emissions so the sector reductions will come primarily from the introduction of electric vehicles. In the meantime, the fuel providers will simply pass the costs along and if the allowance cap limits the availability of allowances too much then they will stop selling fuel or pass the $10,000 per day fine along to their customers.
Fundingsland concludes:
At the end of the day, the goal of any meaningful, measurable reduction of CO2 emissions or theoretical effective pathway to stop “climate change” looks to become a glazed over afterthought in this quagmire of a Washington State bureaucratic money-making machine.
With this scheme, Washington State Government now joins the lucrative profit side of the climate industrial complex at the expense of its constituents while giving a completely different connotation to the term “Net Zero”.
Fundingsland picked up on the affordability issues but did not address the compliance implications. Advocates for cap-and-invest tout the claim that as the allowance cap declines, compliance with the program targets is assured. Proponents have not acknowledged or figured out that the emission reduction ambition of the reduction targets is inconsistent with technology reality. Because GHG emissions are equivalent to energy use, limiting GHG emissions before there are technological solutions that provide zero-emissions energy means that compliance will only be possible by restricting energy use. I don’t think that New York can meet its emission reduction targets but compared to Washington’s emission inventory and targets New York has a much better chance. Washington plans to rely primarily on the transportation and building sectors for its reductions and needs to make sharper cuts. I see no scenario where that will end well.
In conclusion, I believe Fundingsland did a good job describing the issues associated with cap-and-invest in Washington. New York’s program will have the same issues. It will be interesting to see how these state programs work out and which one will be the bigger flop.
The New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”. Implementation of the Climate Leadership & Community Protection Act (Climate Act) started soon after the law was passed at the end of 2019. It was recognized early that “as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid” but here we are three and half years later finally getting around to address this critical requirement. This post summarizes the proceeding, gives an overview of the questions raised by the PSC, and describes the comments I submitted.
I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. I have extensive experience with meteorological aspects of electric generation because I have worked in the sector as a meteorologist for over four decades. I have devoted a lot of time to the Climate Act and the issues raised in this proceeding because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. I represent the Environmental Energy Alliance of New York on the New York State Reliability Council Extreme Weather Working Group. The opinions expressed in this article do not reflect the position of the Alliance, the Reliability Council, the Extreme Weather Working Group, 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 established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. The zero emissions analysis is part of that effort.
Overview of Process
The press release describes the process to “identify innovative technologies to ensure reliability of a zero-emissions electric grid”:
The New York State Public Service Commission (Commission) has initiated a process to examine the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Leadership and Community Protection Act, or Climate Act.
“The Commission’s action reaffirms efforts to ensure New York has the needed clean-energy resources to replace existing fossil fuel-fired power plants,” said Commission Chair Rory M. Christian. “I am proud that New York continues to lead by advancing important clean energy initiatives, such as the one commenced today.”
The Climate Act, passed by the State Legislature in 2019, directs the Commission to establish, among other things, a program to ensure that by 2030, at least 70 percent of electric load is served by renewable energy, and that by 2040, there are zero emissions associated with electrical demand in the State. The initiative will help deliver on the Climate Act zero-emissions electric grid mandate and will enable the necessary types of clean energy to reach all New Yorkers. The Commission’s decision follows a substantial climate package announced by Governor Kathy Hochul in the FY24 enacted State Budget that will advance sustainable buildings, clean energy, and an affordable Cap-and-Invest program.
Today’s action recognizes that as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid. The Commission’s work to meet the Climate Act targets must include exploration of technologies that can support reliability once fossil generation has been removed from the system. The order initiates a process to identify technologies that can close the anticipated gap between the capabilities of existing renewable energy technologies and future system reliability needs. Within the order, the Commission asks stakeholders a series of important questions, including how to define ‘zero-emissions’ for purposes of the zero emissions by 2040 target, and whether that definition should include cutting edge technologies such as advanced nuclear, long duration energy storage, green hydrogen, and demand response. The order further elicits feedback from stakeholders on how to best design a zero-emissions by 2040 program, consistent with the Climate Act’s requirement of delivering substantial benefits to disadvantaged communities and New York State’s electric grid reliability rules, while also leveraging other state and federal efforts to research, develop, and deploy zero-emission resources.
After a 60-day public comment period, Commission staff will convene at least one technical conference to examine a series of issues and questions raised in this important proceeding. The Commission may take additional actions on zero-emission resources based on the information obtained through those processes.
Questions Asked
I have included the questions asked with some brief commentary. I chose to only address one question related to my expertise and one short-coming in the Proceeding. The Commission wants answers to “assist the Commission in determining what, if any, subsequent actions should be taken, which may include refinements to existing policies or establishing new policies.”
Question 1: How should the term “zero emissions,” as used under PSL §66-p(2)(b), be defined?
It has taken three and a half years to define what qualifies as “zero emissions” and address the problems associated with this resource. Given its importance this should have been an immediate and high priority for the Climate Action Council. The Order notes:
Following enactment of the CLCPA, the Commission issued the Order Adopting Modifications to the Clean Energy Standard, which aligns the existing Clean Energy Standard (CES) with the CLCPA renewable energy targets.
The pathway established by the CES Modification Order focuses on options for procuring sufficient renewable energy resources to meet CLCPA requirements. However, several studies indicate that renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced. These studies suggest that there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements. The Independent Power Producers of New York, Inc., New York State Building and Construction Trades Council, and New York State AFL-CIO (Petitioners) also raised this issue in a petition filed in this proceeding on August 18, 2021 (Zero Emissions Petition or Petition).
I did not provide any comments on this question.
Question 2: Should the term “zero emissions” be construed to include some or all of the following types of resources, such as advanced nuclear (Gen III+ or Gen IV), long-duration storage, green hydrogen, renewable natural gas, carbon capture and sequestration, virtual power plants, distributed energy resources, or demand response resources? What other resource types should be included?
If I were to respond to this question, I would simply say the only one of these resources that has a realistic chance of providing the services necessary is advanced nuclear. That answer is obvious to anyone who has looked at the other options pragmatically. I do not believe that a state that shut down 2,000 MW of operating nuclear will ever pivot to nuclear so I am not going to dilute my comments by stating the obvious.
Question 3: How should a program to achieve the Zero-Emission by 2040 Target address existing and newly constructed nuclear energy resources. Should the program be limited to specific types of nuclear energy technologies and exclude others?
It is obvious that keeping existing nuclear in operation as long as it is safe should be a priority but this is New York. Responding to the specific types of nuclear question is beyond my existing knowledge and I do not have time to research a response.
Question 4: Should new measures adopted to pursue compliance with the Zero-Emission by 2040 Target focus exclusively on generation and resource adequacy, or should they also encompass a broader set of technologies that could be integrated into the transmission or distribution system segments, or installed and operated behind-the- meter?
Responding to this is beyond my existing knowledge and I do not have time to research a response. My impression is that the broader technologies being considered are all magical solutions that are only being included to appease the green energy advocates. They may play a role but it will be inconsequential.
Question 5: Should any program to achieve the Zero-Emission by 2040 Target specify subcategories of energy resources based on particular characteristics, such as ramp rates, the duration of their operational availability, or their emissions profile with respect to local pollutants?
I am sure that New York’s reliability experts will address the technical aspects of the energy resources needed. I am not qualified to do so. My comments do address the duration of the operational availability of this resource.
Question 6: What role does technology innovation need to play to meet the CLCPA’s Zero-Emission by 2040 Target?
Given that the Commission by way of this proceeding, the New York Independent System Operator (NYISO), and the New York State Reliability Council (NYSRC) all agree that there is no commercially available resource available that meets the need identified for dispatchable emissions free generation, I would say that technology innovation is an obvious prerequisite to the 2040 target. My comments address the reliability and affordability implications of the technological innovations needed.
Question 7: Should life cycle emissions impacts be considered when characterizing energy resources? If so, how?
It would be inappropriate for me to respond to this question because my comments would be unprofessional. I doubt that something along the lines of the following would be considered: “Why would the State want to start becoming unbiased in its consideration of energy resources now? All of the possible life cycle impacts of fossil sources are included and none of the life cycle impacts of wind and solar are considered. When there was no obvious characterization methodology for fossil fuel impacts available, they just made something up – so do the same.”
Question 8: Given that the feedstocks and other resources required to produce renewable natural gas are limited and will be in demand in other sectors of New York’s economy, how should this fuel be considered in the context of this proceeding?
This question answers itself. There will never be enough renewable natural gas available to provide a meaningful contribution. On the other hand, there are instances where emission reductions will be required and the capture and use of renewable natural gas makes sense.
Question 9: In what ways might a program to meet the Zero-Emission by 2040 Target require reexamination and possibly revision of different tiers of the Clean Energy Standard? Should one or more of the policy approaches that have been used to implement the CES be considered to meet the Zero-Emission by 2040 Target?
Responding to this is beyond my existing knowledge and I do not have time to research a response.
Question 10: What is necessary to align a program to meet the Zero- Emission by 2040 Target with the priority of just transition embedded within the CLCPA?
The Just Transition rubric is a political construct. I pride myself on pragmatic comments that balance impacts, costs, and benefits. Those are not considerations that will be included in the just transition priorities so I did not submit a response to this question.
Question 11: How might the benefits of a program to meet the Zero- Emission by 2040 Target be measured for the purpose of ensuring that, consistent with PSL §66-p(7), it delivers “substantial benefits” to Disadvantaged Communities?
The substantial benefits to Disadvantaged Community rubric is another political construct. It is disappointing that the State has so far ignored the benefits of a reliable and affordable electric grid relative to the alleged benefits and significant affordability and reliability risks to Disadvantaged Communities.
Question 12: NYISO has adopted an effective load carrying capacity (ELCC) rubric and treatment of Zones J and K as load pockets with special resource adequacy requirements. How should these constructs and other NYISO market rules inform design of a program meant to support the development and deployment of resources capable of achieving a zero emissions grid?
Responding to this is beyond my existing knowledge and I do not have time to research a response.
Question 13: What additional studies, if any, should the Commission undertake with respect to the development and deployment of resources capable of achieving a zero emissions grid?
In the following section I describe my response to this comment.
Question 14: Given that New York is not the only jurisdiction investigating options and opportunities for the research, development, and deployment of new technologies capable of achieving a zero emissions grid, how should the State seek to coordinate with and otherwise draw upon efforts that are underway elsewhere?
This is another question that answers itself. Given the challenges we need all the help we can get. How to do that is beyond my pay grade.
My Comments
My comments addressed two concerns: duration of the operational availability of the zero-emissions resources and the need to address the feasibility and affordability conditions in New York Public Service Law § 66-p (4). “Establishment of a renewable energy program”.
In order to determine whether any of the innovative technologies to “ensure reliability of a zero-emissions electric grid” are adequate it is necessary to determine how much energy they can provide relative to the amount needed in the worst case. I have been whining about the ultimate problem in the Integration Analysis for nearly three years. On September 16, 2020 In their presentation to the Power Generation Advisory Panel E3 included a slide titled Electricity Supply – Firm Capacity. Their presentation states: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits.” Those are the zero-emissions resources addressed by the Proceeding. Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.
My comments explained that in New York the winter solar resource is poor because the days are short, the irradiance is low because the sun is low in the sky, and clouds and snow-covered panels contribute to low solar resource availability. If there is a period of low winds, then the zero-emissions resource is needed to provide an economically viable resource solution. Note that the magnitude of the zero emissions resource needed to address this issue will be a significant percentage of system peak load and that the technology (green hydrogen, long-term battery, etc.) does not presently exist for utility scale application.
I also pointed out that the reliability concern is exacerbated for several reasons. The future peak load will be in winter because the primary decarbonization strategy is electrification. During extreme cold weather periods, natural gas used at power plants is diverted to other users and power plants must switch to oil. There are fewer plants that have dual-fuel capability and over an extended event or a series of events the oil in storage could be depleted. Finally, the coldest periods are also associated with wind lull periods because extreme cold is associated with large high-pressure systems that suppress wind resources.
If there are insufficient generating resources available to serve peak loads, then a disastrous blackout will result. In February 2021, the Texas grid was unable to provide support load and resulted in as many as seven hundred deaths and billions in damages. I stated that this proceeding must ensure that this situation does not happen in New York.
I described the NYISO resource adequacy planning process in my comments. It has developed over many years and provides reliability planning projections based on the current mix of electric generating resources. One of the important characteristics of the current system is that there is insignificant correlation between the unavailability of generating resources. I believe that one of the significant findings of the New York State Reliability Council (NYSRC) Extreme Weather Working Group (EWWG) will be the observed correlation of the frequency and duration of low-wind episodes across the entire state, including the offshore wind development areas. I emphasized that this finding must be considered in future planning.
I have no doubt that these issues will eventually be addressed in the resource adequacy planning process and the reliability standards for the electric system. However, in order to determine how to do this it is necessary to understand the worst case. In order to determine how large the DEFR capacity needs to be, the State must know how much energy was available for low renewable resource episodes of different lengths. The EWWG is addressing this issue. However, because of its importance I believe a more extensive analysis and possibly independent analysis by different organizations would be appropriate. It is too important to rely on a single analysis of the expected worst-case availability. Therefore, I recommend this study be addressed as part of this Proceeding.
My comments on this topic recommended what should be included in a worst-case analysis. The most important aspect of any such analysis is to use as long an analysis period as possible. Fortunately, meteorological reanalysis data generated by modern weather forecast models but using original observations since 1950 are available for this application. The analysis should identify potential periods of low wind and solar availability and their frequency and duration. Once worst case periods are identified, modeling that projects the specific resource availability during the worst periods should be performed. That information can be used for future resource planning.
My second comment addresses the feasibility and affordability conditions in New York Public Service Law § 66 “Establishment of a renewable energy program”. The Hochul Administration has not acknowledged that there is a “safety valve” if the implementation does not work out as imagined in the Scoping Plan.
Specifically, New York Public Service Law § 66-p (4) states: “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”. The plain reading of that is that if implementation cannot feasibly maintain reliability standards or adversely affects affordability can “temporarily suspend or modify the obligations” of the Climate Act.
In my opinion, if the Climate Action Council had spent time looking at overarching issues rather than getting bogged down in arguments about wording and the pet concerns of its members then this would have been addressed. In this instance, they should have defined the reliability obligations, and affordability conditions for the commission. They could have specified the metrics to be used and the limits at which it would be appropriate to pause implementation. Because the Climate Action Council failed to provide recommendations, I commented that the Commission must establish those criteria.
Once the criteria are established then they can be used as a test for the acceptability of the proposed zero emissions resources. As part of the process a feasibility analysis for each resource to determine the technological risks for the resource and potential costs must be prepared. If the analysis projects that the § 66-p (4) criteria will be exceeded then the resource should not be considered.
Finally, I noted that my primary problem with the Climate Act is the mandate to go to zero without consideration of tradeoffs. In this instance that mandate precludes an obvious solution. New York’s oil-fired steam-electric generating stations could be used to provide the dispatchable generation needed for the worst-case extremes. The facilities have on-site storage, significant capacity availability, and experience operating units that run rarely. The units could be kept on-line, used for testing, training, and to be available for use in these extreme events. The extreme events are easily forecasted days in advance so the units can be brought on-line to be available as needed. I suspect that the cost to maintain those facilities will be far less than the cost of any zero-emission resource. Overall, the emissions and air quality impacts will be far less of an issue than the ramifications of a blackout. I recommended that this option be considered as part of this Proceeding.
Conclusion
This proceeding puts to rest the myth that the technology necessary for the electric system transition is available today. In order to meet the 2040 “zero emissions” electric generating resource requirement, this zero emissions resource is needed.
My comments were confined to two overarching issues that must be resolved in order to evaluate New York’s “zero-emissions” resources. The energy that the resource needs to provide to replace wind and solar resources during low availability periods must be known in order to determine how much will be needed. I recommended that an analysis that uses as long a period as possible be included as part of the Proceeding. My other concern is that the acceptability of zero-emissions resources should be based on well-defined standards of reliability feasibility and affordability. I recommended that the Proceeding define these criteria.
This is a necessary component of the net-zero transition. Unfortunately the need for this Proceeding has been known since the implementation began and it should have been part of the discussions of the Climate Action Council in 2020.
I believe that the majority of New Yorkers are unaware of the ramifications of regulations implementing control programs for the Climate Leadership & Community Protection Act (Climate Act) emission reduction mandates. This post describes one regulation that will affect most New Yorkers but has not received as much attention as I would have thought. The New York State Department of Environmental Conservation (DEC) recently adopted amendments to 6 NYCRR Section 200.9 and 6 NYCRR Part 218 will incorporate California’s Advanced Clean Cars II (ACC II) regulation that require increasing annual zero emission vehicle (ZEV) sales requirements starting at 35% in model year 2026 and increasing to 100% by model year 2035.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition 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 Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 reduction target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. This regulation is an example: “The amendments are also consistent with the requirements of the Climate Leadership and Community Protection Act, Chapter 106 of the Laws of 2019, as well as legislative requirement for all new, light-duty vehicle sales to 100% ZEV by 2035, Chapter 423 of the Laws of 2021, to further reduce greenhouse emissions in New York State.”
Advanced Clean Cars Regulation
One problem for the public as regulations and legislation are proposed and enacted is that the regulatory action language is dense and unclear. The DEC description of this rulemaking is a good example:
This notice is continuation of the Proposed/Emergency Rulemaking of the same title that was adopted and effective on December 13, 2022 and published in the State Register on December 28, 2022. Emergency Rulemaking – Parts 200, General Provisions, and 218, Emissions Standards for Motor Vehicles and Motor Vehicle Engines. The emergency rulemaking will incorporate the State of California’s Advanced Clean Cars II (ACC II) regulation. The proposed amendments establish new zero emission vehicle (ZEV) and low emission vehicle (LEV IV) standards intended to reduce GHG (greenhouse gas) and NMOG + NOx (non-methane organic gas + oxides of nitrogen) emissions from light- and medium-duty on-road vehicles.
The ZEV amendments include an annual ZEV sales requirement for original equipment manufacturers (OEMs), minimum technical requirements, ZEV assurance measures, regulatory flexibilities, and simplified credit accounting. The proposed ZEV amendments will apply to 2026 and subsequent model year light-duty passenger cars (PC), light-duty trucks (LDT), and medium-duty passenger vehicles (MDPV). Starting with model year 2026, OEMs, will be required to deliver an increasing annual percentage of their sales that are ZEVs or PHEVs. This percentage requirement will start at 35% in model year 2026 and increase to 100% of sales for 2035 and subsequent model years. The proposed LEV IV amendments will apply to 2026 and subsequent model year PC, LDT, and medium-duty vehicles (MDV).
The Notice of Emergency Rulemaking is effective as of July 6, 2023, and will be available in the July 26, 2023 issues of the State Register and the Environmental Notice Bulletin.
Advanced Clean Cars for the Public
I think that the biggest unappreciated impact to the public will be the sales percentage mandates for zero-emission vehicles (ZEV) and plug-in hybrid vehicles (PHEV). Buried in the regulatory documents there is a pretty straigh-forward explanation. On page 4 of the July 26, 2023 State Register (page 14 of the pdf file) the sales mandates are described:
Starting with model year 2026, OEMs, will be required to deliver an increasing annual percentage of their sales that are ZEVs or PHEVs. This percentage requirement will start at 35% in model year 2026 and increase to 100% of sales for 2035 and subsequent model years.
PHEVs may be used to meet up to 20% of the annual ZEV requirement and they must meet minimum technical requirements. The use of PHEVs to meet part of the annual ZEV requirement will sunset following the 2035 model year.
ZEVs and PHEVs will be required to meet minimum technical requirements to earn ZEV values under ACC II. ZEVs must have a minimum all electric range (AER) of at least 150 miles and PHEVs must have a minimum AER of 50 miles and be capable of doing at least 40 miles on an aggressive drive cycle. ZEVs and PHEVs must also meet the ZEV assurance measures to be eligible to earn ZEV values. PHEVs must also be certified to super ultra-low emission vehicle (SULEV) standards and be covered by a 15 year or 150,000 mile warranty
The proposed ACC II ZEV amendments include ZEV assurance measures consisting of durability, warranty, service information/ standardized data parameters, and battery label requirements. The ZEV assurance measures will ensure that ZEVs retain functionality and reliability as internal combustion engine vehicles (ICEVs) are transitioned out of the on-road fleet.
Reactions to Advanced Clean Cars
The Big Green NGOs support this program to mitigate climate change. The NRDC claims “Transitioning to a zero-emission transportation system, therefore, is one of the most effective ways to mitigate climate change, improve air quality and health almost everywhere, and make the total cost of car ownership lower and more predictable.” The Sierra Club says “One policy that has pushed EVs to become more affordable and easier to purchase is the Advanced Clean Cars II (ACC2) Rule, also known as the Zero Emission Vehicle (ZEV) Standard.”
While I am sure that there are people who agree with these organizations, I believe that the majority do not. According to the NYSERDA Electric Vehicle Registration Map there were 155,988 electric vehicles on the road in New York as of July 2, 2023. There are on the order of 11.5 million vehicles registered in New York so electric vehicles account for about 1.5% of the vehicles in the state. The following table lists the number of new EV registrations per year. EV proponents point to the increasing sales but, given the tremendous marketing effort for EVs I do not these numbers represent an endorsement for electric vehicles where it counts.
The reality is that there are issues with EVs. I have set up a background page that provides links to articles describing some of those issues. I am going to describe a couple of recent articles here that list some of my concerns.
Both articles address the obvious issue. What if people like me don’t want to buy a battery electric vehicle because of range limitations, home infrastructure concerns, and worries about the morality of the supply chain of rare earth metals. The first article notes that Unsold Electric Cars May Be Signaling A Death Spiral For The Auto Industry. Ronald Stein lists reasons why people are not purchasing EVs and points out that EV inventories are rising. He also points out that the used car market is important but that the EV used car market is non-existent. Anecdotally, a friend of mine in the car business says that used Evs are not selling because of lemon laws and worries about battery replacement.
In the second quarter of 2023, Ford lost $72,000 on every EV sold. While the latter is ‘sort of’ normal for new car platforms – and Evs are nothing if not new platforms – what isn’t normal is for highly-touted/media-frenzy revolutionary new autos like the Ford Mustang Mach E EV to be selling under 3,000 units per month in the US as it is in 2023, two years after introduction (US sales peaked over 5,000 units per month shortly after introduction). In the second quarter of 2023, Ford sold 14,843 Evs (out of 513,662 vehicles sold by the company overall), a fairly meagre total considering the capital invested and the marketing campaigns. In the minds of most consumers, it seems an EV means a Tesla, and there is scant interest in anything else no matter the marketing hyperbole.
Etam brings up another point that is a concern of mine. Evs are so expensive that the low- and middle- income residents of disadvantaged communities will have a tough time buying one. He explains:
In case anyone cares, and it doesn’t seem that they do when energy transitions are discussed, this will all work out the absolute worst for lower income people. Ordinarily, the auto market provides options for lower economic classes with vehicles that are no longer in favour. For example, in periods of high gasoline prices, consumers that can afford to switch up will tend to go for more fuel efficient vehicles, and the market can get flooded with inefficient ones – which has the effect of pushing down prices of these out of favour beasts, putting them within reach of poorer people. The fuel costs may be higher, but at least they can buy wheels.
That likely won’t happen this time around, if we see people buy ICE vehicles and then hoard them for as long as they can. In fact, things are terrible already for lower income people looking to buy older used cars – prices have skyrocketed for those as well.
Used cars are expensive, new cars are hideously more so, and Evs are, thus far, mostly toys of the wealthy with multi-car garages, or well paid urbanites that can afford to use them where they really shine. Again, we can see where China is twelve steps ahead; many popular Evs in China are tiny, cheap EV runabouts that don’t have massive range, but get the job done. No such option is available here in North America, few in Europe, and if they do show up on these shores, it is a safe bet they will be of Chinese origin, because they’re the only ones that can make money at it.
New York Reality
I took a quick look at the numbers to see if the Advanced Clean Car regulations in New York that require a certain percentage of new vehicle sales that are ZEVs or PHEVs have realistic targets. The requirements are:
This percentage requirement will start at 35% in model year 2026 and increase to 100% of sales for 2035 and subsequent model years. PHEVs may be used to meet up to 20% of the annual ZEV requirement and they must meet minimum technical requirements. The use of PHEVs to meet part of the annual ZEV requirement will sunset following the 2035 model year.
Where is the state now relative to these mandates? At one time it would have been relatively easy to get the necessary data to determine the status. However, the NY Department of Motor Vehicles no longer provides historical registration and new vehicle registration summary information. Instead the primary New York registration information through Data.NY.Gov is a data dump of 12.5 million rows of registrations. Completely worthless without a lot of processing and I don’t think it includes any historical information. There is Data.NY.Gov source of summary registration by fuel type and county data.
In order to estimate the EV percentage of new car sales I needed the number of vehicles sold in New York. I could not find that data but did find data for the United States. I assumed that the percentage of new car sales in New York would be the same as the percentage of the country. I found a source for United State motor vehicle registrations that included state data. The following table lists country-wide and New York registrations by vehicle type. I lumped all the registrations together for this analysis.
For new car sales I found data for the country. I estimated the New York new car sales as the same percentage of new sales to total registrations for the country. The following table lists those results. Because I did not have registration data after 2019, I assumed the New York sales would equal the 5-year average for 2019 and subsequent years (highlighted in yellow).
I previously listed the EV registration data for New York. The following table includes a projection of sales needed for model year 2026. These assumptions show that the idea that New York will be able to meet the Advanced Clean Car rule 2026 mandate is preposterous. In 2023 I estimate that 8.6% of the vehicle sold will be EVs. Note that PHEVs made up around 50% of the sales in 2022 but that starting in 2026 that percentage needs to be lowered to 20%. I interpolated where we are in 2023 to 2026 and the increase in sales of EVs is not likely. To think that in 2025 that EV sales will be larger than the number of EVs currently on the road is nothing but wishful thinking.
The State Register notice describes the public comments:
Most of the more than 4,400 commenters including vehicle manufacturers, environmental groups, and non-governmental organizations supported the Department’s ACC II adoption. The remaining six commenters, including a large manufacturer of diesel engines and a petroleum industry trade group, were opposed to the regulation.
Typically, DEC will point to this overwhelming support in favor of the regulation as “proof” that it is appropriate. If the comments were representative of general public opinion, then the percentage of EVs on the road in New York and the sales totals would be much higher. As a result, the argument that the comments supporting the program are representative of general public opinion fails. The overwhelming numbers do show that the environmental movement is extremely good at playing the game.
Used Vehicles
I believe that the regulation only applies to new cars. This explanation states: “This law doesn’t affect gas cars already on the road, the sale of used gas cars or new registrations of gas cars.” I suspect what we will see will be similar to what happened in Cuba. Etam notes that:
Cuba has not had access to modern automotive technology since the 1960s. As a result, streets still are full of ancient American cars, held together forever.
There is no reason to think that won’t happen in the US, Canada and western Europe when the new-ICE ban comes into effect. Some segments of the population will go with the regulatory-mandated flow, while a great many will hold onto what they know, trust, and love. Short of a miracle battery breakthrough, many will simply not trust EVs in cold weather and/or instances where battery power doesn’t cut it.
As note previously, the lack of used EVs will impact the low income and disadvantage communities the most. The regulation tries to address this problem but I don’t think the plan is very useful:
The proposed voluntary ACC II EJ flexibility is intended to award extra ZEV values to OEMs that undertake programs to expand ZEV availability to low income and disadvantaged communities. Optional programs include discounted ZEVs and PHEVs placed in community-based clean mobility programs, used ZEVs and PHEVs remaining in New York following the expiration of their lease term, and making low-cost ZEVs available to low income and disadvantaged communities. EJ values will be capped at 5% per year and will sunset following model year 2031.
Conclusion
From a practical standpoint I do not see how the new car sales mandates are going to convince those members of the public that EVs have more problems than benefits to buy one. I bet that enterprising car salesmen will figure out ways around the regulation for those people who want a new internal combustion engine or even a PHEV for that matter. If I but one out of state and come in toe DMV to register it are they going to say you cannot do that? Will there be a market for sales out-of-state to middle men who buy a specific new car then turn around and sell it “used”. The ultimate fall back is to simply keep the existing cars running as long a possible.
When I tell someone that there is a regulation in place that will eventually force them to buy an electric vehicle, the usual response is to say they cannot do that and I won’t buy one. Unfortunately, the law is in place and eventually there will not be any other options for new vehicles. The only alternative is to vote out the pandering politicians who respond to the marketing efforts of the Big Green lobbyists that got us into this mess. I think that will eventually happen and I can’t wait.
A recent report by the Syracuse Post Standard described the most recent environmental impact assessment for the Micron Technology’s planned semiconductor plant. Last month I described the keynote address for the Business Council of New York 2023 Renewable Energy Conference Energy by Richard Ellenbogen. I contacted Ellenbogen to let him know that the original projection of for energy use that would be the same as the state of Vermont has been expanded to the same as Vermont and New Hampshire. This post describes Ellenbogen’s reaction to that news.
Ellenbogen is President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with New York’s Climate Leadership and Community Protection Act (CLCPA). I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk. When he sent a copy of the presentation I asked if I could it post after the conference.
Why NY State Must Rethink Its Energy Plan
Ellenbogen’s keynote address was titled “Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems.” My post on the presentation summarized the power point presentation for his keynote address.
One of his suggestions concerned the Micron plant:
Allow Micron Technologies to build a combined cycle plant the size of Cricket Valley Energy Center on their property. The Micron facility will use more energy than the state of Vermont. With generation on-site, the thermal energy could be used at the plant and the 350 GWh of annual line loss will be eliminated. Instead of making them look “green” on paper by buying carbon credits, let them be green in reality with high efficiency generation and have lower energy costs to make them more competitive and able to recoup the $5 billion rebate without faking it. That will eliminate the increase in statewide energy use related to the facility.
Micron Environmental Impact
Glen Coin and Tim Knauss provided an update (subscribers only unfortunately) on the environmental impacts of the facility. Their article included the following statements:
The new estimates of water and energy use are for entire the complex when finished 20 years from now. The company plans to build the four fabrication plants, or fabs, sequentially: Construction of fab 1 starting in November 2024, and work on the fourth fab completed by 2043.
When the Clay complex is complete in 2043, it would use more water and more electricity than all of the company’s factories and offices in use today. The Clay complex will consume 16 billion kilowatt-hours of electricity per year; according to the 2023 sustainability report, all of the company’s fabs now use a combined 11 billion kilowatt hours
Sixteen billion kilowatt-hours per year is enough for more than 2 million average households.
The Micron fab would use about the same amount of electricity as Vermont and New Hampshire combined, according to data from the U.S. Energy Information Administration.
Ellenbogen Update
Ellenbogen prepared the following update after I sent him the article:
I have been using the Micron facility as an example of how the CLCPA is actually going to increase NY State’s carbon footprint because transmitting all of that energy to the Micron site, as much as is used by the state of Vermont, over long distances was going to result in an amount of lost energy on the wires that could operate 1-3/4 Cornell Universities. One of my readers sent me an update of energy use because now it is projected that the Clay complex will consume 16 billion kilowatt-hours of electricity per year, as much as Vermont and New Hampshire combined, or 16,000 Gigawatt Hours annually (16 Tera-watt hours). That is double the original projections and the idea that this could be supported with renewable generation is laughable. 16,000 GWh is an 11% increase in NY State electric usage just related to the one facility. The line loss will also double to consume the output of about a 100 megawatt fossil fuel plant under continuous operation.
To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or 2.1 Gigawatts of generation off site, 5% more. NY State’s policy makes absolutely no sense. To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW) or 200 Square miles. NY State has 7 million acres of farmland so solar arrays to support the Micron facility would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site. A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant. Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient. With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.
The politicians can say whatever they want about the wonders of the CLCPA but the mathematical analysis of the project says that the CLCPA and the mandate for Micron to buy Carbon credits is going to raise NY State’s carbon footprint substantially while also raising Micron’s costs. It’s a Lose-Lose proposition for everyone.
That’s what happens when you outsource utility planning to Climate Scientists and environmental activists that have no understanding of what they are doing, which is what NY State has done.
Conclusion
I agree with Ellenbogen’s points. The obvious approach for the energy needed by Micron would be co-generation. As much as I would like to say that this should be provided by nuclear, I agree with him that costs and implementation time preclude that option now so a combined cycle natural gas-fired plant is the pragmatic choice. Either option produces waste heat that can be used at the facility which increases the energy efficiency. As he says the expectation that renewables can provide the necessary power on top of the existing load needs is laughable. Importantly, a facility like this must have uninterruptible power and providing that from wind and solar is an extreme challenge. Finally, I want to close with one of Ellenbogen’s points from his presentation: “When fantasies meet reality, reality always wins.” The Climate Act renewable plans are fantasy and the inevitable clash with reality is going to be interesting to watch.
The Climate Leadership & Community Protection Act (Climate Act) net-zero transition plan includes a requirement for “zero-emissions” electric generating by 2040. New York’s irrational energy policies preclude the only proven zero-emissions choice (nuclear energy) to meet that requirement. Instead, the emphasis is on solar and wind development. A recent post at Trust, yet verify includes a great graphic that illustrates an inherent flaw with wind and solar that Climate Act implementation must address.
I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. 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 established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.
Implementation
In order to get a sense of the magnitude of the renewable resource development necessary to implement the Climate Act this section shows the expected changes to load and generating resources.
The New York Independent System Operator (NYISO) 2023 Load & Capacity Data Report (also known as the “Gold Book”) 2023 Load & Capacity Data Report (Gold Book) lists the 2022 observed load and projections out to 2053. The following excerpt shows Table I 1-a baseline energy and demand data to 2040.
There are two relevant projections for future generating resources. The “official” Hochul Administration projections are in the Final Scoping Plan. The NYISO projections are in the 2021-2040 System & Resource Outlook I compare the installed capacity for Scoping Plan and the Resource Outlook in the next table. For this post I am only concerned with the total generation projections.
In 2022 the peak observed load was 31,709 MW and the installed summer capability 37,178 MW. In 2030 the NYISO Gold Book baseline predicted summer peak load is 32,490 MW and 36,930 MW in 2040. The peak winter load is 28,970 in 2030 and 44,800 in 2040. In the following table, I list the maximum capability and peak load data and calculate the capability to peak load margin.
The NISO Gold Book Table V-3 lists the historical Installed Reserve Margin (IRM) values for the New York Control Area and the historical minimum Locational Capacity Requirements (LCRs) approved by the NYISO for Zones G-J, Zone J, and Zone K. The IRM requirements are established each year by the New York State Reliability Council (NYSRC). The IRM represents the minimum level of capacity, beyond the forecasted peak demand, which utilities and other energy providers must procure to serve consumers. This post is not going to address the LCRs.
As shown here New York will require an unprecedented level of new wind and solar development in order to meet the net-zero transition mandates of the Climate Act. Note that the capability to peak margin calculated in the preceding table is not exactly the same as the IRM but the expectation is that the IRM will increase significantly in the future. The reason for this IRM shift is that wind and solar are intermittent and overbuilding those resources is necessary to address that intermittency. While overbuilding is suggested as the solution for the best energy plan the question is how much is enough and whether it is a solution that eliminates the need for any new resources.
One Third on Average
I am convinced that overbuilding is not as viable a solution as its proponents claim. However, trying to explain the reasons why is complicated so I have been looking for a more-easily understood graphical explanation. Michel Opdbe wrting at the at Trust, yet verify blog has just such a graphic.
Opdbe lives in Belgium and writes about renewable energy policies in Belgium and adjoining countries. His recent post addressed a claim that on average of 1/3 of the total electricity demand in the Netherlands is now supplied by sun, wind and water. The post was based on a tweet with this message (translated from Dutch):
An average of 1/3 of the total electricity demand in the Netherlands is now supplied by sun, wind and water. The record is from Sunday 24 April, with a nice 68%. The low of last winter was on November 30, with only 4%. #graphoftheday
It was accompanied by a graph showing the daily energy production by solar, wind and water as percent of total demand of the Netherlands:
He explains:
The thick yellow line is the four weeks moving average and, indeed, it ends up at roughly one third of demand at the beginning of 2023. That is however only part of the story, as also hinted by the two values that are mentioned in the text of the tweet.
Although the average ends up around one third of demand, it is derived from a incredibly wide range. According to the tweet, solar and wind together with water produced between 4% and 68% of total demand in 2022 in the Netherlands.
There is also something in this graph that drew my attention, but it is not that clear from that graph. Unfortunately, I don’t have the data from the Netherlands. Luckily, this dynamic is not unique to the Netherlands, it is exactly the same in Belgium and the Belgian data is readily available.
In my opinion this dynamic is universal across all jurisdictions that are moving to a reliance on wind and solar.
This is a recreation of that graph using the Belgian data (only solar and wind, water power in Belgium is negligible):
The Belgian figures are close to that of the Netherlands, albeit a bit lower. The average share of Belgian solar and wind as percent of demand is roughly one fourth (compared to one third of the Netherlands). The range of the Belgian data is also somewhat smaller (between 1 and 58%) compared to the Netherlands (between 4 and 68%). The overall shape is however similar. There is the same funnel shape that is widening the more capacity is added.
The following graphic illustrates the problem well.
Now it is easier to highlight a bit more the wide range that this average is derived from. These are the minimum and maximum values of the share of solar and wind in demand of each year:
It is clear that the lower and upper boundaries don’t increase in the same way The lower boundary is hardly budging, it keeps close to the x-axis over the entire period. In 2022, the lowest daily share supplied by solar and wind was only about 1% of total demand. This didn’t change much over the years: it was roughly between 0.7% and 1.8% of demand between 2014 and 2022. This tells us that a lot of dispatchable capacity will still be needed at specific times of the year (in this case, pretty close to the expected demand and, looking at its shallow slope, that might be the case for quite a while).
The upper boundary behaves different. It shoots up exponentially. In 2022, the highest daily share supplied by solar and wind was 58% of total demand, coming from around 20% in 2014.
Meaning that the difference between the lower and upper boundary will keep increasing over time. Basically, electricity production by solar and wind will at times start to exceed demand, while the need for backup at specific times of the year will stay high.
The key point illustrated in this graph is that over building wind and solar does not help much for those periods when wind and solar resources are low due to the weather.
Some people also seem to recognize this type of dynamic. Already the first comment below the tweet nails it (translated from Dutch):
If we now just install three times as much, then we have more than twice too much at the peak and are almost 90% short at the lowest point.
I couldn’t have said it better.
Discussion
Based on every study of intermittent wind and solar that I have seen, the difference between the lower and upper boundary of wind and solar output will keep increasing over time as these resources are added to any electric system. New York is not as bad as Belgium and Netherlands but it is the reason that the New York IRM will increase from around 20% to on the order of 150% in 2040. The reason for this universal truth is that meteorological conditions that cause light winds are geographically large. When the wind is light at one site in New York it is very likely that winds are light across the state. Data from Australia shows a similar effect across that entire continent.
There are a couple of ramifications. First, overbuilding is not a complete solution. Grid operators must always match load with generation. Therefore, resource adequacy planning must have a solution even at the minimum wind and solar generation output. If the overall state-wide wind generation capacity is only 10% you would need to overbuild by a factor of ten to provide power at night. Aside from the cost I believe that amount of wind development exceeds the expected wind resource availability in New York. In order to address this a new technology is needed. The New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid” for this reason.
The other part of the problem is that when wind and solar resources are over-built there will be more and more periods when their output exceeds demand. When that happens the electricity market has issues. Many wind and solar contracts are written such that the operators are paid whether or not the energy produced is needed. For example, the Ontario Independent Electricity System Operator must get rid of the unneeded power by selling it to neighboring control areas at below market costs. New York is a big purchaser of this cheap power. While those purchases drive costs down for ratepayers it also adversely affects the viability of in-state generating facilities. On the other hand, during the light wind conditions in-state generating facilities are needed so it may reach the point that they have to be subsidized to be available. Eventually New York will be in a similar position to Ontario. It turns out that the low- price sales are subsidized by Ontario ratepayers. When everyone has over-built I also wonder where the excess power will be dumped.
Conclusion
The graph of solar and wind generation resources as a fraction of the total resources shows a characteristic shape that proves that over building wind and solar generation does not help always fulfill load requirements. Electric grid operators must match the output of generating resources at all times so this means the problem has to be addressed. Further compounding the problem is the fact that peak loads are associated with temperature extremes that are linked to high-pressure systems that also create light winds. In other words the over-building effect is most pronounced when energy demand peaks exacerbating the risks to reliability when electricity is needed most.
At least one commenter understands the problem when he said “If we now just install three times as much, then we have more than twice too much at the peak and are almost 90% short at the lowest point”. I agree with Opdbe – I couldn’t have said it better.
The unanswered questions are how will the Climate Act implementation address this problem, what will it cost, and will it be able to maintain current standards of reliability.
On June 24, 2023 the Finger Lakes Times published a commentary, Alternate Energy: Scoping it out, Part VI: My humble opinion, conclusion by Jim Bobreski, a process control engineer from Penn Yan. The commentary concludes a series on the Climate Leadership & Community Protection Act (Climate Act) Scoping Plan. I started this post soon after his article was published but just got around to completing it. While I admire Bobreski’s efforts to try to decipher the Scoping Plan he makes a couple of mistakes that should be addressed.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition 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 Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.
In the age of Trump, energy, is as big and important an issue as it ever has been. The decisions we make as nations, and as individuals about energy are as important as always to our present, and more so to our future. However, in this age of Trump, there are delusions and confusion that he and his regime has perpetrated. Trump has succeeded in creating so much doubt that the average person thinks that up is down and down is up. He has turned science upside down as well. His interference with science has so obstructed the truth that Scientific American came out to for the first time in its 175 year politically neutral history and endorsed Joe Biden. This book is a collection of articles about the politics, economics, and technology of alternate energy and its importance to the future of civilization.
Commentary
In this section I will critique the commentary. Renewable energy advocates commonly make similar mistakes relative to the electric system. Although Bobreski was in power production his expertise in process control is not particularly relevant for electric system resource adequacy issues. Consequently there are misconceptions similar to those Richard Perez made arguing that New York should embrace a solar energy future.
The commentary is a mixture of good and bad points. He starts out explaining that technology advances are necessary to make the Climate Act Scoping Plan work.
A call to grandma cost about $5 back in 1970 which is about $38 today. Now the same call is almost nothing. My point: Technology today comes in leaps and bounds and fast. It improves so fast that as soon as you buy some new device, it is obsolete in some way the minute you use it.
My concern is are we becoming dependent upon technology’s rapid evolution to solve our problems? The scoping plan appears to count on this very thing to be successful. Can it happen? I think the answer is yes, but it’s a cautionary yes.
There are limits to this analogy for the electric system. Wind and solar energy have been subsidized for decades in the hopes that the technology would evolve to the point where it could stand on its own. However, there is no sign that the need for those subsidies will disappear anytime soon.
Theresa Hansen of “T&D World” magazine says, “Some locations in the US might meet President Biden’s goal of 100% clean energy by 2035, but I don’t see the entire country being fueled by zero carbon sources 12 years from now.”
“T&D World” is a trade publication for the power transmission industry and they ought to know!
It may be true that “some” locations may have 100% clean energy by 2035 but I don’t expect that it will be any large jurisdiction. I recently described problems with the transition including the European experience showing that wind is not viable, the costs of wind and solar in Germany are untenable, and that a rapid energy transition has many risks but that information is being ignored. There is a reason trade publications are called trade rags. They will publish anything to appeal to their readership.
In the past five columns, I have tried to put together some information about the directives of the Scoping Plan for the energy future of NYS. I concentrated on solar, wind, the grid and storage systems.
I would like to call this a story, because the efforts made by the state to go “green” stretch back over 40 years. In 1982 PASNY — now NYSERDA — planned to place a wind turbine on the shore of Lake Ontario. Numerous studies in NY have been performed on wind power over those years. Whatever became of this? I have filed Freedom of Information requests on the wind turbine projects proposed by PASNY, but have had no luck finding this information. I was attempting to garner what was already known then and why it wasn’t implemented at the time.
There is one mistake here. The state power authority changed its acronym from PASNY to NYPA not NYSERDA. The New York State Energy Research & Development Authority probably did wind turbine assessments for Lake Ontario but I have never seen them either.
A history of learning from others’ mistakes
Back in the early 1980s Germany embarked on an ambitious plan to go solar and wind. The wind turbines in 2022 provided 17.2% of Germany’s electrical power; solar provided about 8%. The problem that is now realized is the cost of making this decision. It was at a time when nuclear was the “energy cure” for clean and cheap energy, production solar panels were only 10% efficient and were very expensive.
To demonstrate my point, Hoffman Electronics in 1955 offered the first solar cell at 1785/watt at 2% efficiency and at today’s prices a solar cell at 21% efficiency by comparison would cost over $18,000 a watt. Germany proceeded anyway. Today the situation is diametrically reversed. Solar is now the cheapest form of providing electrical power. Nuclear is the most expensive. Although Germany produces about 25% from solar and wind it came at too big a cost.
This argument is based on the presumption that solar is currently the cheapest form of electric power. However, that is only true if the reference is to power capacity (MW). Even if solar capacity is half the cost of fossil capacity the cost for delivered energy is much more. We pay for the kWh electric energy we use each month and we expect it to be available 24-7 throughout the year. In order to provide usable energy, other things must be considered that destroy the myth that utility-scale solar is cheaper than other types of power plants. On average a well-designed solar facility can provide (round numbers) 20% of its potential energy possible in New York. A natural gas fired power plant can operate to produce at least 80% of its potential energy over a year. In order to produce the same amount of energy, that means that you need four times as much solar capacity. Even if the solar capacity cost is half the cost for the capacity the energy cost is double simply due to this capacity factor difference.
But wait, there is more. In order to make the energy available when needed storage must be added to the cost of the solar capacity. Also consider that the life expectancy of solar panels is half of the observed life expectancy of fossil-fired power plants. There are unintended financial consequences that affect the viability of other generators that are needed for reliability that add to ratepayer costs. Because the solar resource is diffuse, it is necessary to support the transmission system to get the energy produced by solar from where space is available to site acres of solar panels to where it is needed. There are inherent characteristics of conventional generation that contribute to the stability of the transmission system that are not provided by solar or wind generation. Someone, somewhere must deploy a replacement resource to provide those ancillary transmission services and that cost should be included the cost comparison. Finally, the Integration Analysis, NYISO, New York State Reliability Council, and the Public Service Commission all agree that another resource that can be dispatched and is emissions-free (DEFR) is needed when the electric grid becomes dependent upon solar and wind resources. The state’s irrational fear of nuclear generation precludes the only proven resource that meets the necessary criteria so an entirely new resource must be developed, tested, and deployed. The Integration Analysis and NYISO 2021-2040 System & Resource Outlook both project that the DEFR resource will be comparable in size to existing fossil resources but will operate no more than 9% of the time. I have yet to see an expected cost for this resource but have no doubts that it will be extraordinarily expensive. Summing all the costs necessary to make solar power usable for electric energy reliable delivery and there is no doubt that solar is much more expensive.
The weak link in NYS’ ambitious clean energy plan is the power storage medium. Choosing the right storage medium is critical and the answer may be to wait until these technologies prove themselves. Right now lithium and fuel cells are the only “off the shelf” storage mediums we have. Both have their issues. Lithium has its safety issues of thermal runaway and current fuel cells are expensive and use platinum, a very limited resource. Lithium too is limited as to availability.
I agree with this paragraph.
It has been said that one form of insanity is repeating a past failed experiment and hoping to obtain different results. The Scoping Plan, to put it mildly, is a highly ambitious plan. It treads in uncharted waters. Its success is hinged upon technologies that are not yet developed or not fully developed. Sure technology has been transformative but is the Scoping Plan actually built around an undetermined future? Will these ambitious plans repeat the mistakes of the past?
These are relevant points and I agree. Interpretation of the mistakes of the past is a challenge. For example, I think that the energy transition problems of Germany were due to the inherent challenge of using intermittent and diffuse wind and solar to power modern electricity and not because solar was expensive at the time it was installed. Overcoming all the reasons why solar produced energy is more expensive than fossil-fired energy is likely an impossible challenge.
Like Germany’s ambitious plan for which the country is now left holding the bag. With NYS’ plan the storage system can be viewed in the same way as the German situation. In my humble opinion, large-scale storage battery technology is the linchpin for the Scoping Plan’s success, a technology essentially at its marketable infancy. You may raise a skeptical eyebrow and note the first accessible battery was invented in 1804! Yes, that is true but there was no practical use for it, ergo no market motivation. Now that also is diametrically reversed. A plethora of battery technologies have come out of the metaphorical woodwork. Improved lithium ion, magnesium, zinc, aluminum, carbon, boron, graphene, iron and who knows what. Each promising their own unique benefit such as size, power density, rechargeability, increased life expectancy.
I agree with this paragraph. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. That does not mean we should not do something but it does mean that we have time to address this problem. If the storage problem cannot be solved then there cannot be a transition so I suggest that New York should focus more on developing technology that will enable the transition than on reducing emissions that cannot have any measurable effect on global warming impacts.
Recently the House Ways and Means proposed the “Limit, Save and Grow Act” (talk about a euphemism!) which has passed Congress. This act will greatly impede the change that we can meet the goals of clean energy. Instead it wants to cripple the Inflation Reduction Act, which provides for the advancement of alternate energy and a clean energy for the future. The GOP- sponsored bill should have been implemented during the 2017-21 era when that president authorized a $2.25 trillion-a-year spending spree that is responsible for the inflation we have today. This careless spending did not improve health care, education, clean energy or our infrastructure. With this act the GOP wants to stop advancement in alternate energy and a clean environment. Let’s hope the Senate feels differently.
I don’t have any comment on this.
In questioning average citizens, they respond with the three main concerns: the plan does not seem feasible in the amount of time, the cost of converting their homes to all electric, and the costs changing the system in New York.
The Scoping Plan is highly dependent upon Biden’s IRA, which as mentioned is under attack by the GOP. The Scoping Plan is also highly dependent upon technologies which have yet to be proven.
This is an excellent synopsis of my concerns. The Scoping Plan does not include a feasibility analysis relative to existing reliability standards, did not provide cost impacts for the citizens of New York, and failed to provide justification for the ambitious schedule. It does not matter if the IRA is under attack by Republicans. The question is whether it can provide sufficient support for Climate Act implementation.
My conclusion
Yes, we have to do something! Continuing to process oil by shale or sand sites and clear cutting to get there is consequentially damaging our forests and fresh water supplies. Not to mention the added expense of cleaning up these sites. Nuclear power is way too expensive. While solar and wind power have their flaws, they are far less than the path of oil and nuclear. Gov. Hochul must make the right decisions. It might be better to wait on the predictable advance of technology than to build a questionable foundation.
Conclusion
My over-riding concern about the Climate Act is that there is insufficient support to prove that the plans will not do more harm than good. The analyses comparing environmental impacts are biased and incomplete. At this time the Hochul Administration has not prepared a cumulative environmental impact statement that considers the effects of all the wind and solar generation projected in the Scoping Plan. Affordability and reliability concerns have been ignored and it is obvious that technological advances are needed if the transition is to be successful. I agree that the it is better to make implementation contingent upon necessary technology.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition 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 Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 reduction target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.
Cap-and-Invest Background
According to the Cap-and-Invest Analysis Inputs and Methods webinar (Inputs and Methods Webinar Presentation and View Session Recording) on June 20, 2023, the New York State Department of Environmental Conservation (DEC) and the New York State Energy Research & Development Authority (NYSE$RDA) are developing the New York State Cap-and-Invest (NYCI) Program to meet the greenhouse gas emission limits and equity requirements of the Climate Act.
The NYCI feedback webinars all included the following slide that describes the program. Setting a cap is supposed to provide compliance certainty and the revenues generated “will minimize potential consumer costs while supporting critical investments” in the control strategies necessary to meet the Climate Act targets.
NYCI Policy Modeling
The Analysis Inputs and Methods webinar mentioned above described the modeling analyses planned to support the development of the program: “This analytics study will assess potential market outcomes and impact from the proposed New York Cap-and-Invest (NYCI) program.”
In order to evaluate the effects of different policy options, the Hochul Administration has proposed policy modeling. This kind of modeling analysis forecasts future conditions for a baseline or “business-as-usual” case, makes projections for different policy options, and then the results are compared relative to the business-as-usual case. I disagree with the presumptions in the proposed modeling associated with which programs should be included.
The Scoping Plan modeling used a reference case that included “already implemented” programs and the NYCI Cap-and-Invest Analysis Inputs and Methods webinar proposed to use the same framework. Starting with the reference case developed for the Scoping Plan, the NYCI modeling proposed to add policies enacted since then. This reference case approach is misleading because it under estimates the total cost to meet the Climate Act emission reduction mandates.
I maintain that it is more appropriate to compare the policy cases to a base case that excludes all programs intended to reduce GHG emissions. NYCI revenues are supposed to “minimize potential consumer costs while supporting critical investments”. I believe that statement argues that NYCI proceeds are intended to fund all the control programs necessary to meet the Climate Act mandates and not exclude programs that were already implemented.
The Climate Act’s directives require the Commission to build upon its existing efforts to combat climate change through the deployment of clean energy resources and energy storage technologies, energy efficiency and building electrification measures, and electric vehicle charging infrastructure. In recognition of the scale of change and significant work that will be necessary to meet the Climate Act’s aggressive targets, the Commission directed DPS staff to assess the progress made in line with its directives under the Climate Act and to provide guidance, as appropriate, on how to timely meet the requirements of the Climate Act.
The Department of Public Service presentation on the Informational Report notes in the following conclusion slide that “ the estimates of total funding authorized by the Commission to date for various clean energy programs in some instances reflect actions that pre-date the enactment of the Climate Act.” This is the only reference to “already implemented” programs. The conclusion states that the information presented “represents direct effects of CLCPA implementation only, and only the portion of direct effects of programs over which the Commission has oversight authority.” I interpret that to mean that they are not concerned with which program implements the necessary control strategies but only the results of all the programs relative to the Climate Act mandates.
The Informational Report also notes that “It is difficult to pull out exactly what costs we would have otherwise incurred for infrastructure investment vs. the cost of CLCPA.” This is the reason a base case is necessary. You need some estimate of investments that would have occurred were it not for the policy. In my opinion if they were worried about the difference between pre-CLPA investment costs vs. CLCPA-mandated investments they would have mentioned it here. Because the Investment Report does not distinguish between costs for programs that pre-date the Climate Act and programs that are mandated by the Climate Act itself, I conclude that the NYCI modeling analyses should follow that precedent and not include “already implemented” control strategy programs.
Implementation Report Costs
I converted the tables in the Implementation Report to a spreadsheet so that I could combine the data from multiple tables. Three tables are of particular interest: Table 4: 2022 Electric CLCPA Recoveries, Table 7: 2022 Typical Monthly Electric Bills with CLCPA related costs disaggregated, and Table 8: Authorized Funding to Date.
Table 4: 2022 Electric CLCPA Recoveries summarizes costs recovered in 2022 by utilities for electric programs. The costs recoveries include: CES (electric only), CEF (electric only), certain VDER (electric only), Electric Vehicle Make Ready Program (electric only), Clean Heat programs (electric only), Integrated Energy Data Resource (electric only), and Utility Energy Efficiency programs (electric and gas). The table states that $1,175,788,000 in Climate Act costs were recovered in 2022.
Table 7: 2022 Typical Monthly Electric Bills with CLCPA related costs disaggregated is the first admission by the Hochul Administration of potential costs of the Climate Act to ratepayers. The basis for the
typical electric delivery and supply bills for 2022 was provided for the following customer types:
A. Residential customers (600 kWh per month),
B. Non-residential customers (50 kW & 12,600 kWh per month),
C. Non-residential customers (2,000 kW & 720,000 kWh per month), and
D. Non-residential high load factor customers (2,000 kW & 1,296,000 kWh per month).
PSC Staff requested the utilities disaggregate the cost components reported in Table 2 (electric) to determine CLCPA related impacts on customers. Climate Act costs added between 9.8% and 3.7% to residential monthly electric bills in 2022.
Table 8: Authorized Funding to Date “gives a sense” of expenditures that will ultimately be recovered in rates. The Implementation Report explains:
This annual report is a review of actual costs incurred by ratepayers to date in support of various programs and projects to implement the CLCPA and does not fully capture potential future expenditures, including estimated costs already authorized by the Commission but not yet recovered in rates. To complement this overview of cost recoveries incurred to date, we also present below a table of the various programs and the total amount of estimated costs associated with each authorized by the Commission to date. Table 8 gives a sense of expenditures that ratepayers could ultimately see recovered in rates. These values are conservative and reflect both past and prospective estimated costs.
It is important to note that the Commission authorized some of the estimated costs in Table 8 prior to CLCPA enactment and that the cost associated with these authorized programs will be recovered over several years to come, based on the implementation schedules for these projects or programs and will mitigate the cost impacts to ratepayers year over year. These estimated costs represent either total program budget, estimated total cost for the program over its duration, or costs incurred to date in support of the program. Additionally, these initiatives will result in a variety of other changes that will impact how much consumers pay for energy. A number of these would put downward pressure on costs, including benefits in the form of reduced energy usage and therefore reduced energy bills to consumers. The Department has also previously described market price effects that are a result of these investments. When load is reduced or more low-cost generation is added, it would be anticipated that energy prices would fall because the market would rely less on higher cost generators. In addition, investments in transmission infrastructure not only unbottle renewable energy but also yield production cost savings and reliability benefits.
In sum, the total estimated costs associated with these programs or projects should not be considered as entirely incremental costs to what ratepayers would otherwise pay. Subsequent annual reports may include additional information about costs recovered relative to the funding previously authorized by the Commission in these programs, including funds already expended in support of these programs.
The takeaway message from Table 8 is that the authorized funding to date of program costs that will eventually make their way to ratepayer bills totals $43.756 billion. Note that the spreadsheet version of this table details the footnote costs.
The following table (Summary tab in the spreadsheet) combines Table 4: 2022 Electric CLCPA Recoveries and Table 8: Authorized Funding to Date. This represents my best estimates of where the cost categories coincide but it represents my opinion only. Given all the caveats in the preceding description I don’t think anyone has a definitive handle on these numbers. The thing that jumps out is the difference between the relatively paltry $1.176 billion in estimated Climate Act costs collected in 2022 relative to the $43.756 billion in authorized funding. Table 4 data is for one year and Table 8 data is over multiple years. The caveats in the previous quotation should be kept in mind.
Buried in a footnote is an admission that these are not all the costs authorized. Footnote 7 in Table 8 states:
Not included in this table is the Propel NY transmission project, selected by the NYISO Board in June 2023 in response to the Commission’s declaration of a public policy transmission need (PPTN) to support injections of offshore wind energy to the Long Island system by 2030 at an estimated cost of $3.36 billion. Since the Commission did not directly approve this project, the estimated cost is not captured in the table above.
The bottom line is that this is just the start of the costs. The Propel transmission project is one example. I described this project and its costs earlier this year. I noted that the costs associated with this project are for 3,000 MW of offshore wind. The Climate Act goal is for 9,000 MW and the Scoping Plan Integration Analysis projects that 12,675 MW of offshore wind will be needed by 2040 in the Strategic Use of Low-Carbon Fuels mitigation scenario. If the transmission costs are proportional that would mean that transmission costs will be three to four times higher than the $3.36 billion listed for the program that is not included. I am sure that there are many more examples of programs that will be needed to satisfy the regulated utility obligations for Climate Act emission reduction mandates.
NYCI Reference Case Scenario
The proposed modeling methodology for NYCI proposes to follow the same policy modeling approach as the Scoping Plan where a business-as-usual baseline is not used as the comparison standard for the policy scenarios. Instead, they propose to use the Scoping Plan Reference Case described as “Business as usual plus implemented policies” that includes the following:
Growth in housing units, population, commercial square footage, and GDP
Federal appliance standards
Economic fuel switching
New York State bioheat mandate
Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
Funded building electrification (4% HP stock share by 2030)
Corporate Average Fuel Economy (CAFE) standards
Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)
Business-as-usual in my opinion should only include: growth in housing units, population, commercial square footage, and GDP; Federal appliance standards; and economic fuel switching. All the other programs only exist as part of electrification strategies to reduce GHG emissions.
The Analysis Inputs and Methods webinar presentation stated that the Scoping Plan’s Reference Case will be updated with policies adopted since the original modeling was completed. The webinar asked for input on which policies to include from the following list:
NYC Local Laws
Statewide new construction codes
IRA Incentives
Advanced Clean Cars II/Advanced Clean Trucks
100% sales MHDVs by 2045
100% ZEV school buses by 2035, 100% transit buses by 2040
IRA Methane Charge
EPA Supplemental Rule
NYS Part 203
AIM Act (EPA Technology Transitions)
All of these programs also exist solely to reduce GHG emissions. In order to determine the cost to meet the Climate Act targets they should be included as part of the policy case and not the business-as-usual case.
It can be argued that every line item in Table 8 could be considered part of the proposed Reference Case because some component of each category started before the Climate Act was enacted. Recall that the Informational Report did not try to differentiate between pre-Climate Act and post-Climate Act programs so there are portions of the programs listed that will likely not be considered appropriate for the reference case. However, using this definition most of these costs will be in the reference case and I would bet that the rationale and costs will not be documented well enough to determine which specific control programs are included.
One other way to differentiate between pre-Climate Act and post-Climate Act enactment is by the case number. The first two digits are the year the proceeding began. In my summary table there is only one case number 20 or higher. Strategic Use of Energy Related Data (Case 20-M-0082) has $72 million funding authorized to date. Using this approach, the proposed Reference Case would include $43.684 billion program costs as opposed to the $43.756 billion of total authorized costs. I believe that they can pick and choose programs to include or exclude based on this reference case approach to satisfy the political motivations of the Hochul Administration.
Discussion
The Scoping Plan has been described as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”. The quantitative documentation supporting the document hides relevant information even better. The single number that most New Yorkers want to know is how much will this cost. The Scoping Plan cost numbers did not answer that question.
I addressed the Scoping Plan cost and benefit numbers in my Draft Scoping Plan comments and the verbal comments I presented at the Syracuse public hearing. The issues I raised and summarized in this post have never been addressed. In that post I compared the Scoping Plan cost presentation to a shell game. A shell game is defined as “A fraud or deception perpetrated by shifting conspicuous things to hide something else.” In the Scoping Plan shell game, the authors argue that energy costs in New York are needed to maintain business as usual infrastructure even without decarbonization policies but then include decarbonization costs for “already implemented” programs in the Reference Case baseline contrary to standard operating procedure for this kind of modeling. Shifting legitimate decarbonization costs to the Reference Case because they are already implemented without adequate documentation fits the shifting condition of the shell game deception definition perfectly.
Anyone who has not spent much time following the Climate Act implementation process might ask why was this done for the Scoping Plan analysis and why is it being proposed for the NYCI modeling analysis. One of the justifications for the Scoping Plan was that the “costs of inaction are more than the costs of action”. Shifting implementation costs away from the Climate Act program reduced the costs of actions to the point that they could make that claim.
Why are they doing it again? One of the great unknowns in the NYCI implementation process is the revenue target. The rational approach would be to calculate expected total costs, revenues from Federal programs, revenues from utility ratepayers, and personal and business investments for required infrastructure then calculate the difference between costs and those revenues as the amount necessary for the cap-and-invest revenues. Each of those values is a politically sensitive number that will likely cause public outcry because it is going to be large. If the NYCI revenue target does not include all the costs necessary to meet the Climate Act targets because those costs are covered elsewhere, then the NYCI modeling can show that the program is “affordable” and will not be a major burden. Given that this strategy worked for the Scoping Plan “costs of inaction are less then the costs of action” scam I believe they are sticking with a proven strategy.
Conclusion
This past week there were signs of discontent with the potential costs of the Climate Act on utility ratepayer assessments. Utility bills in New York City will go up significantly next month when Consolidated Edison of New York’s new rate case assessments become effective. Con Ed admitted that renewable energy investments contributed to the cost increases. “Our customers demand safe and reliable service and increasingly renewable energy. This investment from customers is going to allow us to redesign and rebuild the grid, to move it towards electrification,” Con Ed media relations director Jamie McShane told Fox News Digital.
Comparison of the two state initiatives indicate that these costs are going to get much worse. The PSC Implementation Report states “The magnitude of change the CLCPA requires is significant and will present challenges related to the need to preserve the resiliency and reliability of the energy systems, and cost mitigation to preserve energy affordability”. The NYCI modeling assessment proposes to use an inappropriate modeling scenario that hides the true costs of implementation. I have little doubt that the Hochul Administration analysis team has already determined that this approach is necessary to provide a politically correct NYCI revenue target.
At this point all anyone can do is to ask for a full accounting of the costs and expected emission reductions for all the control strategies necessary to meet the net-zero Climate Act mandate. This information was not provided in the Scoping Plan but is a prerequisite for the proposed NYCI program.
Finally, note that the costs addressed in the PSC proceeding are ratepayer costs for energy. The overall strategy for de-carbonization is to electrify everything possible. The costs for each homeowner to replace their furnace, stove, and hot water heater with an electrical replacement is not included. There also will be homeowner costs associated with electric vehicles to say nothing of the cost of electric vehicle itself. When everything is added up the costs will be enormous. I do not think that customer demand for renewable energy is as strong as the desire for affordable energy. It is past time for the Hochul Administration to supply a full accounting of potential costs to residents and businesses so that people will be able to decide for themselves how much they want to pay.
The goals for two proceedings associated with the Climate Leadership & Community Protection Act (Climate Act) are not clear. The Public Service Commission (PSC) Order on Implementation of the Climate Act (Case 22-M-0149) is supposed to “both track and assess the advancements made towards meeting the CLCPA mandates and provide policy guidance, as necessary, for the additional actions needed to help achieve the objectives of the Climate Act”. The New York State Department of Environmental Conservation (DEC) and New York State Energy Research & Development Authority (NYSERDA) are implementing the New York Cap-and-Invest (NYCI) proposed by Governor Hochul which is a market-based program to raise revenues for the strategies necessary to meet the mandates of the Climate Act. The question for both programs is whether their goal is to address the Climate Act itself or the entirety of the effort needed to make the transition targets mandated by the Climate Act.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition 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 Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 reduction target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. This post addresses a couple of implementation components.
PSC Order on Implementation of the Climate Act
The order implementing this proceeding explains that:
The changes contemplated by the CLCPA are expected to profoundly transform the State’s regulatory landscape and impact every sector of the economy. The Public Service Commission (Commission) will play a critical role in these efforts as it continues to implement a variety of clean energy initiatives, including those related to the deployment of renewable energy resources to support the State’s transition to a zero emissions electric grid, energy efficiency, building electrification, and zero emission transportation.
The Commission has already begun to implement the many objectives of the CLCPA through a number of existing proceedings. To date, the Commission has authorized the offshore wind solicitations necessary to achieve the CLCPA goal of procuring nine gigawatts (GW), funded programs to support the electrification of buildings’ heating load and the transportation industry, supported both large scale and distributed clean energy project development, funded programs to reduce natural gas and electricity usage in the State, and instituted a coordinated planning process to evaluate local transmission and distribution system needs to support the State’s full transition to renewable generation.
The Commission has quickly taken action related to items within its jurisdiction to help put the State on a path to meet the aggressive CLCPA targets. However, in consideration of the scope of the CLCPA and the extensive work necessary to achieve its mandates, continuous monitoring of the progress made will be crucial to ensure the State remains on track to achieve these objectives. In addition, there are existing policies that will need to be reviewed, and new policies that will need to be developed, to further the enablement of the CLCPA. This proceeding will be the forum for such policy development. By this Order, the Commission institutes this new proceeding to both track and assess the advancements made towards meeting the CLCPA mandates and provide policy guidance, as necessary, for the additional actions needed to help achieve the objectives of the CLCPA.
On July 20, 2023 the first annual informational report for this proceeding was released. The Power Point presentation summarizing the results includes the following slide describing the purpose, requirements, and goals for the annual report. It explains that the PSC has statutory responsibilities in implementing the Climate Act that must be consistent with its “core mission to ensure that utilities can provide safe and adequate service at just and reasonable rates along with the reliability and resiliency of the system.” My interpretation is that the PSC is required to address all actions, both pre-and post-Climate Act enactment by the Commission to achieve the mandates of the Act.
The report describes the information provided:
The cost recoveries, benefits, and other information reported here are mainly focused on the direct effects of CLCPA implementation. Notably, the estimates of total funding authorized by the Commission to date for various clean energy programs in some instances reflect actions that pre-date the enactment of the CLCPA. With respect to both pre- and post-CLCPA measures, this report focuses only the portion of those direct effects arising from programs over which the Commission has oversight authority and does not account for programs implemented by other state agencies that are funded from other sources (e.g., Regional Greenhouse Gas Initiative (RGGI) funding). Examples of effects not captured here include property tax revenues to localities from newly developed renewable generation facilities, workforce development and job growth, and local air quality impacts, among others. It should also be noted that the benefits and costs of the measures discussed in this report do not accrue uniformly across stakeholders, and in some cases one stakeholder’s benefit is another’s cost. As such, this report generally describes a subset of benefits and costs related to the CLCPA and does so from the perspective of New York as a whole by using the Societal Cost Test. In instances where this report adopts a different perspective, it indicates what that perspective is. For those benefits that are difficult to quantify, this report includes qualitative descriptions of the nature, extent, and incidence of the benefit.
The issue I want to raise in this post relates to this description and the PSC core mission “to ensure that utilities can provide safe and adequate service at just and reasonable rates along with the reliability and resiliency of the system.” In particular, consideration of just and reasonable rates needs to consider the effect of other programs that directly impact rates. Although the Commission has no oversight authority for programs like RGGI and NYCI, the costs associated with those programs are passed through to ratepayers. Therefore, I believe that this report should include those costs and any other programs that directly affect ratepayer costs in its assessment.
New York Cap-and-Invest
In June 2023, DEC and NYSERDA hosted a series of webinars addressing NYCI implementation. The Cap-and-Invest Analysis Inputs and Methods webinar (Inputs and Methods Webinar Presentation and View Session Recording) on June 20, 2023 described proposed policy modeling. In order to evaluate the effects of different policy options, this kind of modeling analysis forecasts future conditions for a baseline or “business-as-usual” case, makes projections for different policy options, and then the results are compared relative to the baseline case.
The proposed modeling approach uses a unique approach. The Scoping Plan modeling used a reference case that included “already implemented” programs instead of the usual practice of a “business-as-usual” base case. The NYCI Cap-and-Invest Analysis Inputs and Methods webinar proposed to use the same framework. Starting with the reference case developed for the Scoping Plan, the NYCI modeling proposal will add policies enacted since then.
It is more appropriate to compare the policy cases to a base case that excludes all programs intended to reduce GHG emissions. Putting the pre-Climate Act programs and costs in the reference case means that the cost forecasts will not include all the measures necessary to meet the Climate Act mandates. One of the goals of NYCI is to “minimize potential consumer costs while supporting critical investments” but the proposed approach will only consider a subset of the total costs necessary to meet the Climate Act mandates.
Discussion
The question for both proceedings is whether the goal is to consider all the costs and benefits of the Climate Act or some sub-set. The Hochul Administration has never released its estimate of the total costs to meet any of the Climate Act targets. Instead of providing the cost and benefit components themselves only net numbers are provided to support the misleading and inaccurate party line statement that the costs of inaction are more than the costs of action. In order to make that statement the Administration used the reference case approach that hides the total implementation costs.
There are implications for these two proceedings. In order to provide the total costs, both should cover as many programs as possible. The PSC has statutory limits on its Climate Act Implementation analysis that precludes many aspects of the transition but I believe that they should incorporate the costs of Climate Act-related expenditures that get incorporated into ratepayer assessments even if they are not in a rate case proceeding. There was one relevant item not addressed in the PSC Climate Act Implementation Report. New York Public Service Law § 66-p. “Establishment of a renewable energy program” has safety valve conditions for affordability and reliability that are directly related to the PSC core mission “to ensure that utilities can provide safe and adequate service at just and reasonable rates along with the reliability and resiliency of the system.” § 66-p (4) states: “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 think that this mandate calls for including ratepayer costs that are not related to a rate case proceeding.
With respect to NYCI the question is what is the expectation for the revenues. The revenues needed to make the necessary changes to the energy system are not related to the legislation or regulation that drives the initiative. Therefore, the proposed modeling should evaluate the policy scenarios against a business-as-usual base case that excludes any program that exists to reduce GHG emissions. Furthermore, the proposed approach will not be able to provide an estimate of necessary revenues to meet the Climate Act mandates because it excludes already implemented policies and their associated costs.
Conclusion
The goals for these two programs should be clarified. I believe that I am not the only resident of New York that wants to know the all-in costs necessary to meet the Climate Act mandates. In order to provide those numbers both proceedings should address as many program costs as possible for the effort needed to make the transition targets mandated by the Climate Act.
I intend to evaluate the reported costs in the PSC Climate Act Implementation Analysis relative to the NYCI modeling proposal included programs. At this point I can only say the NYCI approach will be mis-leading for the revenue needs of the Climate Act transition costs but cannot estimate the magnitude of the error. Arbitrarily eliminating some costs is nothing more than a politically expedient ploy to downplay the total costs of the Climate Act.
A real short post. I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition. My boilerplate introductory material notes that I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The recommended videos in this post support my position.
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 Policies Hurt the Environment
There is very little career upside for anyone in a regulatory agency to speak up about the environmental impacts of wind and solar development. Consequently, there is not much apparent support for my belief that the Climate Act net-zero transition will do more harm than good. This post links to a video interview with John Baker, retired Assistant Chief with California Fish and Wildlife Department who describes double standards he experienced while enforcing California’s environmental laws:
“In the name of green energy, we’re sacrificing wildlife species. Because of the power mandates, we’re unable to enforce the take of that. I don’t think they have thought what that cost is to us as Californians and to the environment as a whole.”
Baker describes the pragmatic tradeoffs that have been ignored in the rush for net-zero transition.
Climate Fearmongering
Paul Homewood introduces a video with Neil Oliver: Weather maps are among the most blatant forms of fearmongering deployed so far. He notes that British weather maps on TV now use daily temperature maps with frightening colors. He calls out the fearmongers by describing historical European heat waves and goes on to call attention to the hypocrisy of the loudest voices. Finally he notes that the 99.7% of scientists meme is a “scam”.
As they say in the investment business, past performance is no guarantee of future profits. Just because the climatistas consistently got it woefully wrong in the past does not mean that this time around they aren’t right. They could be right this time. There may be a wolf for real this time.
But here’s the thing. They got it wrong in the past for a particular set of reasons. Those same reasons continue to apply in the present case too. Therefore, past performance guarantees the present performance to be precisely the same.
Pragmatic Environmentalist of New York 