Another Example of Gamesmanship in the Climate Act Integration Analysis

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

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

Climate Act Background

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

Draft Scoping Plan Shortcomings

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

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

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

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

Gross State Product (GSP) Degrowth

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

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

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

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

Conclusion

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

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

Is New York State Coming After Our Furnaces?

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

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

Is New York state coming after our furnaces?

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

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

What does that even mean?

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

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

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

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

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

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

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

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

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

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

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

My Response

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

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

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

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

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

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

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

Response from Shultz

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

New Climate Act Related Pragmatic Principle

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

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

Climate Act Background

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

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

Green Hydrogen Swindle

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

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

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

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

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

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

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

Conclusion

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

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

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

Pragmatic Principle 13 Kicking a dead whale on the beach

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

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

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

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

Climate Act Draft Scoping Plan Scenario Components

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

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

Climate Act Background

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

Integration Analysis Reference Case and Scenario 1

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

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

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

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

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

Integration Analysis Mitigation Scenarios

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

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

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

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

Scenario 1: Advisory Panel Recommendations

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

Figure 4: Draft Scoping Plan Page 72

2022

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

2025

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

2030

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

2035

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

2040

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

2050

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

Scenario 2: Strategic Use of Low-Carbon Fuels

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

Figure 5: Draft Scoping Plan Page 72

Italicized items are changes from Scenario 1

2022

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

2025

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

2030

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

2035

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

2040

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

2050

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

Scenario 3: Accelerated Transition Away from Combustion

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

Figure 6: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 2

2022

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

2025

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

2030

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

2035

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

2040

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

2050

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

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

Figure 7: Draft Scoping Plan Page 73

Italicized items are changes from Scenario 3

2022

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

2025

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

2030

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

2035

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

2040

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

2050

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

Conclusion

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

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

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

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

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

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

Overall Conclusions

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

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

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

Specific Comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

About the Author

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

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

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

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

ISO-New England Expert Speaks Out About Net-Zero Transition Risks

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for the state’s greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I have written a couple of recent posts (here and here) that described issues that have been raised by New York’s electrical grid experts but, as far as I can tell, are not being considered by the Climate Action Council.  I think part of the reason for this inaction is that the New York Independent System Operator (NYISO) has not come out in public explaining the issues that could affect reliability.  Gordon van Welie, the president and CEO of Independent System Operator of New England (ISO-NE), recently gave an interview that succinctly describes those issues.

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

Climate Act Background

As shown in the following overview summary. the Climate Act establishes a “Net Zero” target by 2050, various renewable energy mandates, a social equity component, and, of particular concern to me, a requirement for zero-carbon electricity by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that describes the strategies to achieve the mandates.  It was released for public comment on December 30, 2021, and comments on the draft can be submitted until June 10, 2022.

The Problem

In my opinion, the most pressing problem is the 100% zero-carbon electricity by 2040 mandate.  As described in my aforementioned posts, NYISO staff experts have generated analyses that are very concerning.  They have determined that on the order of three times the current total generating capacity will have to be built in the next 19 years.  Of that total, Dispatchable Emissions-Free Resources (DEFR) will be needed equal to around the total current capacity.  That is problematic because there is no resource available that generate power with the required characteristics.  During working meetings, those findings have been described as “stunning” and the question whether anyone is listening was asked. 

Reliability and affordability must not be compromised by the Climate Act.  I think the NYISO has to step up and publicly confront the Climate Action Council about their lack of apparent concern about these reliability issues.  Furthermore, it is laughable that the Draft Scoping Plan claims that the benefits out-weigh the costs when their implementation plan relies on some unknown and untested technology that cannot possibly be budgeted.

The Air Traffic Controller of Electricity

Commonwealth magazine published an article about the ISO-NE role operating the electric grid entitled “The Air Traffic Controller of Electricity”.  It describes an interview with Gordon van Welie, the president and CEO of ISO-NE that addresses the issues associated with the transition to an electric grid that relies on wind and solar generating resources. 

Gordon van Welie, the president and CEO of ISO-NE), says there are four pillars that support the regional power grid his organization oversees, and all four are showing signs of stress.

Pillar number one is renewable energy. With clean electricity the key to decarbonizing the transportation and heating sectors, van Welie says New England needs to produce or procure a lot more renewable energy. “It’s clear we’re not going fast enough,” he said on The Codcast.

Clearly if you want to decarbonize the energy, sector then wind and solar resources are needed.  Note that he makes the point that New England needs to both procure and produce more renewable energy.  It is a little-known fact and something that has not been incorporated into the New York Climate Act numbers that there are wind farms in New York that have contracts with New England generators for their “zero-emissions” credits.  If those generators are used to also provide credits for the Climate Act, then there is double-counting.  As noted before, the Draft Scoping Plan calls for enormous quantities of wind and solar must be developed.

Pillar number two is transmission, the ability to move electricity from where it is produced to where it is needed. Van Welie said transmission is adequate at the moment. But with power generation needing to double or triple over the next few decades to electrify the economy and deal with climate change, transmission is looming as a major hurdle. The decision by Maine voters to scrap a transmission line carrying hydro-electricity from Quebec into New England is a sign of the emerging problem

The same issues will undoubtedly arise in New York.  There is another transmission issue associated with an electric grid that relies on wind and solar.  Generating sources that produce electricity by spinning turbines provide ancillary services needed to maintain synchronous transmission grid stability.  Wind and solar generators are asynchronous so another resource has to be included to provide those services.

Pillar number three is the need for balancing resources, electricity that can be called on as backup when the sun isn’t shining or the wind isn’t blowing. “The problem in New England is we don’t have a very predictable input source into the electric grid, particularly in the winter time when the gas pipelines are constrained,” he said. “I really see [natural] gas the only option for balancing the system at the moment.”

Van Welie says other options for balancing fuels could be pursued, including clean hydrogen. But he sees little effort to seek out alternatives. “I don’t see any focus on that problem in the region,” he said. “We’re just relying on essentially season by season spot purchases of imported fuels and eventually we’re going to come up short with that strategy. “ 

The NYISO requirement for DEFR addresses this need for balancing resources. The Climate Act does not allow natural gas to be used for balancing the system.  The Draft Scoping Plan placeholder resource for DEFR is hydrogen.  I agree that there is no regional focus, including New York,  on that problem.    

The final pillar is energy adequacy. When it gets cold, and the gas pipelines coming into the region reach their limit, New England can run short of the key fuel needed to run the region’s power plants. Even when it’s not that cold, the high price of natural gas can affect the regional market.

This winter, for example, the war in Ukraine sent fossil fuel prices soaring on world markets. The higher prices for natural gas prompted New England’s electricity generators to shift to relatively lower-priced oil and even coal for fuel, both of which drove up greenhouse gas emissions. All that happened even as the winter was relatively mild. 

“It’s the second most expensive winter in our history of the wholesale markets, surpassed only by the winter of 2013-14, when we had a polar vortex,” van Welie said.

Energy adequacy in New York will be an issue when the state relies on wind and solar resources for the majority of its needs.  Until such time that an analysis of wind and solar resource availability over at least 70 years is completed New York won’t even know the worst case resource availability .  If that is not known then it will be impossible to adequately plan for energy adequacy.

Van Welie likens ISO-New England to the air traffic controllers who keep planes flying safely. Like air traffic controllers, ISO-New England doesn’t own what it oversees — the region’s electricity generating plants or transmission lines. Yet through management of the grid and oversight of various wholesale markets the grid operator is charged with getting power to where it needs to go and keeping the lights on.

This is also a good description of  NYISO responsibilities in New York.

Van Welie said it’s his responsibility to draw attention to problems as they arise, even if his warnings are not welcomed by environmental advocates who want to dispense with the use of fossil fuels immediately.

“I certainly do feel like I’m under fire and the organization as a whole is under fire,” he said.  His big fear is that demand for electricity will one day outstrip supply and force the grid operator to bring demand and supply back into balance by shutting off power to customers on a rolling basis.  

“We want people to know that’s a real risk,” van Welie said. “When we do that, it’s not going to feel like reliability. It’s going to feel like someone is turning your lights off.” 

In New York the Climate Act is a state law to dispense with the use of fossil fuels as soon as possible.   Note, however, that the law did not include a feasibility analysis.  The Climate Action Council does not want to hear there are issues.  Nonetheless, the NYISO has an obligation to keep the lights on and eliminating fossil fuels on the mandated schedule may not be compatible with current standards of reliability.  Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong” and that is exactly what we will be doing if the Council does not listen to the experts. 

Conclusion

The reliability oblivious Draft Scoping Plan is not addressing the four pillars described by van Welie.  I have previously described this approach as similar to wanting to jump out of a perfectly good airplane without a parachute assuming that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing.  The president and CEO of ISO-NE has described four parachutes that should packed before jumping out of an airplane.  He sees the future clearly and is willing to speak the truth about the missing parachutes. 

I wonder if the NYISO will forcefully comment on these issues on the Draft Scoping Plan document.   I have just about given up hope that they will make these comments in a public forum.  My only hope is that these issues are being discussed in private with the Climate Action Council.  Unfortunately, there are no hints that is happening.

Empire Center Lights Out Event

On May 3, 2022 at 8:00 AM the Empire Center is hosting a meeting entitled “Lights Out? The Climate Leadership and Community Protection Act and New York’s Energy Future” in Albany, NY.  The meeting is free and open to the public.  James Hanley from the Empire Center asked if I would be willing to spread the word about the event so I am sending this to my distribution list and will make a short post.

Background

New York’s Climate Leadership and Community Protection Act (CLCPA) was passed in 2019 and became effective on 1/1/2020. The Climate Action Council has been working since then to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021. 

Lights Out Event Description

The CLCPA lays out an ambitious slate of policy goals to promote clean energy and fight climate change. But can the state meet its energy needs under the new law and what will be the cost to New Yorkers?

Please join the Empire Center—and a panel of climate and energy experts from across the state—as we explore the economic and energy impacts of the CLCPA.

Event Details:
Tuesday, May 3, 2022
8:00 am to 11:00 am

Albany Capital Center
55 Eagle Street Albany, NY 12207

Agenda:
8:00 – Registration, Coffee & Networking

8:30 – The CLCPA and New York; Opening Remarks

  • James Hanley, Senior Policy Analyst, Empire Center for Public Policy

9:00 – Meeting New York’s Energy Needs Under CLCPA

  • Gavin Donohue, President of the Independent Power Producers of New York
  • Commissioner John Howard, New York State Public Service Commission
  • Ken Pokalsky, Vice President of the Business Council of New York

10:00 – Consumer Effects Of CLCPA; Costs, Benefits and Impact?

  • Richard Berkley, Executive Director of the Public Utilities Legal Project
  • Michael Butler, Mid-Atlantic Regional Director of the Consumer Energy Alliance
  • Donald Chahbazpour, Director of Policy and Regulator Strategy, National Grid
  • Hon. Kevin Parker, Chairman of the Committee on Energy and Telecommunications

Conclusion

It looks like a great group of speakers and I am planning to attend.  Actually it sounds like it would be a good topic for a future post.

Pragmatic Approach to Climate Change Policy

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 but is anything but a pragmatic approach.  Everyone wants to do right by the environment to the extent that they can afford and not be unduly burdened by the effects of environmental policies.  Similarly, there certainly is a risk associated with climate change that popular opinion wants to address.  This post highlights a couple of recent articles that I believe should be incorporated into a pragmatic alternative to the Climate Act. 

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

Climate Act Background

As shown in the following overview summary. the Climate Act establishes a “Net Zero” target by 2050, various renewable energy mandates, a social equity component, and, of particular concern to me, a requirement for zero-carbon electricity by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that describes the strategies to achieve the mandates.  It was released for public comment on December 30, 2021, and comments on the draft can be submitted until June 10, 2022.

Alternate Climate Change Policies

My Citizens Guide to the Climate Act is intended to be a layman summary of the difficulties of a net-zero transition.  I have posted articles recommending books that do a much better job than I have done to explain the problems here and here.  Unfortunately reading a book is a big commitment and recently I described an article, Inconvenient Truths About Energy, that describes most of the issues that worry me.  In brief, the consensus of all the authors of these recommendations argue that New York’s plans will cost a lot, hurt the world’s poor, and fail to fix the issues.

This post highlights two articles that are consistent with what I think would constitute a pragmatic approach to climate change.  In “A ‘Plan B’ for addressing climate change and the energy transition” Judith Curry describes problems with all net-zero energy transition programs.  On March 10, 2022 Doomberg published “A Serious Proposal on US Energy” that described four energy priorities.

Plan B

Judith Curry’s article describes the popular narrative that there is a climate change crisis and sums up the problem with the Climate Act and all net-zero energy transition programs:

“In a nutshell, we’ve vastly oversimplified both the problem of climate change and its solutions.  The complexity, uncertainty, and ambiguity of the existing knowledge about climate change is being kept away from the policy and public debates.  The dangers of manmade climate change have been confounded with natural weather and climate variability. The solutions that have been proposed for rapidly eliminating fossil fuels are technologically and politically infeasible on a global scale.” 

She continues the discussion of the current state of the science and makes another important point that argues for a more pragmatic approach to potential climate change impacts.  The Intergovernmental Panel on Climate Change (IPCC) modeling “projections neglect plausible scenarios of natural climate variability, which are acknowledged to dominate regional climate variability on interannual to multidecadal time scales”.  Natural climate variability accounts for most of impacts of the extreme weather events that “prove” the need for immediate action.  Ultimately “emissions reductions will do little to improve the climate of the 21st century – if you believe the climate models, most of the impacts of emissions reductions will be felt in the 22nd century and beyond”.  The emotional plea that we have to do something immediately for our children and grandchildren is not supportable.

The article goes on to address the urgency for the energy transition.  She defines Plan A as the attempt to reach net-zero in carbon emissions by 2050.  It is based on the precautionary principle that “rapidly reducing CO2 emissions is critical for preventing future dangerous warming of the climate”.  The Climate Act rationale is that there is a crisis.   However, Curry points out:

Note that the IPCC itself does not use the words ‘crisis’, ‘catastrophe’, or even ‘dangerous’; rather it uses the term ‘reasons for concern.’ Apart from the scientific uncertainties, the weakest part of the UN’s argument about manmade global warming is that it is dangerous. The highest profile link to danger relies on linking warming to worsening extreme weather events, which is a tenuous link at best.

Curry raises another important point:

All other things being equal, everyone would prefer clean over dirty energy.  However, all other things are not equal. We need secure, reliable, and economic energy systems for all countries in the world. This includes Africa, which is currently lacking grid electricity in many countries. We need a 21st century infrastructure for our electricity and transportation systems, to support continued and growing prosperity. The urgency of rushing to implement 20th century renewable technologies risks wasting resources on an inadequate energy infrastructure, increasing our vulnerability to weather and climate extremes and harming our environment in new ways.

The article goes on to discuss a Plan B:

The problem is with the urgency of transitioning away from fossil fuels, driven by fears about global warming.  By rapidly transitioning to this so-called clean energy economy driven by renewables, we’re taking a big step backwards in human development and prosperity. Nations are coming to grips with their growing over dependence on wind and solar energy.  Concerns about not meeting electricity needs this winter are resulting in a near term reliance on coal in Europe and Asia. And we ignore the environmental impacts of mining and toxic waste from solar panels and batteries, and the destruction of raptors by wind turbines and habitats by large-scale solar farms.

She goes on to argue:

Here’s a framework for how we can get to a Plan B.  A more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation. Whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.

So what does a Plan B actually look like?  Rather than top-down solutions mandated by the UN, Plan B focuses on local solutions that secure the common interest, thus avoiding political gridlock. In addition to reimagining 21st century electricity and transportation systems, progress can be made on a number of fronts related to land use, forest management, agriculture, water resource management, waste management, among many others.  Human wellbeing will be improved as a result of these efforts, whether or not climate change turns out to be a huge problem and whether or not we manage to drastically reduce our emissions.  Individual countries and states can serve as laboratories for solutions to their local environmental problems and climate-related risks.

A Serious Proposal on US Energy

As good as Dr. Curry’s article is, it is short on specifics for an alternate implementation plan.  The Doomberg article provides some specifics.  The article proposes four priorities to address the direct connection between energy and economic power. My proposed plan incorporates three of the priorities.

Not so long ago the idea that natural gas could be used a bridge fuel until aspirational technology that had zero emissions but could maintain current reliability standards was generally accepted as a rational approach. Doomberg quotes EQT CEO Toby Rice with what has happened to the natural gas industry: “You’re in a situation today where I think it’s very hard pressed for companies to be incentivized to go out and develop this large-scale infrastructure that this country needs, this world needs because of the regulatory uncertainty and just the pressure we get from anti-fossil fuel, keep-it-in-the-ground groups that are out there.Doomberg argues that “It is time to put an end to nuisance lawsuits, regulatory inertia, and environmental radicalism” because expanding the use of natural gas provides immediate benefits.  “It borders on criminal negligence that much of the Northeast burns oil to heat their homes” New England relies on foreign sources of not only oil but natural gas because of a lack of infrastructure.  New York State decisions blocking pipelines have materially contributed to this negligence.

Doomberg’s second priority would expand the production of a crucial component of solar cells:

With the natural gas industry unleashed, the President should make co-located production of polysilicon another national priority. The US blundered into allowing China to secure a dominant position in this critical market, and it is time to reverse that error. Making solar cells is incredibly energy-intensive, and cheap natural gas is the ideal feedstock. There’s going to be huge demand for solar in the decades ahead, and the only thing stopping the US from being the preferred global supplier is a lack of polysilicon production capacity.

The single stupidest New York decision related to zero-emissions energy is the closure of two nuclear stations.  The Shoreham plant was completed but closed in 1989 before it operated.  Indian Point was closed before its operating license expired removing 2,000 MW of the only zero-emissions capacity that can be expanded at the scale needed for New York’s electric system. The third Doomberg priority proposes a commitment to nuclear power.  In particular, “accelerate the development and deployment of small modular reactors (SMRs), which are safer, cheaper, and quicker to bring online than traditional nuclear power plants”.

Finally, Doomberg argues that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead”.   The reason: “there simply aren’t enough battery materials available to support the conversion of a substantial portion of our automotive fleet to full electric.”  It is ludicrous to not recognize that battery materials are a constraint, and that we must manage to that constraint.

Pragmatic Environmentalist Alternate Plan

The basis of my recommendations is my belief that the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology, that there is little additional risk for a policy that emphasizes innovation over implementation at this time, and that doing “good enough” will address many of the problems that the Climate Act purports to address. In short, my alternate plan would incorporate the natural gas, nuclear, and pivot away from BEV Doomberg priorities.   A recent article summarizes my fears that the Climate Act “solutions” are worse than the problem and his alternative priorities are more appropriate.

The ultimate problem with a transition of the electric grid that depends upon intermittent wind and solar generation is that there are extended periods when those resources are low.  Electric resource capacity planners have identified the need for a dispatchable emissions-free resource (DEFR) for those periods.  Unfortunately, there is nothing available at this time that meets the characteristics needed for that resource. 

I recently published an article describing my pragmatic principles as they relate to the Climate Act and I will mention several here.  Gresham’s Law of Green Energy shows that reliance on subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth.  I recommend a deployment plan that makes wind and solar implementation conditional upon the development of viable DEFR before any further deployment.  There is no sense going down that path until the required technology is unavailable.  In the meantime, inherent subsidies should be discarded.  New York’s electric markets should pay very little for any generating resource that is not dispatchable and discount “semi-dispatchable” resources that cannot guarantee availability during periods of high expected demand. In this approach solar net metering would be eliminated and the subsidies for the Champlain Hudson Express project would be much reduced because power is not guaranteed during the winter.

The Pareto principle or 80-20 rule states that 20% of efforts or inputs can yield 80% of the results or outputs and exemplifies “good enough”.  The Doomberg priority that the automotive industry should pivot from “a focus on full battery electric vehicles (BEVs) to plugin hybrid electric vehicles (PHEVs) instead” is a great example of the value of that principle.  I also believe that going all in for natural gas as suggested by Doomberg should be a priority.  New York’s irrational jihad against natural gas is not in the best interests of the state.

One of the problems highlighted in the Draft Scoping Plan is the effects of diesel exhaust on environmental justice communities.  The aspirational goal to convert tractor trailer trucks to zero-emissions BEVs is such a great leap forward in technology that it could be years, if ever, before it could be viable.  Conversion to PHEV trucks could resolve some of the issues but the development and deployment of compressed natural gas (CNG) trucks is further along.  Encouraging CNG trucks and cars would provide immediate reductions in inhalable particulate and ozone ambient concentrations.  This is a real problem as opposed to the contrived problems claimed from the use of natural gas that are incorporated into the Climate Act.

There is another viability aspect of the need for DEFR that should be considered.  One of my pragmatic principles is that we can do almost anything we want, but we can’t do everything.  New York’s reliability experts are worried about the quantity of generating capacity that is needed to meet the 2040 goal of a zero-emissions electric grid in general.  However, the fact that recent analyses project that the quantity of DEFR needed is on the order of the entire existing generation capacity raises a financial concern.  The only time that DEFR is needed is when there is lull in wind and solar resource availability.  When the costs for that high quantity but low-capacity requirement are determined it may be so high that New York will be unable to address other pressing environmental issues.

Conclusion

Three books support the conclusions of the articles referenced here: “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet” by Bjorn Lomborg;  “Apocalypse Never – Why Environmental Alarmism Hurts Us All” by Michael Shellenberger; and “Unsettled: What Climate Science Tells Us, What It Doesn’t, and Why It Matters” by Steven Koonin.  The referenced articles make a compelling case that the Climate Act is simply not good policy.  Dr. Curry explains that the claims of a crisis are not backed up when the veneer of the climate change “science” narrative is peeled back to the fundamental findings.  This obviates the need to charge ahead deploying today’s renewable technologies.  The Doomberg article offers serious solutions for the energy system.

I believe that existing technology is just not ready to meet the ambitions for a zero-emissions economy embodied in the Climate Act.  I concur with Dr. Curry that a “more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation” and that “whether or not we manage to drastically curtail our carbon dioxide emissions in the coming decades, we need to reduce our vulnerability to extreme weather and climate events.” My pragmatic approach would make deployment of wind and solar contingent upon the development of a viable DEFR technology.  The development of a new and hopefully more viable nuclear generating technology such as small modular reactors should be a priority even if a DEFR solution is found.  There are many advantages of natural gas that make it ideal for intermediate and peak load uses on the electrical grid; residential heating, cooking, hot-water, and backup electric generators; and as vehicle fuel.  It is not perfect because there are some emissions but when considered on a fair reliability, affordability, and environmental impact basis it deserves to be part of a sustainable solution to minimize overall global impacts and improve human well-being. 

I have no illusions that the Climate Act will be modified to incorporate nuclear and natural gas as priorities with the current administration and legislature.  However, when the costs are finally publicized to the general public or even worse show up on utility bills, we will see how much New Yorkers are willing to pay for achieving greenhouse gas emission reduction objectives and whether that willingness has limits.  I have long maintained that the costs will be too much and that there will be “yellow-vest” protest response