Scoping Plan Cost Obfuscation

New York’s 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 Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda” and voted to release the Draft Scoping Plan late last year.  I recently posted an article describing my fruitless search for cost number documentation that would enable me or anyone else to evaluate their cost claims.  This post describes an egregious example of hiding the true costs of the Scoping Plan.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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.

Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022. 

I have been working my way through the massive draft document preparing comments on issues that I see.  I have assessed the claimed benefits which was relatively easy because there was a relatively adequate amount of documentation.   However, the cost documentation is very poor.  I have explained that the only description of the net direct costs is a bar chart without a breakdown of the cost components.  This article addresses a nuance to the net direct costs presented in the Draft Scoping Plan.

Net Direct Cost Information

In my latest assessment of direct costs in the Draft Scoping Plan I documented what information was provided for stakeholder assessment of costs.  Starting on page 80 the Draft Scoping Plan section 10.3 Key Benefit-Cost Assessment Findings describes costs.  However, the technical documentation is in Appendix G: Integration Analysis Technical Supplement.   On page 64 of Appendix G, Section I, the text describes the cost metrics included in the Draft Scoping Plan:

The integration analysis includes calculations for three different cost metrics: Net Present Value (NPV) of net direct costs, annual net direct costs, and system expenditure.

        • NPV of Net Direct Costs: NPV of levelized costs in each scenario incremental to the Reference Case from 2020-2050. All NPV calculations assume a discount rate of 3.6%. This metric includes incremental direct capital investment, operating expenses, and fuel expenditures.
        • Annual Net Direct Costs: Net direct costs are levelized costs in a given scenario incremental to the Reference Case for a single year snapshot. This metric includes incremental direct capital investment, operating expenses, and fuel expenditures.
        • System Expenditure: System expenditure is an estimate of absolute direct costs (not relative to Reference Case). Estimates of system expenditure do not reflect direct costs in some sectors that are represented with incremental costs only. These include investments in industry, agriculture, waste, forestry, and non-road transportation.

In my article I explained that the net direct costs represent the total costs of all the mitigation actions minus all the costs of a reference case.  Appendix G notes that “redirecting investment away from status quo energy expenditures and toward decarbonization is key to realizing the aims of the Climate Act” but that overlooks that their estimate of status quo expenditures is already $2.7 trillion.  At the time I found no discussion what was included in the $2.7 trillion estimate.

Draft Scoping Plan that Describes the Reference Case

In order to better understand what is included in the reference case I looked for the term.  This section lists the results of a word search of the Draft Scoping Plan document for the term “reference case”.   In the main body of text there were some references but the substantive information was in Appendix G.

Appendix G, Section I page 8 and 83:

Together, the benefits of avoiding economic impacts of damages caused by climate change and the improvements in public health total $400 – 420 billion. Realizing these benefits will require an incremental investment over the 30-year transition of approximately 10 percent in additional spending, or $290 – $310 billion, in addition to redirecting the approximately $2.7 trillion in expected system spending under the reference case towards New York’s low carbon future.

Appendix G, Section I page 12 there is a footnote for Figure 4: Gross Greenhouse Gas Emissions by Mitigation Scenario, without any accompanying text, presumably the caption for the figure.

6 The Reference Case is used for evaluating incremental societal costs and benefits of GHG emissions mitigation. 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. For more details see Chapter 5.3.

Appendix G, Section I page 66:

When viewed in from a systems expenditure perspective (Figure 48), the NPV of net direct costs for Scenarios 2, 3, and 4 are moderate, ranging from 11-12% as a share of the NPV of reference case system expenditures ($2.7 trillion). Because significant infrastructure investment will be needed to maintain business as usual infrastructure within the state irrespective of further climate policy, redirecting investment away from status quo energy expenditures and toward decarbonization is key to realizing the aims of the Climate Act.

Appendix G, Section I page 68:

Net direct costs are measured relative to the Reference Case, but system expenditures are evaluated on an absolute basis. System expenditures increase over time as New York invests in infrastructure and clean fuels to meet Climate Act emissions limits. As a share of overall system expenditures, costs are moderate: 9-11% in 2030 and 25-26% in 2050 relative to current estimated expenditure levels.

Appendix G, Section I page 76 in the title to Figure 56 there is a reference to footnote 49:

49 The costs presented represent the costs relative to a Reference Case with equivalent levels of electrification loads, and as a result are not directly comparable to the electric sector costs presented in the economy-wide analysis, in which costs are measured relative to a Reference Case with Reference loads.

Aside from similar statements on pages page 78, and 83 of Appendix G, Section I that is all the results for the search on “reference case”.

Discussion

One of the arguments in the discussion of costs and benefits is that the realizing these costs only represents an “incremental investment over the 30-year transition of approximately 10 percent in additional spending, or $290 – $310 billion, in addition to redirecting the approximately $2.7 trillion in expected system spending under the reference case”.  In my original analysis of these costs, I mentioned that it is important to understand exactly what is included in the reference case in order to accept this statement.  However, no explanation is prominently featured in documentation.

However, when I searched the document for the term “reference case” there was some information, buried in a footnote reference to a figure caption that was missing.  It 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.”  This exposes the scam.  Cynic that I am I suspect that someone, somewhere intended to completely delete the caption for this figure so that the damning footnote would not be available.

Why is this so egregious?  Recall that the presented net direct costs are relative to the reference case.  If the reference case costs are higher by including mitigation efforts that are required to meet the Climate Act targets this approach perverts the numbers presented.  Energy efficiency is a critical component of the mitigation strategies and this statement says we are going to include those costs in the reference case.  Electrification of buildings is another key component and “funded building electrification” costs are in the reference case.  The last two items take the cake however.  The authors of the Integration Analysis have slipped the costs for the statewide zero-emissions mandate and Clean Energy Standard into the reference case so that those costs do not show up as net direct costs of the Climate Act.

If this is on the up and up then the projected benefits, which are also allegedly relative to the reference case, should exclude the emission reductions and associated benefits for energy efficiency programs and building electrification that are already funded, the statewide zero-emissions mandate, and the Clean Energy Standard.  That may be the case but it is impossible to tell because the only numerical description of the net direct costs is a bar chart without a breakdown of the cost components.

Conclusion

I certainly could have mis-interpreted these numbers and normally when my evaluation shows significant differences from someone else’s work that is my first thought.  However, this finding fits a consistent pattern of over-estimated benefits and under-estimated costs in the Integration Analysis. 

The claimed benefits for the avoided cost of GHG emissions range between $235 and $250 billion, but I have shown that the Integration Analysis incorrectly calculates avoided GHG emissions benefits by applying the value of an emission reduction multiple times.  If that error is corrected then the total benefits range from negative $74.5 to negative $49.5 billion.  

It is very difficult to verify Draft Scoping Plan cost numbers because of the lack of documentation, but in two instances I have projected costs inconsistent with the Plan.  I evaluated the projected costs for residential retrofits to electric heating.  I estimated in the Draft Scoping Plan the entire building sector component cost is $230 billion relative to the reference case.  I calculated that just the residential retrofit heat electrification costs range between $259 billion and $370 billion using one methodology and between $295 billion and $370 billion using a different methodology. In the other analysis I estimated the costs and benefits of upgraded rail transportation.  The draft scoping plan claims a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion between Scenarios 2 and 3 and Scenario 4.  I estimate that the only valid cost for the difference between the scenario rail alternatives is $8.4 billion and that it would only provide a vehicle mile reduction of 64.7 million miles. 

Were it not for this consistent pattern I would be reluctant to label this egregious example of hiding the true costs of the Scoping Plan as a deliberate attempt to obfuscate direct costs.  However, the lack of documentation, the complete absence of reference case details  and contrived way they present the cost numbers convinces me that this is deliberate.  In order to “prove” that the Climate Act benefits out-weigh the costs they have deliberately cooked the books.

The rebuttal for my claim is for the Climate Action Council to provide complete and transparent documentation.  It would be best if the Council would host an expert analysis session where the costing methodology used could be explained and the public could be given the opportunity to provide questions beforehand.  Obviously, this post could provide a number of those questions.  While it would not be possible to address all the sectors in such a session this format could provide answers to the cost projections most impactful to New York residents.  Residential electrification and personal transportation head that list.

There is a massive disconnect between the costs projected in the Draft Scoping Plan any by other authors.  Earlier this year I compared costs estimated in the Scoping Plan with costs in an article by Ken Gregory that is a critique of a report  by Thomas Tanton “Cost of Electrification: A State-by-State Analysis and Results”.  Tanton estimated that the New York overnight cost for a net-zero economy is $1.465 trillion.  Gregory’s estimate for net-zero consistent with the Climate Act is $18.2 trillion.  Until such time that the Climate Action Council produces documentation that enable independent verification of their estimates, I believe the actual costs will be consistent with these higher estimates.

Scoping Plan Renewable Energy Resource Availability Analysis

New York’s 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 Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  This post describes comments I submitted to the Council about the inadequate analyses of renewable energy resources in New York.  It is important to get this right because the availability of renewable energy resources informs the basis of resource adequacy planning.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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 Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.  The integration analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The Scoping Plan has to be finalized by the end of 2022 and a recent meeting discussed issues that need to be addressed to meet that schedule.

New York’s unprecedented transition to a zero-emission electric generating system means that the system will be heavily dependent upon wind and solar resources.   Because those resources are intermittent it is imperative that New York energy planning determine the frequency and duration of periods when wind and solar resources are low.  This article summarizes comments that I submitted on the problem, describes analyses that address this issue completed elsewhere, and recommends that New York agencies develop an appropriate study centered on New York.

Problem

The comments included a description of New York blackouts and the responses made to prevent reoccurrences.  I believe that, despite the best efforts of those responsible for the reliability of the electric grid, the transition to an electric power system that relies on intermittent wind and solar resources introduces so many changes that it will be impossible to anticipate them all.  As a result, grid resilience will decrease and blackouts are inevitable.   For example, consider that a team of researchers from the University of Nottingham recently addressed the effect of renewable energy resources on power grid stability.  The abstract from the paper states:

Contemporary proliferation of renewable power generation is causing an overhaul in the topology, composition, and dynamics of electrical grids. These low-output, intermittent generators are widely distributed throughout the grid, including at the household level. It is critical for the function of modern power infrastructure to understand how this increasingly distributed layout affects network stability and resilience. This paper uses dynamical models, household power consumption, and photovoltaic generation data to show how these characteristics vary with the level of distribution. It is shown that resilience exhibits daily oscillations as the grid’s effective structure and the power demand fluctuate. This can lead to a substantial decrease in grid resilience, explained by periods of highly clustered generator output. Moreover, the addition of batteries, while enabling consumer self-sufficiency, fails to ameliorate these problems. The methodology identifies a grid’s susceptibility to disruption resulting from its network structure and modes of operation.

My comments included a description of the Texas blackout of February 2021.  Ultimately the reason for the blackout was poor planning.  When the people of Texas needed electric power the most the generating resources available were unable to meet those needs.  In order to prevent the same thing from happening in New York it is necessary to provide sufficient energy at all times.

Reliability planning in the past relied on dispatchable generating resources.  The Climate Act future electric generating system will rely on intermittent renewable wind and solar that is not dispatchable.  Energy storage resources are needed to cover periods when wind and sun energy is not available to provide dispatchable electricity.  The problem is that we have to know what the worst-case renewable resource availability is in order to size the energy storage resources correctly.

Last year I described issues related to this as the Climate Act’s ultimate problem. Although there have been analyses that have identified winter wind lull periods are a problem, I do not believe that they addressed this analysis correctly because they used relative short periods as the basis for their projections.  As far as I can tell the Integration Analysis did not even consider the same period for wind and solar resources in their analysis.  As a result, I believe the Draft Scoping Plan projections for the amount of resources during these periods is incorrect.

Proposed Analysis

In order to do this right, the critical consideration is the frequency, duration, and severity of periods when wind and solar resources are in “droughts” or low resource availability.  I described several recent applicable papers that estimate the frequency and duration of periods with those conditions using a meteorological reanalysis data base.  In this approach historical observations are re-analyzed using current weather forecast models.  The first step in developing a weather forecast is to incorporate meteorological observations to setup the weather maps that are the starting point for weather forecast calculations.  That component of the models is used to develop weather maps for the observations and the forecast component is used to provide hourly data until the net observation period.

In order to provide a robust estimate of the wind and solar availability during worst case conditions it is necessary to analyze as long a time period of historical meteorological data as possible. The ERA5 global reanalysis data base generated using this reanalysis technique provides hourly estimates of a large number of atmospheric, land and oceanic climate variables. The data cover the Earth on a 30km grid and resolve the atmosphere using 137 levels from the surface up to a height of 80km. That information is then used to estimate the availability of hourly wind and solar resources for any area of the globe.

Last fall I described a paper that included an approach that might work for an analysis centered on New York.  Since then, I have been in touch with the author and I am not confident that using these data would be provide invaluable information. 

In my comments I strongly recommended an analysis in New York using the complete (1950 to present) ERA5 meteorological database to determine the frequency and duration of renewable resource droughts in order to estimate the appropriate worst case.  The goal of the project would be three-fold:

  • Determine historical intensity, frequency, duration and seasonality of wind and solar droughts in New York;
  • Identify co-occurrence of wind and solar droughts with high demand periods (heating/cooling degree days); and
  • Interpret the droughts and high demand periods: seasonal, weather regimes, interannual variability (e.g. El Niño-Southern Oscillation), multi-decadal climate regimes, and trend associated with global warming

Conclusion

I have submitted comments in various proceedings and have tried to work behind the scenes to get this analysis completed because I don’t think it is possible to adequately project the renewable resources necessary to keep the lights on when needed most without this information.  I submitted these comments to get on the record again that this work has to be done to ensure that sufficient renewable energy generation and energy storage is developed to prevent blackouts.

New York Climate Action Council Plan for 2022

New York’s 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 Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda” and voted to release the Draft Scoping Plan late last year.  After a two-month hiatus the Council finally got around to having a meeting to discuss the plan for 2022 on March 3, 2022 (recording here).  This post describes my thoughts about the meeting and plan.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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 Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.  The integration analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. At that time, the Climate Action Council stated that the public comment period would extend through at least the end of April 2022 and would include a minimum of six public hearings. This meeting outlined their plans for 2022.

March 3, 2022 Meeting

The meeting followed the usual routine of all previous meetings.  After the formal welcome, roll call, and consideration of the previous meeting minutes, the co-chairs take the floor to blame any recent unusual weather on climate change (slow couple of months because there were no examples this time), to brag about what a great job they are doing with the implementation process, highlight anything the Governor proposed related to the climate recently (in this case the State of the State annual address), and highlight any related project awards.

My primary interest was the overall goals and objectives discussion starting at 23:50 of the video.  There was a discussion of the proposed 2022 activities & schedule, a debate about the outstanding topics that required further deliberation, an agreement about the decision-making process and a conversation regarding public engagement.

2022 Schedule 

The activity and schedule overview discussion starting at 25:41 in the recording was disappointing.  The proposed plan is for three phases.  From the start of the year through the end of April they proposed to gather information.  From May to August the information there will be a discussion and deliberation phase.  Over the rest of the year the final scoping plan will be drafted and finalized.  This is disappointing because there is no iterative component.  There is no chance for stakeholders to ask questions and respond to their answers.

In addition, there is no opportunity for the Council to ask stakeholders about their comments. If, for example, the Council ever gets around to reading the comment I submitted on February 1 where I argue that the claims that the benefits are greater than the costs are wrong, I believe that claim should be addressed and not ignored. There was no indication in the discussions that this situation would ever arise which pretty much suggests to me that this process is just going through the motions and substantive issues raised in comments will simply be ignored.  It that is not the case and they do respond to substantive issues like whether the benefits may not be greater than the costs, then I think I should be given the chance to rebut whatever hand-waving argument they contrive to claim I am wrong. 

The next slide (25:41 in the recording) presented the plan for Council meetings and supporting activities) It is encouraging that the expert topical input includes the opportunity for experts to provide input and feedback on topics of interest and for representatives of key sectors and industries to provide targeted feedback on topics of interest.  However, there is a problem because throughout the implementation process to date, only one side of the transition challenge has been heard. The Council members who spoke at the meeting are missing this point.  I will discuss this concern more later.

Climate Justice Working Group feedback was the subject of the next slide (30:12 in the recording). In my opinion the Climate Action Council has placed an inappropriate level of focus on this feedback.  There is a Public Service Commission mandate that should be the first priority.  Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

I interpret that to mean that the Climate Act has to meet the following obligations:

  • It cannot impede the provision of safe and adequate electric service (i.e., reliability)
  • It cannot impair existing obligations and agreements and I assume they mean existing contracts
  • It cannot cause a significant increase in arrears or service disconnections that the commission determines is related to the program (i.e., affordability)

The Council’s focus on meeting the targets and placating the Climate Justice Working Group ignores these obligations.  With all due respect to the Working Group, they have no affordability and reliability responsibilities so their priorities differ and could easily result in a Scoping Plan that does not address those obligations adequately.  More importantly, reliability and affordability issues impact disadvantaged communities more than other communities so they should be their priority too.

The next slide addressed public input (33:27 in the recording).  The Climate Action Council is required to hold six in-person hearings across the state but they proposed to add one more public hearing and two virtual public hearings.  However, I am very disappointed with the proposed hearings approach because I think that substantive issues raised won’t get recognized.  They apparently plan to follow the same approach to public input as was used for the advisory panels input.  In particular, they plan on three-hour hearings and to limit speakers to two minutes which is insufficient time for anything meaningful.  Instead it is about enough time for a speaker to say that they are in favor or not in favor of the plan.  Ultimately this approach means the Council is simply going through the motions for the public input requirement of the Climate Act.

The concept that the Council would hold meetings to solicit expert input was a feature in the presentation.  However, there was no recognition that the Council might want to invite speakers to participate in a Council meeting if their comments raised issues not addressed in the Draft Scoping Plan.   

Another issue related to the public comments is how they will be handled.  It was mentioned that there already have been over 1,000 comments submitted to the portal.  The following slide says that “Council to consider the full set of public comments after the comment period closes” (discussed at 34:20 in the recording) but it is silly to wait to start to evaluate the comments until the end of the comment period.  Clearly staff has to be organizing the comments and there was mention that the Council will have access to the NYSERDA web system to see the comments.  I think that the comments should be publicly available after they are reviewed for acceptability and not held from the public until the end of the public comment period.  The comments should be sorted regarding relevance to specific chapters, issues, or form submittals expressing generic support or lack of support.

The proposed schedule and meeting locations for the public hearings was discussed starting at 35:30 in the recording.  Staff pointed out that adding other meeting locations beyond the six mandated in the Climate Act means that the comment period is going to be extended 30 days until the end of May.  Nonetheless Council members suggested additional public hearings in Nassau/Queens, Yonkers/Westchester, Southern Tier and Mid-Hudson areas.

There was a long discussion about the timing, content, and format of the in-person and virtual meetings. 

The next slide (1:12:55) discusses the Integration Analysis plans for 2022.  The authors not that “priority topics can be addressed by focused sensitivity analysis”, but also mentions that there isn’t much time to able to do additional research based on feedback. 

This reinforces my argument that the feedback from already submitted public comments and others submitted before the end of the public comment period should be evaluated and considered on an on-going basis.  The slide says that the analyses needed will “need to be finalized within the second quarter of 2022”.  Three potential areas of inquiry are mentioned in the slide:

  • Continued assessment of impacts of electrification, heating system configuration, and magnitude of building shell efficiency investment on key output metrics (e.g., system peak, cost)
  • Impacts of expanded uncertainty range of electric distribution system cost
  • Further alignment of benefit cost framework with net GHG emissions accounting in Statewide GHG Emissions Report

While I don’t disagree with these areas of inquiry, I am disappointed that the words feasibility, reliability, and affordability are not mentioned.  In my opinion the Draft Scoping Plan does not address those concepts adequately. The fact that they are not menti0ned suggests that the authors of the Draft Scoping Plan think they are covered.

The next slide (1:14:50) describing 2022 activities discusses the finalization of the Scoping Plan.  It just fits the finalization into the schedule.  After this slide was presented, there was an opportunity for comments and discussion (starting at 1:17:00).  Carolyn Ryan pointed out the time to discuss public comments is going to be limited so it will be difficult to incorporate public comment.  Sarah Osgood pointed out that there have been 1100 to 1200 comments submitted already.  She said that they would be summarizing them as quickly as possible as they come in and consider how to present them to the Council for consideration.  At 1:20:50 Gavin Donohue made the first mention of reliability.  He said that he hoped that expert engagement would include this topic. 

Topics and Process

According to the next slide (1:24:30), equity and climate justice “are overarching lenses to apply consistently to all topic areas”.  That sums up the framework of Climate Act implementation as it stands.  In any rational take on implementation, reliability and affordability should be the overarching lenses applied to all topic areas.  Isn’t it obvious that this is the cornerstone to equity and climate justice because an unaffordable and unreliable energy system will impact those least able to pay the most?  Incorporating those social justice issues as part of the need for an affordable and reliable system is the appropriate approach but I fear it is not on the agenda.

Three topics were discussed that “require more deliberation” starting at 1:27:02.  All of these issues were raised by members of the Climate Action Council.  In order to meet the Climate Act mandates the natural gas system has to be replaced and this is the first topic.  Some Council members have interpreted the law to preclude the use of combustion entirely so the “potential applications of advanced fuels” topic addresses this issue.  If it is not necessary to consider technological feasibility then adding another layer of untried technology at the scale necessary may be appropriate but someday, someone has to point out that eliminating combustions has risks.  Chapter 17, Economy-Wide Strategies of the Draft Scoping Plan addresses comprehensive policies that price GHG emissions. 

In the process for supporting council decision-making slide (starting at 1:30:33) several suggestions were made.  Given that there are unresolved issues even before the public comment period started a process is an obvious need.  There is no question that additional input and support to the Council are needed.  During the meeting they talked about subgroups developing recommendations for particular topics.  My concern is that the topics chosen will be based on the biases of Council members rather than on the feasibility of the proposed transition without adverse impacts on reliability and affordability.

Starting at 1:47:00 the three identified topics were discussed in detail.  This particular discussion was so relevant that I am going to make it the subject of another post.

The last substantive slide (2:46:20 in the recording) addressed the decision-making process itself and particularly how they will address “consensus”.  I think the statement “Consensus requires that there has been a good faith effort to find a package of recommendations that meets the most important interests of Council members” sums up my over-arching concern about the Council.  In particular the interests of some of the more vocal Council members are ideological rather than logical.  I keep mentioning affordability and reliability feasibility concerns because those ideologues are ignoring those critical concerns.  Given that every other jurisdiction that has tried to implement some similar transition to emissions-free energy systems has run into problems with affordability and reliability ignoring them in this instance is a recipe for disaster.  Of course, when that happens it will be somebody else’s fault.

Discussion

There are some over-arching points to be made regarding the 2022 Climate Action Council plans for this year.  The first issue is logistical.  The outlined plan does not place enough emphasis on starting to address comments received as soon as possible.  I believe the process of summarizing, categorizing, and disseminating comments should start immediately so that the Council can determine if there are substantive issues that need to be addressed.  If the Council makes it clear that the sooner a substantive issue is raised, the more time they will have to address it, then I think stakeholders will realize it is in their best interests to get comments in as soon as possible rather than waiting until the comment period closes.

I was disappointed that reliability and affordability were not at the top of the list of issues that need to be addressed in 2022.  It appears that climate justice and disadvantaged communities are higher priorities despite the massive impacts of higher costs and unreliable power on those least able to afford higher costs and blackouts.  That point of emphasis reinforced my concern that for many on the Council the green energy transition is more about political pandering to specific voting blocs than addressing climate change in a rational way.

Finally, the Council appears to be tone deaf to the need to hear both sides of substantive issues.  For example, Dennis Elsenbeck at 1:44:58 bias notes that we “use the word bias all the time”.  He goes on to argue that there is bias in this entire process but then claims that “You deal with bias by having an unbiased facilitator”.  In the discussion of combustion avoidance his suggestion is that the Council should hear from experts like Plug Power on the topic of fuel cells.  According to their website, Plug Power is the “leading provider of clean hydrogen and zero-emission fuel cell solutions that are both cost-effective and reliable”.  There is zero chance that any presentation they give to the Council is going to suggest in any way, shape, or form that fuel cells are not the answer with no downsides.  If all the presentations to the Council are from subject matter experts that have a bias towards their technology, then an unbiased facilitator will not be needed because there is only one side presented.  It is time to open up the discussion and make sure that the pros and cons of all implementation topics are heard.  For example, at 29:40, Sarah Osgood mentioned having a presentation on district heating systems.  If this is done then they should not invite just the advocates for those systems but people who can describe potential issues with this approach.

Conclusion

The scope and schedule of the Climate Act transition to a “zero-emissions” energy system is so daunting that a full accounting of the risks to reliability and affordability cannot hope to be adequately addressed in the time frame available.  Nonetheless, I had hoped that the Council would consider the inconvenient issues as well as the convenient issues.  The plan for the electric system transition relies on technology that does not exist.  Any responsible implementation plan would incorporate specific technological and cost conditions in the schedule for this massive transition to ensure that the technology needed is available before the existing system is dismantled.  The Integration Analysis has not confronted this reality and the Council appears blissfully unaware of this risk  The public comment period is supposed to afford stakeholders the opportunity to raise concerns about the viability of the proposed plan relative to issues like this.  However, the plans outlined at this meeting suggest that the public comment requirement will be treated as a formality rather than an opportunity for meaningful issues to be raised and considered.  I do not see how this will end well.

Integration Analysis Transportation Incremental Benefits Associated with Scenario 4

New York’s 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 Climate Action Council has released for public comment the Draft Scoping Plan that outlines the implementation plan for the Climate Act. The document is huge as it covers all aspects of New York’s energy system.  This post looks at one minor component of the Scoping Plan’s mitigation scenarios to determine if the numbers presented are reasonable.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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 Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan.  The Integration Analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

The Integration Analysis developed four scenarios to compare with a reference case that describes the New York energy system without the Climate Act.  The first scenario is based on Advisory Panel inputs but did not meet the Climate Act targets.  According to Appendix G, Integration Analysis Technical Supplement, Section I, page 13:

Transformative levels of effort are required across all sectors, and scenarios include high levels of electrification including Scenario 2, which also incorporates 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 including use of some low-carbon fuels, examining very high VMT reductions, and assuming high (but also highly uncertain) levels of innovation in the waste and agriculture sectors. The Council expressly seeks feedback on the components of these scenarios of which detailed information can be found in the sector strategies portions of the sectoral chapters in this draft Plan.

This article describes only one component of the strategies.  Make no mistake there is so much information presented and the documentation is so marginal that it is impossible to evaluate all the components in any detail.  For this article I am going to address one aspect of the transportation sector plan. The addendum to this article consolidates relevant information in Appendix G, Integration Analysis Technical Supplement, Transportation in Section I starting on page 35 where the components of the transportation sector scenarios are described.

Transportation Component Comment

The mitigation scenarios reduce transportation emission by reducing the miles traveled by vehicles, adoption of zero-emission vehicles, electrification of non-road sectors, and targeted low-carbon fuel use. Reducing energy consumption means that GHG emissions are reduced within the transportation sector.

When I evaluate a regulatory proposal my first step is to try to reproduce the proposal’s numbers so that I can verify that the assumptions used are reasonable.  Even though I limited myself to just the transportation sector there still are far too many aspects to consider them all.  The scenarios proposed to reduce vehicle miles traveled using smart growth, expanded public transit, telework and demand management programs but all of those strategies are broader than I want to deal with at this time.  I considered discussing the suggestion that there could be a “small role for electric aviation in decarbonizing short distance flights by 2050, and hydrogen aviation to decarbonize medium distance flights”.   The claim that “hydrogen and electric aviation displace 47% of remaining aviation fuel demand in Scenario 4” sets off my BS detector but I chose instead to use a different claim in this article to see if the numbers can be trusted.

In this example I will address the enhanced transit & mobility claims related to the Scenario 4 alternative “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS”.  In particular, I am only going to address the rail improvements measure shown in Table 11 of Appendix G: 200 million light duty vehicle miles can be reduced relative to Scenarios 2 and 3 at a per unit cost of $6 per mile.

57 Moving Cooler: http://www.reconnectingamerica.org/assets/Uploads/2009movingcoolerexecsumandappend.pdf, accessed November 2021

Empire Corridor Draft 1 Tier EIS: https://railroads.dot.gov/environment/environmental-reviews/empire-corridor, accessed November 2021

EU Hydrogen Aviation Study:

https://www.fch.europa.eu/sites/default/files/FCH%20Docs/20200720_Hydrogen%20Powered%20Aviation%20report_FINAL%20web.pdf, accessed November 2021

58 Scenario 2 and Scenario 3 include 9 billion LDV miles reduced in 2050 relative to Reference scenario, from enhanced transit and mobility; telework and travel demand management; smart growth and mode shifting to biking/walking; No $/mile cost was assessed for tranche of VMT reduction achieved in Scenarios 2-3. Table above shows incremental investment relative to Scenarios 2-3

Table 11 documents transportation-related incremental costs associated with Scenario 4.  It claims that the per-unit cost is $6 per mile and that 200 million light duty vehicle miles will be reduced relative to Scenarios 2 and 3 in 2050.  The plain reading of this is that the 200 hundred million light duty vehicles miles reduced will cost $6 per mile or $1.2 billion.  The basis of the claim is the “Empire Corridor Draft 1 Tier EIS” which is an analysis of improvements that could be made to railroad passenger service in New York.

Empire Corridor Rail Passenger Improvements

The Federal Railroad Administration (FRA), in cooperation with the New York State Department of Transportation (NYSDOT) completed the Empire Corridor Environmental Impact Statement (EIS) in 2014 to “evaluate proposed system improvements to intercity passenger rail services along the 463-mile Empire Corridor, connecting Pennsylvania (Penn) Station in New York City with Niagara Falls Station in Niagara Falls, New York.”  The components of the EIS include the following:

Completing an EIS always takes a long time but the fact that the FRA anticipates publishing the final report in 2022, eight years after it was completed suggests that there were issues.  For this evaluation the point is that there were four alternatives considered to upgrade railroad service from New York City to Niagara Falls.  There were two alternatives to raise passenger train speeds to 90 mph between Albany and Buffalo and one to raise passenger train speeds to 110 mph that all use the existing right-of-way.  The fourth alternative would raise the passenger train speeds to 125 mph but that would require the development of a “new electrified (with overhead catenary), two-track, grade-separated high-speed rail corridor of 283 miles between Albany/Rensselaer Station and a new Buffalo station”.  The following table highlights the differences between the alternatives. 

According to Appendix G, Scenario 4 would get additional vehicle miles traveled reductions by using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS”.  As this document is the sum total of the documentation a certain degree of guessing is required to deduce what that means.  Although never mentioned it seems likely that Scenarios 2 and 3 use Alternative 110 from the Empire Corridor EIS to project reductions in vehicle miles traveled and using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” appears to provide incremental improvements.

It is possible to check the projected numbers.  Table 11 claims that “200 million light duty vehicle miles will be reduced relative to Scenarios 2 and 3 in 2050” at a per unit cost of $6 per mile.  Recall, however, that I previously interpreted this to mean that the 200 hundred million light duty vehicles miles reduced will cost $6 per mile or $1.2 billion.  The capital cost difference between Alternative 110 ($6.3 billion) and Alternative 125 ($14.7 billion) is $8.4 billion, far more than that per unit cost. 

There is another possible check.  Exhibit 6-7 in the Empire Corridor EIS estimates the annual reductions in auto trips in 2035 for the different alternatives.  Assuming that using the “125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” means that the proposed improvement is the difference between the 110 and 125 alternatives, then that means that 307,475 autos are diverted from highways. 

In order to estimate the vehicle miles traveled reduction from the estimate of 307,475 autos diverted from highways, the distribution of where the passenger boarded and exited is needed.  Exhibit 2-21 provides that information for 2009.  I have an issue with these data.  In particular, while the total appears consistent with the numbers in the rest of the document it is worrisome that the origin and destination numbers match exactly.  I interpret this table to state that 320,155 people boarded trains in New York to go to Albany reading down the first column to New York City then across to the third column under the heading Albany.  For the people going from Albany to New York City read down the trip origins column to Albany and then over to the second column for New York City.  I believe it is highly unlikely that exact number of people going from Albany to New York City and vice-versa would be identical.  Furthermore, the fact that the station pairs in all instances are the same means that there is an issue with the numbers.  Because I don’t expect that there would be a big difference between the numbers and the total is consistent, I have ignored this issue.

Unfortunately, there is no similar breakdown of boardings for the alternatives.  Exhibit 6-6 does break down total ridership by alternative in 2035.

My spreadsheet Empire Corridor Data uses the information from these three tables and the distances between the stations listed along the Empire Corridor (Markets tab) to estimate the vehicle mile traveled reduction expected in 2035 if the 125-mph alternative is implemented rather than the 110-mph alternative.  I assume that the relative ridership between stations remains the same as that shown in Exhibit 2-21 and that the diversion from highways estimates are proportional to the passenger boardings.  The difference in auto trips diverted from highways between the 110-mph alternative (177,603) and the 125-mph alternative (485,078) is 307,475.  The number of diverted auto trips for each station is proportional to the station boardings per station in 2009 multiplied by 307,475 divided by the total number of boardings in 2009 (932,801).  The vehicle mile traveled reduction is the number of trips per station pair times the distance per station pair.  The sum of the distances for all these diverted trips is 64.7 million miles in 2035.  The Table 11 projected number of light-duty vehicle miles traveled is 200 million miles in 2050.  Even though the dates are different I think it is clear that the numbers, and therefore the methodology, are incompatible.

There are a couple of ways to interpret these discrepancies.  It could simply be that my interpretation of the Scoping Plan total costs and mileage reductions for this strategy are incorrect.  On the other hand, I think it is more likely due to a methodology difference.  Due to the lack of documentation, it is impossible to determine how the Integration Analysis estimated the costs and mileages.  I suspect, but cannot prove, that the Integration Analysis assumed some sort of a relationship between railroad passenger investments and vehicle mile reductions based on the results of the Empire Corridor EIS.  Unfortunately, the existence of a relationship does not mean that you can estimate benefits for anything other than the total costs of the alternative.  The cost difference between the 110-mph alternative and the 125-mph alternative is $6.3 billion and diverts 307,475 auto trips away from the roads to the trains.  It is not appropriate, for example, to assume that an investment of $3 billion would divert half as many trips but I think that something along those lines was done.

Conclusion

Without herculean effort by many people over a long period it is impossible to evaluate all the cost-benefit claims in the Draft Scoping Plan.  It is not only that there are many components to the New York energy system but the lack of documentation means that a large part of the analysis is trying to guess how the numbers were generated.  The only alternative is to evaluate a few discrete components and to see if the estimates are reasonable.

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

Every time I have dug into the numbers, for example residential heating retrofit electrification, the Draft Scoping Plans numbers are not a reasonable estimate compared to my work. I have consistently found that the Scoping Plan costs estimates are biased high and the benefits proposed are biased low.  I conclude that there is little reason to trust the cost estimates in the Draft Scoping Plan because of the issues I have found.

All indications at the March 3, 2022 Climate Action Council meeting were that the plan for public involvement will simply going through the motions.  For example, there is no provision for the kind of discrepancy documented here to be reconciled as a result of public comments.  This example is trivial and has no major bearing on Climate Act implementation.  The terrifying prospect is that the issues associated with reliability raised at last summer’s Reliability Planning Speaker Session could possibly be treated the same, that is to say ignored.  Those issues must be addressed or the result could lead to people freezing to death in the dark.

Climate Act Upstream Emissions

The Draft Scoping Plan that outlines the implementation strategy for New York’s Climate Leadership and Community Protection Act (Climate Act) has been released for public comment by the Climate Action Council. This article discusses the implications of the Climate Act requirement to consider upstream emissions from fossil fuels imported into New York.  I believe that only considering the impacts of fossil fuels and not the impacts of “clean” energy development is biased and hypocritical.

If you are more interested in a video that addresses the point of this article there is an option.  Ron Clutz at Science Matters provides a post with a link and excerpted transcript to a video prepared by Deutsche Welle News, the German international broadcaster.  He explains:

The theme is described by adding a bit to the title: The Price of Green Energy Will Destroy Us.  The message is not about the exorbitant expense so much as the destruction of the world’s environment in order to save it.  The imagery in the video is compelling.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”.  Once complete an updated Energy Plan will guide New York’s energy policy going forward.

The Draft Scoping Plan “Key Milestones and Implementation Steps To-Date” is on page 21 and states (my emphasis added):

This draft Scoping Plan and recommendations outline measures and other State actions to ensure attainment of the statewide GHG emission limits and net zero emission goal. The statewide GHG emission limit rulemaking is the first regulatory action to implement the Climate Act, the foundation for multiple components of the Climate Act, and critically important for successful implementation of the Climate Act. DEC promulgated 6 NYCRR Part 496 that established the two statewide GHG emission limits called for in the Climate Act: a limit for 2030 that is equal to 60% of 1990 GHG emission levels and a limit for 2050 that is equal to 15% of 1990 emission levels. Specifically, using a 20-year global warming potential (GWP) and including upstream emissions from fossil fuels imported into New York as required by the Climate Act, the statewide GHG emission limit for 2030 is 245.87 million metric tons (MMT) of carbon dioxide equivalent (CO2e), and the statewide GHG emission limits for 2050 is 61.47 MMT CO2e. DEC, in consultation with NYSERDA, continues to update the inventory of GHGs and will publish the annual statewide GHG emissions report that reflects these updates.

This article concentrates on the significance and utter hypocrisy of the implications of “including upstream emissions from fossil fuels imported into New York as required by the Climate Act” into the Climate Act implementation process. 

Zero Emissions

The Climate Act is hypocritical.  Throughout the Draft Scoping Plan electricity generated by wind and solar resources and the energy storage systems required to cover for the intermittency of those renewable resources is referred to as “zero” emissions.  Of course, there are no emissions when these resources generate electricity.  However, in the Climate Act accounting framework fossil fuel generation includes not only direct emissions but also any upstream GHG emissions attributable to the extraction, transmission, and use of fossil fuels or electricity imported into the State.  The development of wind, solar, and energy storage resources on the scale necessary for the Climate Act certainly have environmental and emissions impacts for extraction of the rare earth metals necessary for those technologies, the construction of the massive number of structures needed, and the disposal of the enormous quantities of wind turbine blades and solar panels at the end of their useful lives.  This article summarizes references to these issues that I have documented on my “Clean” Energy Environmental Issues page

Paul Driessen summarizes my concerns in the Real Climate Crisis where he argues that the ecological destruction and human death tolls of the green energy transition is worse than the purported impacts of climate change.  He states:

They would require mining on scales unprecedented in human history, much of it by slave and child laborers, and nearly all using fossil fuels – bringing massive habitat and wildlife losses, air and water pollution, and horrific human health and safety problems. But since most of the mining, ore processing and manufacturing will occur in other countries, far from the USA, politicians and promoters of climate crisis can say this “alternative energy” is “clean and green.”

Rare Earth Metals

The EIA special report, The Role of Critical Minerals in Clean Energy Transitions, is the most comprehensive global study to date on the central importance of minerals such as copper, lithium, nickel, cobalt and rare earth elements in a secure and rapid transformation of the global energy sector.   The report explains that:

The types of mineral resources used vary by technology. Lithium, nickel, cobalt, manganese and graphite are crucial to battery performance, longevity and energy density. Rare earth elements are essential for permanent magnets that are vital for wind turbines and EV motors. Electricity networks need a huge amount of copper and aluminum, with copper being a cornerstone for all electricity-related technologies.

The reason this is an issue is because the clean energy technologies require more of these materials.  The report notes that:

A typical electric car requires six times the mineral inputs of a conventional car, and an onshore wind plant requires nine times more mineral resources than a gas-fired power plant. Since 2010, the average amount of minerals needed for a new unit of power generation capacity has increased by 50% as the share of renewables has risen.

The following graphic shows the increases needed.

 

French journalist and documentary filmmaker Guillaume Pitron has been following the global trade in rare earth metals. Unfortunately, mining these materials come with heavy environmental and social costs. Mining generates massive amounts of polluted wastewater, which left untreated, poisons crops and makes people sick. Guillaume documents these issues in his 2018 book “Rare Metals War’. Recently his work was summarized in the article Toxic secrets behind your mobile phone:

Above all, our dependence on rare metals brings two very big problems. The first is that mining, refining and recycling them is immensely polluting, thereby giving the lie to the idea that our increasingly digital and electricity-powered life is greener than one reliant on fossil fuels.

Second, one country – China – has a near stranglehold on the production and supply of rare metals. The Beijing government is not just seeking to control the metals found in its lands but also to control the production of rare metals wherever they are found on the globe. It has used barely credible chicanery to position itself as the sole supplier. It’s as if Saudi Arabia, which holds the world’s largest oil reserves, took it upon itself to control the reserves of the 13 other main petroleum-exporting countries.

The fact is that the European Union and the United States have little leverage to prevent Russia from invading Ukraine because they rely on Russia for the fossil fuels necessary to keep the lights on, homes heated, and transportation systems operating.  It seems obvious to me that it is imprudent to set up an energy system that is entirely dependent upon another nation whose interests may not be in our best interests.

Mark Mills’ Mines, Minerals, and “Green” Energy: A Reality Check paper from the Manhattan Institute picks up on the same themes: 

This paper turns to a different reality: all energy-producing machinery must be fabricated from materials extracted from the earth. No energy system, in short, is actually “renewable,” since all machines require the continual mining and processing of millions of tons of primary materials and the disposal of hardware that inevitably wears out. Compared with hydrocarbons, green machines entail, on average, a 10-fold increase in the quantities of materials extracted and processed to produce the same amount of energy.

This means that any significant expansion of today’s modest level of green energy—currently less than 4% of the country’s total consumption (versus 56% from oil and gas)—will create an unprecedented increase in global mining for needed minerals, radically exacerbate existing environmental and labor challenges in emerging markets (where many mines are located), and dramatically increase U.S. imports and the vulnerability of America’s energy supply chain.

Renewable Waste Disposal

Because the quantity of materials needed for wind turbines and solar panels is so much larger and those machines have shorter life expectancies, the inevitable result will be a waste disposal problem.  Consider wind turbine waste disposal.  They are so big that they have to be cut up and because they were designed to handle strong winds they cannot be “crushed, recycled or repurposed”.   As a result, the sheer volume of material is an issue.

Robert Bradley describes a Harvard Business Review article, The Dark Side of Solar Power, that concludes that “given the current very high recycling costs, there’s a real danger that all used panels will go straight to landfills”.  Bradley excerpts some passages from the article:

      • Economic incentives are rapidly aligning to encourage customers to trade their existing panels for newer, cheaper, more efficient models. In an industry where circularity solutions such as recycling remain woefully inadequate, the sheer volume of discarded panels will soon pose a risk of existentially damaging proportions.
      • The International Renewable Energy Agency (IRENA)’s official projections assert that “large amounts of annual waste are anticipated by the early 2030s” and could total 78 million tonnes by the year 2050. That’s a staggering amount, undoubtedly. But with so many years to prepare, it describes a billion-dollar opportunity for recapture of valuable materials rather than a dire threat. The threat is hidden by the fact that IRENA’s predictions are premised upon customers keeping their panels in place for the entirety of their 30-year lifecycle. They do not account for the possibility of widespread early replacement.
      • The industry’s current circular capacity is woefully unprepared for the deluge of waste that is likely to come. The financial incentive to invest in recycling has never been very strong in solar. While panels contain small amounts of valuable materials such as silver, they are mostly made of glass, an extremely low-value material. The long lifespan of solar panels also serves to disincentivize innovation in this area.
      • The direct cost of recycling is only part of the end-of-life burden, however. Panels are delicate, bulky pieces of equipment usually installed on rooftops in the residential context. Specialized labor is required to detach and remove them, lest they shatter to smithereens before they make it onto the truck. In addition, some governments may classify solar panels as hazardous waste, due to the small amounts of heavy metals (cadmium, lead, etc.) they contain. This classification carries with it a string of expensive restrictions — hazardous waste can only be transported at designated times and via select routes, etc.
      • The same problem is looming for other renewable-energy technologies. For example, barring a major increase in processing capability, experts expect that more than 720,000 tons worth of gargantuan wind turbine blades will end up in U.S. landfills over the next 20 years. According to prevailing estimates, only five percent of electric-vehicle batteries are currently recycled – a lag that automakers are racing to rectify as sales figures for electric cars continue to rise as much as 40% year-on-year. The only essential difference between these green technologies and solar panels is that the latter doubles as a revenue-generating engine for the consumer. Two separate profit-seeking actors — panel producers and the end consumer — thus must be satisfied in order for adoption to occur at scale.

Conclusion

Andy West’s statement about another aspect of net-zero policies is equally applicable to the Climate Act mandate to consider upstream fossil fuel emissions while ignoring the impacts of “zero” emissions environmental impacts: “Ardent belief in cultural fairy-stories creates a pretty effective blindfold against glaring truths”.  The Climate Act’s war on fossil fuels is based entirely on the popular belief that climate change is an existential threat.  Authors of the law incorporated every opportunity to inflate the impact of fossil fuels and ignored any negative ramifications.  It is evident that there are significant issues associated with the materials necessary for the clean energy transition.  The Climate Act ignores them in a blatant example of hypocrisy.

NY Business Council Climate Act Scoping Plan Overview

The Draft Scoping Plan outlines the implementation strategy for New York’s Climate Leadership and Community Protection Act (Climate Act) has been released for public comment by the Climate Action Council. The NY Business Council recently published a summary of the Draft Scoping Plan that I think is an excellent overview of the Plan. 

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”.  Once complete an updated Energy Plan will guide New York’s energy policy going forward.

The NY Business Council is the “voice of business and employers in New York State Representing 3,500 business of all sizes, in all sectors Including nearly 100 local chambers and business groups”.  At a recent webinar Ken Pokalsky referenced a summary of the Draft Scoping Plan that he prepared.  I asked for permission to publicize his summary and this post is the result. 

The summary of thescoping plan points out that the document and supporting documents “amount to more than 1,000 pages and provide significant details on the Climate Action Council’s analysis and recommendations. It explains that “Some sections, i.e., transportation and buildings, provide specific recommendations and timelines for action” and that “Others, including sections on the electric power and natural gas sectors, and on industry, provide far less in the way of a detailed implementation plan.”

The distinction between the sections is an important point.  In order to be a credible basis for the Energy Plan’s roadmap for “providing clean, reliable, and lower-cost energy to all New Yorkers” the State has to prove that it is feasible.  While the transportation and building sector sections provide more detail it is barely sufficient for a feasibility analysis. There clearly isn’t anything approaching a feasibility analysis for the electric power and natural gas sectors.  I believe that this is partially due to the complexities of the electric and gas sectors.  Unfortunately, a main driver of policy is the political calculus to incorporate social and environmental justice concerns.  As a result, appeasing those interests is over-riding technological feasibility concerns.

Benefits and Costs

The following lists the benefits and costs presented with my indented and italicized comments.

  • The plan discusses the range of adverse impact caused by climate change and asserts that climate change will be affected by the actions proposed in the scoping plan.

Pokalsky recently gave a presentation at the Real Cost of New York’s Climate Leadership and Community Protection Act webinar.  My post on the webinar made the point that technical feasibility of wind, solar, and energy storage should be a primary concern but only one of six presenters raised that point because it is politically incorrect to argue the point.  Pointing out that the Intergovernmental Panel on Climate Change technical reports don’t agree with the range of adverse impacts listed in the Draft Scoping plan and that the state has never quantified the effect of any New York GHG emission reduction program on global warming itself is even more of a politically incorrect argument.

 In addition to reducing the impacts of climate change, it recognizes that the state will need to adapt to risks that cannot be avoid.

I agree.

 While the report provides few specifics on the cost of implementation measures, it reports on macro-level models of the cost and benefits of multiple compliance scenarios, each of which projects that benefits will significantly outweigh implementation costs, with benefits including public health benefits from improved air quality Improvements in air quality, increased active transportation, and “energy efficiency interventions” in homes generating health benefits ranging from approximately $165 billion to $170 billion. However, this analysis compares the costs of implementing this state specific scoping plan with benefits, including estimates of avoided economic damage from climate change at up to $250 billion, benefits that would require actions beyond those proposed in this scoping plan to achieve.

I have shown that the health benefits claimed exaggerate the projected values, that the estimates of avoided economic damages from climate changes are manipulated to be 5.4 times higher than other jurisdictions, and, despite all the biased calculations, the benefits are not greater than the macro-level cost estimates unless the benefits of reductions are counted multiple times.  If only that error is corrected the total benefits range from negative $74.5 to negative $49.5 billion instead of positive net benefits ranging from $90 billion to $120 billion.

 The scoping plan applies an analytic framework that projects approximately $140 billion in annual New York State energy system expenditures, including capital expenditures and fuel costs, representing 8.9 percent of gross state product. A significant share of that amount, including $30 billion of $50 billion in fuel costs, leaves the state. In part, the economic impact study discusses the effect of redistributing these annual expenditures to achieve the state’s renewable energy and energy efficiency objectives.

In the absence of detailed cost numbers, it is difficult to comment on the analytic framework for costs.  This is a good description of what is available.

 Public health benefits from reduced GHG emissions will include those related to heat, flooding and food, water, and vector-based diseases, and will result in indirect benefits from the reduction of emissions of GHG co-pollutants including particulates and various toxic emissions.

The heat, flooding, food, water and vector-based disease benefits are associated with the social cost of carbon calculations.  I have prepared a white paper on these alleged benefits for anyone who wants to get into the technical details.

  • The scoping plan focuses significantly on historic disparate impacts on disadvantaged communities. Throughout the document, the scoping plan references recommendations of the Climate Justice Work Group (CJWC) and the extent to which they were not adopted by the Climate Action Council.

This is an important point that I have not addressed in my work yet.

  • The plan asserts that it establishes “the country’s – and perhaps even the planent’s – strongest GHG emission reduction and clean energy requirements,” and it will serve as a model for other jurisdictions.

At the end of the day, I believe that this is the only benefit of the plan.  New York’s politicians will have bragging rights.  Of course, the owners of the Titanic had bragging rights on their maiden voyage too.

 The scoping plan will result in a cleaner environment and a more competitive economy, and will support new jobs, new businesses, and new economic opportunities. (The CAC also issued a report on projected job creation resulting from CLCPA implementation.) It contains several recommendations for retraining workers displaced by CLCPA mandates, and for offsetting any adverse economic consequences on communities impacted by the loss of facilities. It recognizes that CLCPA implementation will require an expanded, trained workforce, and supports measures such as project labor and community workforce agreements on CLCPA-related projects.

This is a primary concern for the Business Council.  I have not addressed this in my work yet and given the amount of material will more than likely defer to the Business Council’s opinion.

  • It recognizes the potential impact of emission leakage due to actions that increase the cost of energy, reduces the reliability of energy, or increase the cost of GHG emissions, and recommends some approaches, including credits for early action and targeted incentives.

This is another topic I have not addressed.  Based on my work with Regional Greenhouse Gas Initiative emissions leakage I am pretty sure that leakage is inevitable but that the numbers can be manipulated to make it look like less of an issue.

Conclusion

The Business Council memo is intended to provide an overview of the most significant energy-related proposals impacting major sectors of the New York State’s economy. It does an excellent job in that regard.  The memo points out that “Most businesses will be impacted by the recommendations of multiple sector-specific proposals”. The Business Council urges its members to review the scoping plan and get involved with their internal comment development process.  I recommend that all New Yorkers review the plan and comment too.

Air Permit Applications and the Climate Act

The implementation strategy for New York’s Climate Leadership and Community Protection Act (Climate Act) is being finalized by the Climate Action Council  in 2022.  Because the schedule is so ambitious the Council has been pushing for the implementation of policies even before the strategies are finalized.  This post addresses the New York State Department of Environmental Conservation (DEC) proposed policy DAR-21: The Climate Leadership and Community Protection Act and Air Permit Applications that is supposed to establish the procedures staff will use to review permit applications with respect to the Climate Act.  This turns out to be another example of the Climate Act putting the cart before the horse.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”.  Once that is complete the Energy Plan will be revised to set the state’s energy policies. The goal of the Energy Plan process is to “map the state’s energy future by showing how the state can ensure adequate supplies of power, reduce demand through new technologies and energy efficiency, preserve the environment, reduce dependence on imported gas and oil, stimulate economic growth, and preserve the individual welfare of New York citizens and energy users”.

The Proposed Policy DAR-21: The Climate Leadership and Community Protection Act and Air Permit Applications describes “the content of analyses required by the Division of Air Resources (DAR) pursuant to the requirements of Section 7(2) of the Climate Leadership and Community Protection Act (CLCPA). Chapter 106 of the Laws of 2019”. It further describes “the procedures staff in DAR will follow when reviewing those analyses for conformance with the requirements of the CLCPA”. Finally, this policy “establishes the types of air pollution control permit actions required to prepare an analysis as part of the permit application process”.

My Comments

I submitted comments on the proposed rule.  My main concern is that if DEC refuses to permit individual existing air permit applications without considering whether the facility is needed for reliability then problems could occur.  Importantly, DEC has no such responsibility so they should work with the New York Independent System Operator (NYISO) to cover this concern.

The policy document outlines the requirements for analyses developed “pursuant to Section 7(2) of the Climate Leadership and Community Protection Act (CLCPA) in support of air pollution control permit applications”. The document notes that the CLCPA went into effect January 1, 2020 (Chapter 106 of the Laws of 2019). It also notes that the CLCPA also establishes a Climate Action Council that is given three years (by January 1, 2023) to finalize a Scoping Plan providing recommendations for meeting those limits, and requires the DEC to promulgate regulations on GHG emission sources within four years (by January 1, 2024) that will ensure those limits are met. I commented that this policy is putting the cart before the horse. It is inappropriate to require analysis before regulations are promulgated simply because no standards have been established.

Ultimately the problem with the guidance document can be traced back to the CLCPA presumption that a transition to net-zero can be accomplished by 2050 if only there is political will. The reality is that there are enormous technological challenges particularly for the mandated schedule. As a result, there is a gaping hole in the Scoping Plan because it does not include a feasibility plan for the specific technology and schedule that the Climate Action Council proposes. It is not clear to me when and how the organizations responsible for electric system reliability will review and sign off on an implementation plan. Until that happens it is inappropriate for DEC to put any limitations on fossil-fired generation.

My comments argued that it is obvious that there are serious limitations with existing technology and the aggressive schedule. The New York Independent System Operator (NYISO) 2021-2030 Comprehensive Reliability Plan is the most recent reliability study in New York. It states:

Moving to 2040, the CLCPA requires generation to be emission-free. The Climate Change Study looked at 100 x 40 (emission-free electric grid by 2040). It noted the significant amount of dispatchable resources that would be needed to meet that goal but did not describe the technology that would be able to provide a dispatchable resource, instead choosing to refer to generic dispatchable, emission-free resources. Not surprisingly, the Climate Change report found that a similar amount of dispatchable resources as the RNA case would be needed to maintain reliability under baseline assumptions. However, under CLCPA assumptions, the amount of dispatchable emission-free resources needed increases to over 32,000 MW in 2040, approximately 6,000 MW more than the total fossil-fueled generation fleet on the grid in 2021. The Climate Change Study noted that the current system is heavily dependent on existing fossil-fueled resources to maintain reliability and eliminating these resources from the mix “will require an unprecedented level of investment in new and replacement infrastructure, and/or the emergence of a zero-carbon fuel source for thermal generating resources” (emphasis added). The Climate Change Study did note that while the amount of installed capacity (MW) of dispatchable resources is significant, the amount of energy generated (MWh) required from such resources would likely not be significant, with the percent of total energy being in the range of 10% ― 20% range depending on the penetration level of intermittent resources.

This guidance and the Draft Scoping Plan don’t consider one component of the CLCPA. The Public Service Commission mandate in Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) that states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

Given that the Energy Plan has to consider the provision for safe and adequate electric service, and it will not be prepared until 2023, it is premature for DEC to pick any winning or losing technologies in this guidance or any other permitting decisions for that matter. I recommended that the effective data be made contingent upon the completion of an Energy Plan that meets PBS Chapter 48, Article 4, § 66-p. Establishment of a renewable energy program requirement for safe and adequate electric service. Because reducing emissions is so dependent upon electrification the electric service criterion is a good surrogate for all permitting activities covered by the guidance.

There is another aspect of NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report that the guidance should consider.  My comments highlighted some risk factors that threaten electric system reliability in the report.  The CRP states:

As generators age and experience more frequent and longer duration outages, the costs to maintain the assets increase. These costs may drive aging generation into retirement. A growing amount of New York’s gas-turbine and fossil fuel-fired steam-turbine capacity is reaching an age at which, nationally, a vast majority of similar capacity has been deactivated. As shown in Figure 11, by 2028 more than 8,300 MW of gas-turbine and steam-turbine based capacity in New York will reach an age beyond which 95% of these types of generators have deactivated. 

The impact of the unavailability of system resources can readily be seen through tipping point evaluations. While transmission security within New York City (Zone J) is maintained through the ten-year period in accordance with design criteria, the margin would be very tight starting in 2025 and would be deficient beginning in 2028 if forced outages are experienced at the historical rate, as shown in Figure 12. Transmission security within Long Island (Zone K) is also maintained through the ten-year period, with the slimmest margin in the first few years as shown in Figure 13. If forced outages are experienced at the historical rate the Long Island margin would be sufficient through the study period.

My comments pointed out that using history as a guide, there will be forced outages from these old generating resources.  Obviously not renewing permits will exacerbate this problem.

Replacement Permit Applications

Obliviously, DEC has rejected permits for new replacement generating facilities that addresses this risk factor.  This was outside the scope of the guidance document but is important for readers to understand. In the DEC’s “Notice of Denial of Title V Air Permit” for the Danskammer Energy Center (DEC ID: 3-3346-00011/00017) and its “Notice of Denial of Title V Air Permit” for the Astoria Gas Turbine Power Project (DEC ID: 2-6301-00191/00014), the DEC rejected the use of both hydrogen and renewable natural gas (RNG) as a 2040 compliance mechanism because the DEC labeled them “speculative” and “aspirational”. However, the Scoping Plan’s placeholder for a dispatchable, emission-free resource is hydrogen. Governor Hochul’s recent State of the State address proposes that New York position itself to compete for nearly $10 billion in federal funding for green hydrogen R&D under the federal infrastructure bill. Obviously, it is in the state’s best interest to preserve the option to use hydrogen in the future. In the meantime, the options to supplant the dispatchable energy from those facilities with energy storage and renewable energy alternatives are no less “speculative” and “aspirational”.   In my comments I argued that the proposed guidance must incorporate a process similar to that used for the Peaker Rule (6NYCRR Part 227-3) whereby the NYISO works with DEC to ensure reliability issues are addressed for any permit application affecting electric generation viability.

Conclusion

The zeal of the State of New York to implement the Climate Act before the plan is complete is endangering the security of the electric grid.  In particular, there are many generating units in the state and New York City in particular that are nearing the end of their useful life. I submitted comments arguing that the DAR-21 Guidance must be revised to incorporate electric system reliability considerations.  Firstly, as shown above there are reliability concerns related to existing electrical generators.  The guidance must not preclude continued operation of existing units.  Secondly, DEC should not prevent operators from developing modern generating units that are more reliable than the existing aging units.  Even if the state plans to shut down all fossil-fired units by 2040 the owners know that and it can be addressed with a permit condition.  Finally, the Energy Plan has to consider the provision for safe and adequate electric service at the same time that the Draft Scoping Plan is proposing the use of currently unavailable technology.  For all three reasons it is premature for any DEC application to limit, shut down or prevent upgrades at existing electrical generation facilities.

The Real Cost of the Climate Act

On February 16, 2022 New Yorkers for Affordable Energy hosted a Zoom webinar titled The Real Cost of New York’s Climate Leadership and Community Protection Act.  The sponsor said to “feel free to share this with anyone you think would enjoy it” so this post describes the webinar.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it “continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023”.

The The Real Cost of New York’s Climate Leadership and Community Protection Act webinar was organized by New Yorkers for Affordable Energy, “a coalition of community, labor, business and industry leaders from across the state who support greater access to clean, reliable and affordable sources of energy for residential and business consumers.”  They understand that reliability and affordability are at risk due to the Climate Act and are starting to get the word out to consumers who have no idea what is involved with the state’s plan to do “something” about climate change. There is a recording of the Zoom meeting but this article will focus on presentations made by six speakers.

New Yorkers for Affordable Energy

Michelle Hook, the Executive Director of New Yorkers for Affordable Energy (NYAE) gave the first presentation.  The mission for NYAE is “to educate New Yorkers about the impacts of New York energy policy on their personal livelihood and advocate for a pragmatic and balanced approach to our state’s energy decisions”.  She explained that there are active bills that could have major impacts:

  • S.8008/A.9008 Budget Bill TED, Part EEE and S.6841 (Kavanaugh) A.8431 (Gallagher) – “All Electric Buildings Act”
    • Both bills prohibit any new construction that is not all electric.
  • S.8198 (Krueger) – Statewide Natural Gas Transition Plan
    • Requires the PSC to develop a statewide gas transition plan that decreases gas sales and decommissions natural gas systems
  • S.5939-A (Ramos)/A.6761-A (Mamdani) – “Clean Futures Act”
    • Prohibits the development of any new major electric generating facilities that would be powered in whole or part by any fossil fuels.

She also brought up the issue of aging power plants and the potential impact to reliability.

New York Independent Power Producers

Gavin Donohue, the President and CEO of the New York Independent Power Producers is also a member of the Climate Action Council.  He explained that of the 22 members of the Council only two appointees are from the traditional energy sector, him and Donna DeCarolis of National Fuel Gas Distribution Company His presentation outlined the requirements of the Climate Act.  I will reproduce much of his material and, in the rest of the article, highlight differences between his take and the other presentations.

He listed the following recommendations from the Draft Scoping Plan:

  • Moratoriums on new gas infrastructure (NOT a Council-wide recommendation)
  •  No new natural gas service to existing buildings
  •  Prohibit propane, natural gas and oil equipment in new homes in 2024
  •  Prohibit traditional heating systems in existing homes in 2030
  •  Ban use of natural gas appliances (dryers, stoves, etc.) in homes in 2030
  •  No gasoline vehicles sold in New York in 2035

Donohue described the following gaps and challenges:

  • Gas and oil resources currently make up more than two-thirds of the energy downstate and one-third statewide overall
  • New York’s grid operator (NYISO) says quick-start power options are essential
  •  State power reserves are thin (no wiggle room for very hot/cold days or broken units)
    • NYSERDA says electrification and electric vehicles increases electric demand 65 to 80%
  • No consensus on what qualifies as Zero-Emission Dispatchable Technologies for 2030 and beyond
  • Increased electrification results in electric consumption doubling by 2050
    • Approximately 1 to 2 million homes will need to be electrified with heat pumps by 2030
  • Approximately 3 million zero-emission vehicles will need to be sold by 2030
  • Necessary to create emission-reducing or eliminating technologies like carbon capture, hydrogen fuel cells, offshore wind and battery storage
  • Redefining/retraining state labor force
  • Diversion of organic waste from landfills
  • Management of manure and animal feeding practices

Donohue presented a list of Draft Scoping Plan positives:

  • No recommendation to ban wood burning
  • Acknowledges need for nuclear facilities through 2029
  • Low-carbon fuels such as bioenergy or green hydrogen have a role
  • Investments in development of zero emitting resources
  • Includes carbon pricing as an option

Then he followed up with what he thought was the biggest issue: How much will this cost?

  • No comprehensive cost analysis on how to pay for any of the recommendations:
    • Geothermal/heat pumps
    • Electric vehicles
    • Home appliances
    • Grid electrification
    • Expansion transmission, renewables and energy storage

I agree with most of the points raised by Donohue and all the gaps and challenges points raised.  I suppose it is unreasonable to expect that a member of the Climate Action Council could question the value of the law itself.  However, New York’s share of global GHG emissions is less than a half a percent of total emissions and, on average, over the last three decades the annual increase in GHG emissions is more than half a percent, so any reductions made in New York will be replaced by global emission increases in a year. As a result, I think that any presentation on the Climate Act should ask the question “What is the point”.   I agree that costs are the biggest issue. I would add that the Draft Scoping Plan does not document any of the costs provided so not only isn’t there an analysis on how to pay, but there isn’t satisfactory documentation supporting what it might cost.

National Fuel Gas

National Fuel Gas is a “diversified, integrated energy company with a complementary mix of natural gas assets located in the heart of the prolific Appalachian basin” that serves customers in western New York Donna DeCarolis is President and also a member of the Climate Action Council. Her presentation emphasized the need to balance the goals and objectives of the Climate Act with consumer impacts. 

Her list of items in the Draft Scoping Plan is the same as Donohue’s. 

The presentation by DeCarolis includes the following slide pointing out all the items that are not included in the natural gas system transition.  Clearly National Fuel Gas is in a fight for its existence so their plan is to support the New York narrative that a transition to low and no-carbon is necessary.  From what I have seen there isn’t enough renewable natural gas to make much of a difference and problems with metal embrittlement with hydrogen will prevent the use of the existing natural gas system for its use.

Her list of what is missing in the Draft Scoping Plan includes the following:

  • Existing “electric-based clean energy technologies” can’t meet forecasted demand & maintain reliability
  • Unprecedented level of NEW renewable energy generation development in next 8 years.
    • 26% current   
    • 70% required
  • NYISO published its concern about declining levels of reliability beginning as early as 2023
  • Measures will likely increase consumer cost for potentially less reliability
  • Full assessment of affordability
  • Recognition of upstate and downstate differences
    • Plan will be more burdensome for western New York residents
      • Weather is 56% colder
      • 94% of energy used on the coldest WNY winter day is natural gas
      • Older, larger Upstate housing stock
      • Burden falls hardest on Upstate residents – Downstate produces more emissions

National Fuel Gas proposes an “all-of-the-above” pathway based on three building blocks:

  • Widespread energy efficiency that emphasizes weatherization
  • Dual-energy heating and cooling systems
  • Use of the existing natural gas infrastructure to incorporate low carbon fuels

The presentation expands on these points and DeCarolis argued that it is possible to meet the goals of the Climate Act.  Given that anyone who “questions” the value of reducing GHG emissions will be labeled a “denier”, National Fuel Gas has decided not to argue much about the futility of the Climate Act having an effect on global warming so they are presenting their plan as a more viable option to get the same result.

Empire Center

The Empire Center for Public Policy is an independent, non-partisan, non-profit think tank based in Albany, New York.  Their mission is “to make New York a better place to live and work by promoting public policy reforms grounded in free-market principles, personal responsibility, and the ideals of effective and accountable government.”  

Senior Policy Analyst James E. Hanley gave a presentation that did not have pull its punches because of vested interests within the organization.  He argued that utility customers expect electricity when and where needed at all times.   However, the drive for electrification will increase electricity demand by 65% to 80% at the same time New York policy is shutting traditional sources of electricity.  As a result, adequacy margins are already shrinking.  Donohue’s presentation claimed that electricity demand would double and I believe he is correct.

Hanley pointed out that the Climate Act forces an unprecedented shift to variable renewable resources.  The Draft Scoping Plan projects that in addition to a massive buildout of wind and solar that dispatchable emissions-free resources are needed for reliability.  He explains that the Plan suggests advanced fuels such as green hydrogen and renewable natural gas might fill the reliability gap: ”if scalability, feasibility, and environmental impact and air quality issues can be addressed.”  The biggest problem is that it is not known if any advanced technology will be deployable at scale and how much it will cost by 2040 when fossil fuels are banned from the New York grid.  He also argues that energy storage on the necessary scale is “science fiction”.  He concludes that “nuclear closures, non-permitting of new sources, and aging and closure of existing fossil-fuel sources could mean NY inadvertently “sleepwalks” into an era of energy unreliability”.  These points all imply that the Climate Act targets and schedule are not likely to be achieved so Council members Donohue and DeCarolis steered clear of these arguments.  I personally think that Hanley’s feasibility assessment is optimistic.

New York Business Council

Ken Pokalsky, Vice President of the NY Business Council, also gave a presentation.  The Business Council is the “voice of business and employers in New York State Representing 3,500 business of all sizes, in all sectors Including nearly 100 local chambers and business groups”.  He referenced a summary of the Draft Scoping Plan that he prepared and made the point that feedback during the public comment process is essential. 

Pokalsky described how the Draft Scoping Plan handles the industrial, transportation, buildings, and waste management sectors.  He described key considerations for business:

  • Most businesses will feel multiple impacts
  • Limited focus on direct costs, opportunity costs, return on investments
    • Risk for emission and economic leakage is real
  • The legislature wants to act now!
    • S.4264-A (Parker)/A.6967 (Cahill) – “Climate and Community Protection Act”
    • S 6843-A  (Kavanagh)/A.8431 (Gallagher) – Electric building mandate
    • S.8198 (Krueger) – Mandated restructuring of electric and gas utilities
    • Others and more to come . . .
  • You need to be engaged!!

For the most part his arguments were consistent with Donohue.

United Association

John Murphy is the International Representative for New York State, United Association Plumbers & Pipefitters and was a member of the Environmental Justice and Just Transition Working Group. (I am not sure if this was one of the Climate Act working groups.) His presentation argued that the costs of the Climate Act will be astronomical if not done right. 

Murphy argued that high utility bills, escalating consumer prices and massive job losses are likely and that the poor and energy workers will be hit the hardest.  As an example, he pointed out the Department of Environmental Conservation’s permit denials for a couple of natural gas generating plants will eliminate over 1,000 jobs and two sources of clean and reliable power.  This is just the tip of the iceberg because the Climate Act will phase out 66 natural gas plants and 3 nuclear plants which will “eliminate tens of thousand of good middle-class jobs”.  He argued that an all-of-the-above approach is the sensible solution.  He concluded that “following the narrow path of renewables only will drive high costs, result in widespread outages & massive job losses”, but that the all-of-the-above strategy can ensure adequate and reliable power, generate tens of thousands of good jobs and provide a big part of carbon-free power.

The Draft Scoping Plan argues that Climate Act implementation will create job growth and some unions have bought into that argument.  Murphy’s presentation points out that there will be significant job losses too.  However, he also supports the idea that we have to act using a strategy that includes nuclear and natural gas.  I agree that if you want to keep the lights on that is absolutely necessary.

Conclusion

The webinar offered good summaries of issues and alternative solutions for New York’s energy future.  It is notable that the vested interests and corporate business plans of most of the organizations represented influence their recommendations for the Climate Act.  Only Hanley from the Empire Center emphasized the point that technical feasibility of wind, solar, and energy storage should be a primary concern.  The Business Council did not address feasibility.  The IPPNY, National Fuel Gas, and United Association presentations all suggested that renewable energy issues could be addressed by an all-of-the-above strategy. I think the risks and costs of an electric system that relies mostly on wind, solar, and energy storage out-weigh the benefits of this unprecedented transition.

One of the major themes of the webinar was that New Yorkers must get educated and involved if they want to have an affordable and reliable energy system in the future.  In my opinion that boils down to preventing passage of the proposed legislation described in the presentations.  I encourage all New York residents to contact your legislators and tell them that you are not willing to give up natural gas.

Nuclear New York Comments on Proposed Tier 4 Contracts of NYSERDA

Last December I posted an article that compared residential cost impacts of the recently announced New York State Energy Research and Development Authority (NYSERDA) contracts with Clean Path New York LLC for its Clean Path NY (CPNY) project and H.Q. Energy Services (U.S.) Inc. (HQUS) for its Champlain Hudson Power Express (CHPE) with the energy needed as part of the Scoping Plan.  I was recently contacted by Dietmar Detering from Nuclear New York who called my attention to the comments that they submitted to the Department of Public Service on those contracts.  This post reproduces their comments and describes their context relative to the Climate Leadership and Community Protection Act (Climate Act). I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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.

Background

The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The NYSERDA contracts described here are one component of Climate Act implementation.

Tier 4

I described this effort in a previous post.  According to the NYSERDA Tier 4 webpage:

The Public Service Commission’s October 15, 2020 Order [PDF]establishes a new Tier 4 within the Clean Energy Standard (CES) in response to NYSERDA’s CES White Paper. The new Tier 4 will increase the penetration of renewable energy into New York City (NYISO Zone J), which is particularly dependent on polluting fossil fuel-fired generation. NYSERDA’s CES White Paper found that without displacing a substantial portion of the fossil fuel-fired generation that New York City currently relies upon, the statewide 70 by 30 Target would be difficult to achieve. Through Tier 4, the State will procure the unbundled environmental attributes (in the form of Tier 4 RECs) associated with renewable generation delivered into Zone J. These environmental attributes include the avoidance of GHG emissions, as well as the avoidance of local pollutants such as NOx, SOx, and fine particulate matter.

On November 30, 2021 New York Governor Kathy Hochul announced that finalized contracts for two projects to meet this solicitation had been awarded.  In order to complete this process NYSERDA and the Department of Public Service (DPS) submitted “a petition for approval this Petition and two contracts for renewable energy credits (RECs) entered into under Tier 4 of the Clean Energy Standard (CES)”.  These documents are available on the DPS website for this matter.  For the reader’s information and because trying to access the DPS website is a challenge I have posted the petition, press release, cost analysis, and the contracts on this website.  According to the petition:

Tier 4 was established by the Public Service Commission (Commission) in October 2020 to overcome the challenge of New York City’s reliance on fossil fuels and to help accelerate achievement of New York’s target of 70% renewable energy by 2030. To this end, the Commission instructed NYSERDA to proceed with a Tier 4 solicitation that will increase the penetration of renewable energy into New York City (Zone J). NYSERDA issued its solicitation in January 2021 and received a highly competitive response with seven projects submitting proposals.

Following a robust and comprehensive evaluation process, which considered bid prices, viability and economic benefits, in September of 2021, the selection of two projects was announced: (1) the Clean Path New York (CPNY) project; and (2) the Champlain Hudson Power Express (CHPE) project. Contract negotiations have now concluded, and in accordance with the Commission’s instructions, NYSERDA and Staff are submitting the signed contracts for the Commission’s consideration and approval. The selected projects are expected to deliver 18 million megawatt-hours of renewable energy per year to Zone J, more than a third of New York City’s annual electric consumption, from a diverse generation portfolio including onshore wind, solar and hydroelectric power from Upstate New York and Québec.

The bid evaluation document describes the two projects.  The CPNY proposal has three main components:

    • New Tier 4 renewable generation to be built in New York (CPNY Resources), located largely upstate,
    • A new 1,300 MW HVDC controllable link from upstate to New York City, and
    • The use of the New York Power Authority owned Blenheim Gilboa pump storage facility to store energy produced by the CPNY resources that is generated in excess of the Tier 4 transmission capacity.

The CHPE project is an underground transmission line from Quebec to New York City that will deliver 1,250 MW of hydro generation from Hydro Quebec.  Both projects terminate in New York City so that it can be considered “in-city” generation.

Nuclear New York Comments

Last November the DPS submitted “a petition for approval this Petition and two contracts for renewable energy credits” and asked for public input.  Nuclear New York submitted a comment on 2/14/22.  They were “formed in response to the travesty of shutting down Indian Point” and support long-term investments in zero-emission infrastructure.  The comments note that: “Most importantly, the contracts will provide system benefits and emission avoidance for much longer than the thirteen years used to calculate them (2028–2040), an aspect overlooked by some commenters.”  I reproduce the following nine points made in their comment letter below with my italicized and indented comments.

  1. CPNY gets to use NY Power Authority’s Blenheim-Gilboa pumped storage facility presumably free of charge. The estimated dollar price of this unique facility would be about $2 billion should New York build it today. In reality, Blenheim-Gilboa is priceless: New York will most likely be unable to build another like it. Yet, there is barely any mention of this gift by the people of New York in the Tier 4 Bid Evaluation, making the comparison with CHPE, which gets no such gift, unfair. Without Blenheim-Gilboa, CPNY’s intermittent generation would be much less valuable to NYC and the proposed transmission line much too undersized. The connection would either sit idle when variable renewables are not generating or simply transmit electricity from fossil combustion to NYC most of the time.

In my Tier 4 article I pointed out that the CPNY capacity factor for the new Tier 4 renewable generation is so high because the project plan uses the Blenheim Gilboa pump storage facility.  However, Blenheim Gilboa was built in 1973.  It has been in daily use storing energy when prices are low and producing energy when prices are high.  It does not represent anything new even if the plan is to use it differently.  As pointed out in the Nuclear New York comments this is just a shell game. 

 2. The annual bid quantity for CHPE is higher than that of CPNY, which is also reflected in the higher costs and system value of CHPE over CPNY. However, NYSERDA expects cumulative carbon abatements of 49 million metric tons by CPNY but only 37 million metric tons by CHPE over the 13 years under evaluation. Per kWh, this translates to 479 grams of carbon avoided by CPNY, and only 274 grams per kWh avoided by CHPE. It is slightly worse in NYSERDA’s Benefit Cost tables: $50 per MWh in Carbon Value delivered by CPNY, but only $27 for CHPE. Even more extreme is the valuation for air quality improvements, where CPNY scores $27 per MWh vs. CHPE’s disappointing $12. If there is a clear explanation for this somewhere, we haven’t seen it.

The proposal treats CPNY as an entirely new sources of carbon abatement but that is not the case.

 3. If anything, the Carbon Benefits that NYSERDA calculated for CPNY should be lower than those of CHPE given that most of CPNY’s wind and solar projects are already planned and, so far, tallied as so-called Tier 1 Renewable Energy Credit (REC) projects. Little is being won with CPNY since it is difficult to add additional Tier 1 projects upstate due to the ever growing number of transmission-constrained “pockets”. These pockets can host the same projects either for Tier 1 or Tier 4, but to benefit from both credit schemes requires additional transmission investments, ignored in NYSERDA’s Bid Evaluation analysis.

Nuclear New York makes the point that it is even worse than I claimed because the State already took credit for the Tier 1 renewable energy projects.

  1. NYSERDA and the PSC need to examine how extreme weather may impact New York’s expected energy imports. In the payment formula, both projects get the promised Strike Price “minus the simple (not load-weighted) average of Zone J’s marginal price” for each MWh delivered during that month. This is treating both CPNY and CHPE like baseload power sources but without actually getting baseload service. Quebec and NYC often experience the same weather. Consequently, CHPE will deliver electricity during low or moderate demand periods. But Hydro Quebec will keep all power at home during grim winter weeks, such as on January 22 of this year: Exports to ISO-NE (the New England grid) were reduced to the contracted minimum, and, instead of exporting power to New York, Quebec needed to import power from New York. On really cold days in the Northeast, NYC will get no power via CHPE and will again rely on fossil-fueled “peaker plants”. Yes, CHPE and CPNY will get paid little for their electricity in the wholesale market if they fail to serve NYC in times of most desperate need. However, New Yorkers are still going to pay plenty for the RECs generated during “nice weather” hours.

This is a very important point.  The Climate Action Council is supposed to develop the Scoping Plan that will direct the future Energy Plan.  Reliability is a crucial requirement for the Energy Plan but I have not seen any indication in the Draft Scoping Plan or during deliberations of the Council that they understand the primary problem with providing electricity when it is needed most is during peak load periods.  The future New York electric grid is going to peak in the winter and the really cold days issue is a big problem.  If Hydro Quebec “keeps all power at home during grim winter weeks” this resource will be worthless when needed most.

 5. While CPNY cannot make any enforceable guarantees as to when they are able to deliver their weather-dependent power, CHPE could. However, the only assurances that the CHPE contract provides is a vague Minimum Delivery Requirement, calculated over the six months of “Winter” or “Summer”. This incentive structure does nothing to guarantee New Yorkers access to hydropower at times when it is needed most to balance intermittent wind- and solar-based generation and to protect against deadly power shortages, such as seen during the Texas Freeze of 2021. Therefore, neither project will help displace the need for fossil-fuel-based backup power plants.

I have long believed that one of the hidden problems with the Climate Act transition to zero emissions by 2040 is that market mechanisms have to be developed that will provide the services needed when needed.  This example supports my concern that serious problems are inevitable.

 6. Both contracts sound strong in Sections 4.03/4.04: NYSERDA is going to pay nothing for RECs created during hours in which the marginal price of electricity in NYC is zero or negative. However, this provision expires after the first 200 such hours in a year – a mere 2.3% of the time. However, over the lifespan of the contracts, NYSERDA is planning to connect not 9,000 MW, but possibly 19,000 MW of offshore wind power to NYC and Long Island. Often, these facilities will produce no electricity at all, but when the wind blows NYSERDA is obligated to accept all the generated power or pay for curtailment. Given federal production tax credits, this will force NYC wholesale electricity prices into negative values, perhaps for thousands of hours every year. The contracts’ pricing formula, however, forces NYSERDA to compensate CHPE and CPNY for these depressed prices, irrespective of whether NYC needs their output or not.

The Nuclear New York comments provide another example where the contract language is not going to be in the best interests of New York ratepayers.  In this instance it appears that costs will be higher than would be expected in an ideal system.  I am confident that the Draft Scoping Plan Integration Analysis does not include curtailment costs as part of the total costs of implementing the Climate Act.

  1. NYSERDA and others expect New York’s peak electricity load to move to Winter as heat pumps replace gas boilers for space heating. Thus, capacity market prices will be much higher in Winter than in Summer. The REC pricing formula for both contracts subtract the capacity value of each project from the respective strike price. However, for the CHPE contract, this adjustment only happens in the six months of “Summer”. For the “Winter Capability Period”, this adjustment is set to zero and New Yorkers are “paying” CHPE, via the unadjusted strike price, for capacity that CHPE is not guaranteeing. Adding insult to injury, all the careful clauses of the contract, for “Loss Factor”, “Unavailability Factor”, and “Mitigation Factor” are being multiplied by the same “zero capacity” factor in Winter, when they should matter most.

One of the problems with Climate Act implementation is that there is no master plan.  We know peak load planning is important and we know that the winter peak will be the future issue. Is it in the best interests of New York to support a solar project on the Tug Hill downwind of Lake Ontario where 300” of snow per year are common when we know we cannot rely on energy from there when it is needed most?  This example in the comments reveals an astounding disconnect between future needs and the contracted resources from CHPE. 

 8. NYSERDA calculates the “Carbon Benefit” using the globally-suffered Social Costs of Carbon as calculated by the New York State Department of Environmental Conservation. However, this value has been calculated using a 2% discount rate, whereas everything else in NYSERDA’s Bid Evaluation is using a discount rate of 3.68%. NYSERDA is mixing apples and oranges, and no one seems bothered. In partial acknowledgement, NYSERDA is offering a “low carbon value scenario”, employing a social cost of carbon calculated at a 3% discount rate. But this is still a HIGH carbon value scenario in the context of this analysis. The only Carbon Benefit we should be looking at would be one based on the same discount rate used elsewhere in the analysis, 3.68%, yet NYSERDA denies us this clarity.

I have previously shown that NYSERDA’s carbon benefit calculations are biased, incorrect, and inconsistent with other jurisdictions.  These comments show that they are also inconsistent with other state policies.  There is no question in my mind that NYSERDA knows full well that they are running a con game with this metric in a desperate attempt to claim the transition benefits will out-weigh the costs.

  1. Sadly, the benefits of both projects combined already show a diminishing rate of return. With relatively cheap Quebecoise hydropower tapped out, and priceless Blenheim-Gilboa pumped hydro power given away for free, how is NYSERDA planning to sell New Yorkers on the next Tier 4 projects, which will be more expensive and offer smaller benefits?

This is an excellent point.  The comments correctly point out that the best chances for substantial renewable resources have been used.  Moreover, existing renewable resource developments are likely sited in the best locations so any future developments will also be more expensive and have smaller benefits. 

Cost Estimates

My previous post on this topic looked at costs.  The petition includes the following cost estimates:

The costs of program payments for the purchase of Tier 4 RECs from the projects are projected as $5.9 – $11.6 billion, equating to an estimated increase in customer electric bills of 2.1 – 4.1% (or $2.08 – $4.08 per month for the average residential customer) on average across the State for the 25-year period of the Tier 4 contracts. The range of these projections reflects future uncertainties including energy and capacity prices and includes the benefits to ratepayers from the expected purchase of Tier 4 RECs by the City, which reduces the ratepayer impact by $0.8-$1.7 billion. Additional cost reductions could occur as a result of federal transmission tax credits, which could reduce the remaining costs of Tier 4 to ratepayers to 1.8 – 3.8%. Voluntary purchase of Tier 4 RECs by New York City organizations with interest in switching to renewable energy could reduce ratepayer impact even further.

Keep in mind that these comments point out that CHPE won’t necessarily provide power to NYC when needed the most in the winter, that the costs listed here do not incorporate curtailment costs, and that the CPNY does not represent a significant addition to renewable resources because it is mostly a re-packaging of the priceless Blenheim-Gilboa hydro pumped storage assets.  Throw in irregularities in the cost calculations and these comments should be considered in the petition process. 

Conclusion

Clearly the utter hypocrisy of claiming that there is an existential threat due to climate change but shutting down 2,000 MW of emissions-free dispatchable generating capacity is a major flaw in the Climate Act.  The Nuclear New York comments are completely consistent with my concerns about the viability of a New York zero-emissions electric system without using nuclear energy.  The comments point out numerous issues related to contracts associated with one of many future contracts necessary to implement the Climate Act.  This does not portend well for the transition.  The comments also reinforce my concern that the hurdles for the transition are not limited to technological constraints and costs.  If the market mechanisms and contracts don’t deliver what is needed, then New York ratepayers will be left holding the bag. 

Climate Act Draft Scoping Plan Comment on Residential Heating Electrification

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. This post describes comments on residential heating electrification retrofits that I submitted on 2/15/22.  I found that the documentation is insufficient and that the cost estimates are low.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023.

The Integration Analysis estimates that the buildings sector is the largest source of existing GHG emissions.  In all the future scenarios building emissions reductions are driven by “rapid electrification, increased energy efficiency, and improved building shells”.  For home heating electrification that means conversion to heat pumps and improvements to building shells to minimize the energy needed to heat homes.  Late last year I published an article that provided background for this sector.  It also included a table that was updated last month that used the Integration Analysis documentation that could estimate the costs to replace existing home heating systems with all electric systems.  More recently, I documented my fruitless search for the cost numbers presented as graphs in the Draft Scoping Plan.  My comment was based in large part on the material in those posts.

Summary of the Comments

The comment submittal is available along with the calculation spreadsheet.  In my opinion, home electrification is a primary concern for New Yorkers given the importance of affordability and the widespread impact to every household.  Accordingly, I spent a lot of time trying to replicate the costs to retrofit existing furnaces with heat pumps so that I could provide substantive comments explaining whether I thought they were doing it right.  Unfortunately, the documentation was not of sufficient quality to enable me to match their numbers.

One of the points of my comments is that this level of documentation is not acceptable. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan (my emphasis added).  The fact that the only description of net direct costs is a bar chart without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in the Draft Scoping Plan.

I also pointed out that there is a Public Service Commission mandate that needs to be considered.  Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

I maintain that the only way to ensure that there won’t be a significant increase in arrears or service disconnections is to provide fully documented cost numbers.

In addition to the comment document, I attached a spreadsheet that replicated relevant tables from the Integration Analysis spreadsheets, explained how I thought the cost to retrofit residences with heat pumps should be calculated and compared that to what was available.  The comments describe the missing documentation that is needed to replicate their projections.

My analysis found that a primary driver of home heating electrification is the building shell cost.  I argued that a more refined climatology of cold weather was appropriate.  The Draft Scoping Plan claims only 26% of residences need deep shell upgrades.  I estimate that more than half actually will need to have deep shell upgrades using a more refined climatology.  As far as I can tell from the graphs, I estimate that the entire building sector component cost is $230 billion relative to the reference case in the Draft Scoping Plan.  I calculated that just the residential retrofit heat electrification costs range between $259 billion and $370 billion using one methodology and between $295 billion and $370 billion using a different methodology.  The primary driver of costs is the number of residences that need deep building shell upgrades.   

In order to support my contention that there was insufficient documentation I documented my calculations to show where the documentation is inadequate.  While some aspects of the cost projections are documented in the Integration Analysis spreadsheets, there are critically important numbers missing.  Moreover, the calculation flow is not documented well enough to reproduce the cost projections.  It is unacceptable that the component costs shown in the figures of the Draft Scoping Plan are not provided.

The residential home heating retrofit component of building costs discussed in my comments are a good example of what should be provided for a publicly available evaluation.  The spreadsheets should provide all the data used in the calculations and describe the flow of data between table calculations should also be provided.

Other additional information is needed. I provided examples from my evaluation of the residential heating retrofit spreadsheet.  I suspect that the device costs vary over time but there is no documentation.  Any other values that change with time should also be documented. Building shell assumptions and values used are particularly important given their out-sized impact on the final costs.  What was the rationale for the values used?  Was there an uncertainty analysis of the effect of these assumptions?  How were the building shell assumptions used to estimate air and ground source heat pump distributions?  How were mobile homes addressed?  How many residences were deemed inappropriate for heat pumps?  What is the technology expected for those residences in the future?

Finally, I recommend that the Climate Action Council have a technical workshop that focuses on home electrification.  It is important that this workshop explain how the Integration Analysis calculated all the numbers presented.  An opportunity for stakeholders to provide questions beforehand to be addressed at the workshop would be appropriate as well as the chance for stakeholders to ask clarifying questions during the workshop itself.  The emphasis should be on the exchange of technical information without any opportunity for personal comments.  Throughout the implementation process to date, only one side of the transition challenge has been heard.  It is time to open up the discussion.

Conclusion

My comments on the Draft Scoping Plan addressed several issues related to the lack of documentation and provided suggestions for going forward.  The Climate Act requires the Climate Action Council to make evaluation of the total potential costs and potential economic and non-economic benefits “publicly available”. The fact that the only description of the net direct costs in the Draft Scoping Plan are bar charts without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in Plan.  I outlined what is needed to provide satisfactory information in the supporting spreadsheets and suggested that a technical workshop focused on electrification of residential heating given that impacts to most citizens.

My analysis highlighted the importance of building shell technology on heating electrification.  Because the documentation is so limited it is difficult to determine the assumptions used to project the requirements.  However, I believe that the Draft Scoping Plan underestimates the number of buildings that need deep shell upgrades.  That affects the cost projections significantly.