Pragmatic Environmentalist of New York

Recent presentations on the integration analysis strategies to meet the  Climate Leadership and Community Protection Act (Climate Act) targets are providing insight into the impacts on personal choice and costs necessary to meet the so-called “net-zero” goals.  There is a lot of information in the presentations and it takes effort to unpack what they are saying, why they are saying it and how they came to their recommendations.  This post looks at one aspect of the alleged benefits of the Climate Act and its implications for the public.

I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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

Implementation for the Climate Act implementation began soon after the law became effective in January 2020.  The law established the Climate Action Council whose charge was to develop a scoping plan to meet the targets.  The Council was supported by seven advisory panels who between late summer 2020 and spring 2021 developed strategies for the required emission reductions.  Over the summer they were turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan in October so that the scoping plan can be finalized by the Climate Action Council by the end of the year.  Next year the public and other stakeholders will get to comment on the scoping plan

In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented.  The analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with four scenarios that incorporate different emission reduction strategies.  The results presentation described specific recommended strategies and provided the first inkling of the costs and alleged benefits.  I am convinced that most New Yorkers have no idea what is included in the state’s plan to do “something” about climate change.  This article addresses the primary driver of the health benefits – inhalable particulates or PM_2.5.

Claimed Inhalable ParticulateHealth Benefits

The integration analysis included health co-benefits analysis to estimate and quantify health benefits of mitigation scenarios relative to a reference case.  They did a county level analysis using EPA’s CO Benefits Risk Assessment (COBRA) Health Impacts Screening and Mapping Tool customized with detailed inputs specific to NYS and the pathways scenarios analyzed.  The model projects ambient air quality based on SO₂, VOC, NO_X , and direct PM_2.5 emissions and the ensuing changes in annual PM_2.5 concentrations from 2020 to 2050.  The results include 12 different health outcomes, such as premature mortality, heart attacks, hospitalizations, asthma exacerbation and emergency room visits, and lost workdays.

I cannot over-emphasize the point that modeling inhalable particulates air quality is a challenge.  In addition to direct PM_2.5 emissions from a wide range of sources these particles also form as a byproduct of reactions in the atmosphere.  As a result, a large area that includes upwind sources has to be analyzed and that means transport becomes complicated.   As a result of these complexities and a lack of verification studies I am suspicious of the results.

The presentation on October 14, 2021 (meeting recording at 3:00:00) claimed that:

• • • Decarbonization of New York can result in a substantial health benefit from improved air quality, on the order of $50 –$120 billion from 2020 to 2050 (based on reduced mortality and other health outcomes).
    • Benefits would be experienced throughout the state and downwind of the state in
    • neighboring states.
    • Benefits of reduced fossil fuel combustion are higher in urban areas due to both higher emissions and larger impacted population.
    • Benefits of reduced wood combustion are higher in upstate areas
    • Annual benefits grow over time as pollution rates decrease.

The presentation also claimed that air quality improvements can avoid:

• • • Tens of thousands premature deaths
    • Thousands of non-fatal heart attacks
    • Thousands of other hospitalizations
    • Thousands of asthma-related emergency room visits
    • Hundreds of thousands lost workdays

The integration analysis modeling monetizes the air quality improvements over the period 2020 to 2050 to come up with the $50 –$120 billion claimed health benefits.  The components of the benefits are described in the following slide (meeting recording at 3:06:43).  It shows that the two largest sources of benefits are coming from “benefits of all other reduced combustion (downstate)” and “benefits of reduced wood combustion (upstate)”.  The integration analysis develops strategies to meet the targets but it does not specify how regulations will be written to implement them.  In order to realize those benefits upstate home heating with wood has to be replaced by electrification and energy efficiency effectively banning wood heating.  Policy options could include a wood burning prohibition mandate or they could assume that their electrification and energy efficiency solutions are so wonderful that everyone will willingly convert.  Authors could also believe that the efficiency of wood-burning furnaces could be improved so much that the impacts will be reduced.  In practice, however, getting any combustion source “tuned” to minimize emissions is an operator challenge and I think it is unlikely that owners will take the time and effort to master that skill.

New York Inhalable Particulate Trends

Over the past 30 years there has been a remarkable decline in SO₂, VOC, NO_X, and direct PM_2.5 emissions and the observed annual average inhalable particulate concentrations at seven locations across the state have declined in response as shown below.  Inhalable particulate monitoring started in the late 1990’s but since 2000 the annual averages have dropped between 30% and 60%.  These reductions are mostly due to decreased SO₂ and NO_X emissions caused by the Acid Rain Program and ozone reduction programs.

New York State PM_2.5 Trends

Inhalable Particulate Emissions and Benefits Projections

The integration analysis presentation (meeting recording at 3:08:26) includes the following slide that describes where the emissions are coming from that provide the alleged benefits.  The key point here is that the modeling projects that roughly three quarters of the expected inhalable particulate emissions in 2025 come from commercial and residential wood burning and industrial wood burning is another big chunk. According to Carl Mas “It is not that we are burning a lot of wood, it is that it is very dirty when it is burned”.

Not surprisingly, the projected health benefits by sector analysis comes to the conclusion that if there was no wood combustion there would be benefits.  This provides the benefit justification to offset the costs for the electrification, home energy efficiency, and wood stove energy efficiency strategies.

Inhalable Particulate Air Quality Projections

The integration analysis presentation (meeting recording at 3:17:42) presents the PM_2.5 air quality projections that drive the benefits analysis.  Carl Mas claims that we are getting “deep” reductions of inhalable particulates across the whole state but the highest annual average value is no greater than 0.35 µg/m³. That is a pretty small concentration that I suspect, but could not document, is near the precision of the monitoring system.

It is also informative to compare the predicted decrease in inhalable particulate concentration resulting from the Climate Act strategies to the observed decrease from 2000 to 2020.  As shown in the following figure where I inserted the observed decreases from the seven PM_2.5 ambient monitoring stations used before, all but one of the monitoring sites observed a PM_2.5 decrease a factor of ten greater than the largest predicted reduction.  On average, the observed reduction between 2000 and 2020 was fifteen times greater than the predicted future decrease.

Discussion

The EPA’s relationship between inhalable particulates and health benefits, as exemplified by the COBRA model, has been used as the primary benefit-cost rationale for many air quality regulations.  At this time New York state is in compliance with the inhalable particulate national ambient air quality standard which is the legally enforceable mechanism to protect human health.  These projections claim that there is no threshold for health impacts and that there is a linear relationship between health impacts and ambient concentrations.  For example, in September, 2011 US EPA Administrator Lisa Jackson testified to Congress that fine particles kill hundreds of thousands of people in America every year, a claim based on EPA epidemiology and extrapolated projections.  However, Enstrom tested the validity of this relationship and found no effect of fine particulates.  Nonetheless, these results have been used for years to justify regulations and legislation and from the basis of these Climate Act benefits.

In order to convince me that the relationship used to predict these benefits is correct I need to see verification of the health benefits with a reduction in inhalable particulate concentrations.  In order to  do the verification correctly, the EPA Environmental Benefits Mapping and Analysis Program should be used.  That model uses similar health outcome predictions to COBRA but uses observed air quality changes as its input.  The linear model used to project the health benefits should show proportional impacts to the integration analysis projections.  If that relationship is correct then there should be observable reductions (on the order of 15 times great than the integration analysis predictions) in all the health outcomes used.

Conclusion

I do not accept the linear no-threshold model for air pollution health analysis mostly because the National Ambient Air Quality Standards are based on a threshold approach.  Consider this example as an illustration of my cynicism.  No one questions the fact that prolonged exposure to wood smoke can cause health problems.  I have no doubt that there are health studies that have conclusively shown that at high pollution levels people have contracted cancer.  For the sake of argument, assume that the health studies have found that wood smoke at a continuous dose of 100 ppm for one year causes cancer.  The linear no-threshold model can extrapolate that dose response down to 0.00019 ppm per minute.  Using that extrapolation relationship, if 5,256 people sitting around campfires were exposed to the 100-ppm dose for one minute then linear no-threshold models claim one of them will get cancer from that dose.  Anyone who has sat around a campfire probably has been downwind of the smoke and received a dose of wood smoke.  It does not matter what the actual health impact dose response rate is, if you extrapolate that down to the dose of people sitting around a campfire and multiply that by all the people sitting around campfires the linear no-threshold model predicts an impact.

Comparison of the observed reductions of inhalable particulate ambient concentrations since 2000 and the projected decreases expected due to the climate act suggests that NYSERDA could validate their health impact benefit claims.  They claim benefits by preventing tens of thousands premature deaths, thousands of non-fatal heart attacks, thousands of other hospitalizations, thousands of asthma-related emergency room visits, and hundreds of thousands lost workdays.  Using their linear relationship and an order of magnitude larger observed reduction of inhalable particulates then the relationship should show up.  I find it hard to believe that the reduction in inhalable particulates has actually prevented millions of lost workdays.

Finally, note that the integration analysis only presents strategy recommendation.  At the end of 2022 the scoping plan will be finalized and the next year NY agencies will have to develop implementing regulations.  In this example, will they actually prohibit wood burning to ensure that the greenhouse gas emission targets and the projected health benefits are realized?  Maybe they will just assume that their electrification and home heating energy efficiency programs will be so popular that everyone will convert willingly. I don’t think that will work given that many of the people that I know who use wood for heating, get the fuel from their own woodlots.  Electric options have to be significantly more expensive for them.  Finally note that they might believe that wood stove energy efficiency programs will improve performance and reduce inhalable particulate emissions.  I don’t think that is a realistic hope because maintaining efficiency is too difficult for typical home owners.

I gave a presentation titled “Climate Act – All Pain and No Gain” describing the New York Climate Leadership and Community Protection Act (Climate Act) to the New York Propane Gas Association Fall Conference on October 25, 2021.  This post summarizes the presentation because it gives a good overview of issues related to the Climate Act.

I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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

According to their website the New York Propane Gas Association (NYPGA) is “a member-focused trade organization providing services that communicate, educate and promote the propane industry in New York”.  I led off the discussion of the Climate act with my overview presentation on the Climate Act. The second speaker, Richard Goldberg from Warm Thoughts Communications, described their plans to fight the Climate Act.   Finally, Assemblyman Phil Palmesano updated the group on the climate initiatives political situation in Albany.  I am only going to discuss my presentation in this post.

Presentation

Because the slides and annotated slides with references are available I will not go through every slide in the presentation.  Instead, I will highlight the points that I was trying to make and only include a few slides.  There were four main topics: an overview of the science, a summary of the Climate Act, a description why I think there is no gain from the Climate Act and an explanation why it is all pain.

For the science overview I used slides prepared by Dr. Judith Curry that she graciously allowed me to use.  One problem I had is that there is so much material that I could have presented it was difficult to pare down the content to fit the 30-minute time slot.  I only used the first three slides from Dr Curry’s presentation.  The first slide described the common perception of the climate crisis.  The second explained problems with the climate crisis narrative:

• We’ve vastly oversimplified both the problem and its solutions
• The complexity and uncertainty surrounding climate change is being kept away from the public and policy debates.
• Rapid reductions in emissions are technologically and politically infeasible on a global scale

I also included her summary of the 97% climate science consensus and the disagreements about the current state of climate science:

• How much of the recent warming has been caused by humans?
• How much the planet will warm in the 21st century?
• Whether warming is ‘dangerous’
• And how we should respond to the warming to improve human well-being

My summary of the Climate Act used graphics from the New York agency publications.  I noted that the rationale for the Climate Act is that we need to do something to address the “the greatest threat facing life as we know it” but explained that I did not have time to demonstrate that this claim is an exaggeration, see this example of the material I would have used if I had time.  When I showed a list of the Climate Act targets, I explained that they were developed by motivated special interest authors and that the limits were set entirely to fit a political agenda with no thought of feasibility.

While I tried to avoid getting into the details of the greenhouse effect, I had to address a couple of points. I included a slide describing the greenhouse effect as background for the discussion of global warming potential (GWP) after a slide listing the six greenhouse gases covered by the Climate Act.  The GWP is used to intercompare the effects of different greenhouse gases.  It is a function of the gases’ ability to absorb radiation and their residence time in the atmosphere.  The Climate Act vilifies methane by using a 20-year GWP time scale whereas, everybody else uses a 100-year GWP time scale.  This triples the importance of methane in the accounting for all the gases.  However, if the Climate Act is really intended to address the potential for New York emissions to cause global warming this is inappropriate.  The actual effect of a greenhouse gas on global warming is a function not only of GWP but also observed atmospheric concentrations.  Because the concentration of methane is so low in the atmosphere, doubling the concentration will “change the outgoing forcing by less than one percent”.  In other words even if we control methane it will have not effect on global warming.

I included the following table that showed where the state currently stands relative to the 2030 goal of a 40% reduction of greenhouse gas emissions.  The data in the table were extracted from the advisory panel presentations and are a sum of all six greenhouse gases expressed in million metric tons of carbon dioxide equivalent – adjusted for the 20-year global warming potential.  In the most recent year of data (2018), emissions were only 8% less than 1990.  Getting an additional 32% by 2030 is an ambitious goal.  I also pointed out that Climate Act methane obsession increases residential, commercial, and waste sector emissions to nearly half the total in 2018.

My no gain for the Climate Act argument is that it will not have an effect on global warming. If the point is that we want to reduce global warming to reduce the effects we constantly hear about in the media, then perhaps it is time to re-think this approach.  I showed that if New York manages to eliminate all the 1990 emissions that we can only expect a reduction, or a “savings,” to global warming of approximately 0.0097°C by the year 2100.  Given that atmospheric temperature measurements only have a precision of 0.1°C that means we will never measure the change due to the Climate Act.  In addition, we will never perceive that reduction using the general rule of thumb for temperature change with elevation or latitude because the predicted temperature savings is equivalent to a vertical distance change of 39 inches or latitudinal distance change of 0.9 miles.  Most importantly emission increases elsewhere overwhelm any reductions New York can make.  For example, emissions from coal plants under construction and completed in China in 2019 will subsume the reductions of all of New York in less than two years. 

I also argued that there is a moral case for using fossil fuels that makes it very likely that fossil fuel will be the appropriate choice to provide reliable, affordable, and abundant electricity to the over 1.2 billion people in the world who don’t currently have it.  The following slides shows that even as CO2 emissions have gone up poverty has decreased, life expectancy has increased and population has increased.  Similar results for other parameters representing human well being show the same thing.

My presentation went on to describe how the Climate Act implementation was set up and the current status.  I explained that the law established the Climate Action Council to develop a scoping plan to meet the targets.  It has 22 members and 14 members were appointed indirectly or directly by former Governor Cuomo.  Those members were chosen for political purposes rather than technical expertise.  Technical expertise was supposed to come from the advisory panels composed of people with expertise or direct involvement.  Unfortunately, direct involvement meant politically correct so technical expertise was short-changed.  The result was that the proposed strategies from the panels are more aspirational than practical.

I went on to explain that the strategy recommendations developed since last year have been turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan in October so that the scoping plan can be finalized by the Climate Action Council by the end of the year.  Next year the public and other stakeholders will get to comment on the scoping plan

In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented.  The analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with different scenarios that incorporate emission reduction strategies.  All of the analyses have common themes as shown in the following slide.  They will have major impacts to reliability, cost, and personal choice.  For the presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” that translates into mandates for electrification of heating, cooking, and hot-water. 

Four scenarios are included in the integration analysis.  Scenario 1 incorporates recommendations by the Advisory Panels for potential reduction strategies that included ambitious actions but the emission reductions were only 34% by 2030 instead of the 40% target.  The remaining scenarios were designed to meet the 40% target at a minimum and include even more ambitious actions.  Scenario 2:  uses low carbon fuels (bioenergy and hydrogen) for combustion for difficult to electrify applications and for times of low renewable availability.  In order to placate the members of the Climate Action Council who believe that all forms of combustion are bad Scenario 3 reduces combustion as much as possible and accelerates electrification of buildings and transportation actions.  Scenario 4 was developed to respond to those on the Climate Action Council who think that more reductions faster are possible which pushes all the actions further.

At the October 1, 2021 Climate Action Council meeting new findings from the integration strategies were described.  The one I find most unsettling notes that meeting the targets will require: “unprecedented rate of adoption of novel and potentially disruptive technologies and measures”.  I explained that I did not know what a disruptive technology was so I had to look it up.  I found a reference that explained that disruptive technologies “significantly alter the way consumers, industries, or businesses operate” and a “disruptive technology is one that enters the mainstream and changes the way most people think or behave.”  However, that same reference notes that there are disadvantages: “New technology is typically untested and unrefined during its early stages and development can continue for years” and “innovations go through a period of problem-solving”.  The problem is that the Climate Act schedule precludes most testing and problem-solving for these technologies  For example, one of the low-carbon fuels proposed is green hydrogen produced by hydrolysis of water powered by wind and solar but the economic viability of this new technology is unclear.  Beyond the mere unproven mechanics of the process as a way to store intermittent wind and solar for later use, the logistics of deploying the technology as well as the environmental impacts have not been addressed.  The bottom line is that depending on disruptive technologies to meet the Climate Act goals is incredibly risky.

For this presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” and specifically discussed the potential mandates for electrification of heating.  The silver bullet technology for home heating is the heat pump.  I explained that they are more efficient than combustion and they have the advantage that they can provide both cooling and heating.  I noted that they basically are refrigerators operated in reverse.  Instead of taking heat out of the refrigerator to cool it they take heat out of the environment to warm the house.  There are two types of heat pumps.  Ground-source heat pumps use energy in ground that does not vary as much but are more costly and more difficult to retrofit.  Air-source heat pumps are cheaper and can be retrofit more easily.  However, they use atmospheric energy so they require backup heating capability in New York because there is insufficient energy available outside when the temperatures go below zero deg. F.  I went back to the refrigerator analogy to make the point that refrigerators work well because they are insulated and well-sealed.  In order to work as well in a building, comparable insulation and building shell efficiencies are needed. Clearly that is unlikely in most homes.

I explained that the mitigation scenarios all have mandates for heat pump installations.  I extracted the heat pump strategies in the October 1, 2021 building sector descriptions for the following table.  The scenarios assume that all furnaces sold in 2035 will be heat pumps and include a transition of heat pump sales (77% to 80%) by 2029.  Note that this modeling does not propose how people will be coerced into those sales before the 2035 mandate.  The modeling also makes assumptions about the number of heat pumps in the system by 2035 and 2050.  Scenario 2 assumes 80% of the heat pumps installed are air source and Scenario 3 is a “lower share”.  Backup is mostly electric in Scenario 2 and is all electric in scenario 3.  It is interesting to note that only Scenario 3 admits that retirement before the end of useful life of fossil-fired furnaces is needed.  It is not clear how they would design a regulation to enforce that mandate.

I explained that there are three painful aspects of the Climate Act

1. Strategies don’t work everywhere
2. Strategies don’t work all the time
   1. In some cases that is just a nuisance
   2. In other cases, it could be dangerous
   3. Without significant revisions I think it could lead to catastrophe
3. Real costs will be substantial and their purported benefits are unrealistic
   1. It is not possible to offset consumer costs with the benefits claimed

I gave three examples of Climate Act strategies that do not work everywhere.  One of the prominent buzz phrases in the advisory planning recommendations is “smart planning” which basically boils down to strategies that reduce energy use such that less generation is needed.  One prominent example is to combine residential, commercial, and retail in one location to reduce energy use.  For example, a smartly planned development could enable residents to walk to a grocery store rather than having to drive.  However, in order to work the population density has to be high enough to support the grocery store.  I don’t see how that strategy could work outside of New York City and its immediate suburbs.  A major strategy to reduce transportation emissions is to enhance public transit to enable people to reduce vehicle use but this also needs a minimum population density and is unlikely to ever be a viable alternative in rural areas.  Note that the Climate Action Council members who want to eliminate combustion sources would eliminate the use of wood burning for home heating.  I believe that would be a non-starter for many rural residents who use their wood lots to provide the energy for heating their homes.

I noted that there are three examples of Climate Act strategies that do not work all the time.  The second major strategy to reduce transportation emissions is to electrify vehicles.  I will admit that electric vehicles work well for limited applications but they have limitations relative to gas powered cars.  For example, I could use an electric vehicle for most of my local trips around Syracuse but I also use the car to visit family in Brooklyn.  I don’t think that is a viable option with an electric vehicle because I would have to stop en route to charge up the car and then compete with around a million other car owners to find a place to charge when in the city.  However, it is just a nuisance because I have the alternative of taking a train or flying down.

The Climate Act strategy to electrify home heating is more problematic.  While heat pumps have advantages, the inescapable fact is that air source heat pumps don’t work well in really cold weather when you need heat the most.  In my case, in order to ensure that I have sufficient heat when the temperature is below zero, I am going to have to have a backup radiant electric heat that is inconvenient and expensive.  When everyone in my neighborhood has been forced to install similar systems, we will have to hope that the local distribution system will be able to handle the extra load because trying to heat our houses with toasters is not energy efficient.  I also have to hope that my house service can handle the extra load at the time of critical need.  If I get this wrong, it is not only inconvenient but also dangerous.  I don’t think the odds of everyone getting this right are very high.

There is an even worse possibility.  The future electric system is going to depend on intermittent wind and solar energy to provide electricity.  If electric system planning gets this wrong the results could be catastrophic.  I have previously described this situation as the Ultimate Problem with the Climate Act.  In early 2020 a couple of analyses highlighted this issue as shown in the following slide.  In order to keep the lights on grid operators have to balance load and generation which is relatively easy when the majority of the generators can be dispatched to do the matching.  However, wind and solar are not dispatchable so it gets more complicated.  In their presentation to the Power Generation Advisory Panel on September 16, 2020,  E3 included a slide titled Electricity Supply – Firm Capacity that stated that: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  They noted that they had found multi-day periods with low wind and solar output as shown in the slide when the renewable resource energy was far less than the load needed.

In order to provide sufficient electrical energy to power the future grid when home heating and transportation loads are added to the electrical loads, we have to know the frequency, duration and intensity of the periods when there is low wind and solar output.  In February 2021, there was a disaster in Texas caused in part because the electrical system failed when it was needed most.  Energy problems were related to the fact that the Texas electricity market only pays for the power produced, nuclear and fossil generators were not sufficiently resilient to cold weather, and the cold weather was accompanied by light winds so wind resources were mostly useless.  In order to keep the grid operating they had rolling blackouts. 

Superstorm Sandy , often mentioned as a reason why we need to implement the Climate Act, killed 147 people and caused $70 billion in property damages.  The Texas energy debacle in February 2021 caused at least 151 deaths, property damage of $18 billion, and $50 billion for electricity over normal prices during the storm.  Note that because one aspect of smart planning is to increase the cost of electricity when load is highest, that prices will be highest when backup resistance heating is required so there will be similar increases in cost over normal prices.  If New York similarly mis-judges the availability of renewable resources similar impacts can be expected.   

There is an even more concerning issue.  If New York does its planning correctly the frequency, duration and intensity of low solar and wind output periods will be known and, assuming the disruptive technologies necessary do work as hoped, the electrical grid may be able to avoid a renewable resource reliability crisis.  However, those are predictable conditions.  What happens for a black swan event?  The projected amount of offshore wind resources in 2050 is 10% of the capacity and 20% of the energy.  What happens when a Category 4 hurricane hits the offshore wind farms?  That would have the potential to destroy a significant portion of New York’s electrical generating resources for years.  Maybe not at the same scale but an ice storm would also be problematic when everything is electrified.  Clearly anyone who claims that a wind and solar energy system is “resilient” is pushing the envelope for credibility.

The final painful aspect of the Climate Act is the cost.  The first summary of costs and benefits was presented at the October 14, 2021 Climate Action Council Meeting and I provided my first impression here.  Costs in Scenario 2 are estimated to be $340 billion and if we start spending that in 2025 that is over $13 billion per year.  They claim that the cost of inaction exceeds the cost of action by more than $80 billion.  The basis for that claim is that improvements in air quality, increased active transportation, and energy efficiency interventions provide health benefits ranging from $160 – 170 billion and that reduced GHG emissions avoid economic impacts of damages caused by climate change equaling approximately $260 billion.

Conclusion

I concluded with five takeaways:

• • • We’ve vastly oversimplified both the problem and its solutions
    • Over-reliance on technological innovation is incredibly risky
    • Strategies proposed don’t work all the time and you need them the most when they don’t work
    • Texas energy debacle was caused in part by over-reliance on renewables and costs were equivalent to the costs of superstorm Sandy
    • The bottom line is that the solutions don’t add up

I think the presentation was well received.  It was encouraging to talk to like-minded individuals because this is a hot button topic that I have found best to avoid because the true believers cannot be persuaded that there are issues and uncertainties associated with the science.  It is troubling that I see the same slavish devotion to the premise that renewable energy solutions can replace the existing system if we only have the political will.  On the other hand, now that we have specific policy recommendations, I am convinced that a list of what will be required will awaken the majority of New Yorkers to what is coming at them.  Then we can explain the fact that the ambitions for a zero-emissions economy are not affordable and increase energy reliability risks too much with available technology.  It is appropriate to call time out and determine a better course of action than the Climate Act.

I am starting to see more New Yorkers becoming aware of the impacts of New York’s Climate Leadership and Community Protection Act (CLCPA).  In order to meet the target of a 100% carbon-free electricity system by 2040, an enormous amount of solar power will have to be built.  I recently heard from Dan Steward, an agronomist and environmental planner in western New York who raised the issue of another unintended consequence after finding this blog.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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.

Steward’s Concern

In brief, Dan notes that most farmers rent a significant portion of land for their operations, especially dairy farmers who use it to grow forage for their herds.   Farmers have always competed for the use of land:  there is a saying that the farmer who can farm the land most profitably is the one who will end up with it.  This is economics 101.  Farmers are now competing with solar developers with vast direct and indirect subsidies, offering land owners up to ten times the current agricultural annual lease rates.   This raises the concern that farmers will not have enough available farmland to support the investment they have made in facilities, livestock, or equipment.   At a minimum, it will raise the cost of land for New York farmers, making it harder to compete on the increasingly global food markets.

Dan explained that in the last year they have reviewed and commented on Notices of Intent for at least a half dozen industrial solar developments that convert farmland in agricultural districts in New York’s Chautauqua County.  He notes that although there are “guidelines” for developers to site solar on poorer, under-utilized soils, many of the project plans they have reviewed are planned for prime soils. 

He doesn’t think most farmers understand what is heading their way. He said: “New York State Ag and Markets, who does know, is doing very little to speak out against this travesty. This is just another unintended consequence of this ill-advised policy put forward by our “leaders.”

In the past large utility-scale solar projects would have gone through an extensive permitting process that includes a requirement to inform everyone who could be impacted by the project about the plan.  However in order to “ensure that renewable generation is sited in a timely and cost-effective manner” the state passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA).  The AREGCBA has guidelines to site solar away from prime farmlands but, given the volume of applications, I doubt that permitting staff at the agencies has time to review applications to ensure that this guideline is applied.  Moreover, because the permitting requirements for notifications are so much less stringent so it is very possible that a developer could get an application approved before impacted farmers could object to the loss of the prime farmland they need to operate.

It gets worse.  Another guideline concerns decommissioning.  Developers are supposed to set-aside enough money so that when the solar development is decommissioned the land can be returned to its previous condition.  That challenge is markedly easier if the land is poorer quality or under-utilized but if the land used was prime farmland, it is much more difficult. 

There are a couple of concerns.  Given the state’s aggressive implementation policy and lack of stakeholder input in the permitting process, there is a good chance that insufficient funds will be set-aside for reclamation.  Dan is concerned about a situation where the developer declares bankruptcy without having a legitimate bond and then the landowner will let the property go back on taxes to the county without ever having decommissioned or restored the land.  He explained that:

When the question about who is responsible for decommissioning is posed at meetings or addressed in informational literature, it is stated that a land-owner should consult an attorney to protect themselves. However, in the situation I just described, it is the local taxpayers, neighbors and the county that will ultimately be left in possession of what is now basically a brownfield.

We the public have the risk, not the landowner. The landowner will have collected, according to reports, around $1,000 per acre annually. He has more than recouped the value of the land and has no incentive to engage in a costly clean up. I understand that bonding is supposed to play a role in these projects. I admit that I am not familiar with different forms of bonding and how they work. However…

This must be a common concern with these projects, but I have never heard it addressed definitively. Why does everyone need to get a lawyer to get an answer?

If you are interested in more information, Dan also passed on a video of the September 15, 2021 meeting of the Planning and Economic Development Committee of the Chautauqua County Legislature where these topics were discussed.

Cornell Analysis

In a similar vein, Max Zhang, professor in the Sibley School of Mechanical and Aerospace Engineering at Cornell recently published “Strategic Land Use Analysis for Solar Energy Development in New York State“. Unfortunately it is paywalled, but there is a summary of the article in Science Daily, Roadmap to expand NY solar energy, meet green goals. The study notes that:

So far, 40% of current solar energy capacity has been developed on agricultural land, the researchers found, while 84% of land identified as suitable for future solar development — about 140 gigawatts — is agricultural.

“Solar farms are already taking up agricultural land and it will likely take even more to achieve New York’s energy goals,” Zhang said. “For the solar-energy community, this is not a surprise. But for the agricultural community, this is a surprise.”

All this is consistent with Steward’s concerns.  Zhang’s analysis estimated the amount of solar needed for the CLCPA targets.

Under New York state’s 2019 Climate Leadership and Community Protection Act, the state must reach 70% renewable energy generation by 2030 — and 100% by 2040. Assuming no further offshore wind energy development beyond the current 9-gigawatt goal, the state will need 21.6 gigawatts of utility-scale solar energy capacity to reach that target.

However, Zhang did not have the results of the latest estimates of solar deployment.  On October 14, 2021 integration analyses were presented to the Climate Action Council that include the resources necessary to meet the CLCPA targets.  Scenario 2, “strategic use of fossil fuels”, projects that 64.6 GW of solar will need to be deployed.  That total includes both utility-scale facility and roof-top solar.  Assuming half is utility-scale solar that means we can expect 32.3 GW of industrial solar installations.  I have reviewed Article Ten solar facility applications and 11 included both the proposed capacity (MW) and area expected to be covered with equipment.  The average was 9.3 acres per MW so that means in order to meet the CLCPA targets 300,300 acres or 469 square miles of land will need to be covered with 32.3 GW of solar panels by 2050.

Zhang has a couple of suggestions to reduce negative impacts.  He suggests that “Keeping solar farms from becoming too concentrated in regions will likely help mitigate negative economic activity”. Overly concentrated development leads to agricultural land conversion which initiates “a negative, economic chain reaction for businesses that depend on farming”.  In an interview on his paper Zhang notes that  one strategy would be to use low quality land or consider dual-use (agrivoltaics) options.  He does note that there is an economic reason to use the higher quality land because it is flat and has already been cleared.

For the most part I agree with his analysis and statements.  However, I have to disagree with his interview statement that “solar PV is generally a benign technology.  In order to get the solar power to your home energy storage is required.  Processing to obtain the rare earth metals needed for solar and energy storage is anything but a benign impact.  In addition, the installation of the massive number of panels creates massive areas of impermeable surface which will increase stormwater runoff.  If not handled correctly serious problems will occur.

Past Experience

In no small part the reason for Dan’s cynicism is his past experience with other state renewable energy programs.  He cites the problematic wind turbines installed on the Thruway. Several years after installation they weren’t working and the State ended up suing the developer.  I could not find any reference to a resolution of the problem. 

Another example is the NYSERDA Solar Thermal Incentive Program.  Dan explains that:

Contractors were paid to install solar thermal panels on barn roofs. Most farmers paid nothing for them. However, there was no incentive to make them work. All of the farms I have talked to, including my brothers, that had them installed through this program have told me they never worked! The contractors took their money and got out of Dodge. Eventually they will need to be taken down at the farmer’s expense. Some may now have some equipment that has some value for other uses, but in most cases, little to no renewable energy hot water was produced. Stop in and ask a farm or two.

Dan also mentions another renewable energy project that I remember from my days at Niagara Mohawk.  The idea was to plant stands of willows as a pilot project for renewable energy on agricultural land.  The plan was to burn the willow at the Dunkirk coal-fired power plant but when somebody did the math it turns out that the plant could have burned all the willow planted in such a short time that they could not justify getting the system setup to use the wood.  As a result, it was never harvested and it is not hard to find hundreds of acres of willow in Chautauqua and Cattaraugus County if you know where to look.  Of course, even if it had worked the plant is closed now so failure to use the resource was only a matter of time.

Conclusion When the people affected by the massive amounts of renewable energy development get a chance to make their concerns known, it turns out that there are legitimate concerns that should be addressed.  Unfortunately, the New York renewable energy siting process no longer mandates that their concerns should be heard even from peer-reviewed work such as Zhang’s.  As a result, I expect many unintended consequences to arise unless changes are made. Given that the history of previous renewable energy projects in New York does not have a particularly good record of success it is easy to presume that this will be the case this time too.

This post discusses an example of New York’s Climate Leadership and Community Protection Act (CLCPA) environmental hypocrisy.  I describe an instance where infrastructure support projects will have a far greater environmental impact than similar but smaller impacts that were grounds for permit denials for fossil fuel infrastructure applications.  This example discusses underwater cables and pipelines.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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.

New York Regulatory Decision for a Pipeline

On May 15, 2020 the New York Department of Environmental Conservation (DEC) announced the denial of the Water Quality Certification (WQC) the proposed North Easy Supply Enhancement (NESE) Project.

This project included a 26-inch diameter pipeline proposed by Transcontinental Gas Pipe Line Company LLC (Transco) that would transport natural gas from Pennsylvania through New Jersey, traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline will be installed, of which approximately 17.4 miles would be in New York State waters.

The DEC denial letter states that the application was denied, in part, because of:

Transco’s inability to demonstrate the Project’s compliance with all applicable water quality standards. To obtain a WQC from the Department, an applicant must, among other requirements, demonstrate compliance with State water quality standards. See 6 NYCRR § 608.9. Transco has not demonstrated that construction and operation of the Project would comply with applicable water quality standards. Because the Department lacks reasonable assurances that the Project would comply with applicable water quality standards, particularly without the use of a default 500-foot mixing zone for mercury and copper, the Department hereby denies the 2019 WQC Application.

The letter goes on to say:

Transco’s projections in the 2019 WQC Application are based on the presumed use of a default 500-foot mixing zone. But as the Department noted in its 2019 Denial, the Department maintains discretion to assign a smaller mixing zone or no mixing zone, based on its assessment of relevant factors including the nature of sediment contamination, the proximity of sensitive habitats, and other qualitative assessments. The Department has considered the Project in light of these criteria and has determined that the default 500-foot mixing zone is not appropriate at all locations proposed to be crossed by the Project. Without the use of a default mixing zone at all locations, the Project would not comply with all applicable water quality standards, and therefore, the Department is denying the 2019 WQC Application.

The DEC description of the permit denial states that:

Based on NYSDEC’s review of the May 17, 2019 WQC application for the NESE Project, including all supplemental materials, review of the over 16,000 public comments received, and review of the FEIS and other record materials associated with the NESE Project, NYSDEC has determined that the construction of the Project would likely have significant water quality impacts in New York State. This includes significant water quality impacts from the resuspension of sediments and other contaminants, including mercury and copper, particularly without the use of the discretionary default mixing zone in certain areas. The Project would cause impacts to habitats due to the disturbance of shellfish beds and other benthic resources. The water quality impacts would be especially problematic within the productive hard clam area located between milepost (MP) 14.2 to MP 19.7.

CLCPA Offshore Wind

At the October 14, 2021 CLCPA Climate Action Council  meeting Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) presented results from the integration analysis.  At this time, he explained that an estimated 16,000 to 19,000 MW of offshore wind development will be required to meet the CLCPA targets.  One of the first offshore wind projects recently announced that they are pushing back the completion date for their 816 MW project to the end of 2026.  According to the article, “While Empire Wind does not plan to have its project generate power for the grid by the on meeting the 2025 deadline, the developer said it is prepared to make ‘substantial investments’ by that date in order to ease potential concerns on part of New York Independent System Operator. Among the investments, Empire Wind will build a substation at Gowanus, lay 40 nautical miles of submarine and underground interconnection cable circuits, and install an offshore collector substation in the New York Bight project site.”

Project Comparison

The NESE project proposed a 26-inch diameter pipeline traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline was planned and it was all outside of the inner New York Harbor.  The Empire wind project includes a 40 nautical mile underground cable from somewhere out in the New York Bight that will cross the location of the proposed NESE pipeline as it runs through the inner New York Harbor to Gowanus in Brooklyn.  Assuming that all the offshore wind projects will be about the same size indicates that at least 20 offshore wind projects with comparable underground cables will be required.

The New York Power Grid study identifies the transmission upgrades necessary to support the CLCPA targets.  It concludes that interconnecting 5,000 to 6,000 MW of offshore wind into New York City electric Zone J “should be feasible with sufficient planning and coordination to efficiently use scarce cable routing corridors through the New York Harbor and limited space at the points of interconnection substations. In addition to the planned cables, it would require siting four 1,300 MW cables and securing landing points in Zone J.”  Note, however, that this study analyzed the resources needed for 9,000 MW of offshore wind, far less than 16,000 to 19,000 MW the integration analysis indicates is necessary.

Based on this project comparison it appears to me that four transmission cables each 40 nautical miles long are needed just for 6,000 MW of offshore wind power into the New York City points of interconnection substations.  That is over seven times as much seafloor disturbance as the NESE pipeline that was rejected because of water quality concerns.  All four cables will have to cross the proposed location of the pipeline but rather than staying outside of New York Harbor they will all be located within the harbor.  The remainder of the offshore wind energy will land on Long Island but they will all have similar impacts.

Conclusion

Any rational comparison of the scope and impact of the underwater cables needed for the proposed offshore wind developments necessary to meet the CLCPA targets and the NESE pipeline must conclude that the offshore wind cable water quality impacts will far exceed those of the pipeline.  Obviously, the pipeline denial was a blatant politically motivated action to cater to the environmental activist community who demand the end of fossil fuel infrastructure without having any appreciation of importance of reliable energy.  The Cuomo administration made the calculated decision to appease this voting bloc rather than make an unpopular decision to guarantee reliable energy.  Of course, the politicians in charge now will deny any responsibility if the gas pipeline supply issues do cause energy reliability problems.

I don’t think New York politicians have figured out that it is impossible to always appease environmental activists.  For example, the NESE pipeline explicitly noted that “The water quality impacts would be especially problematic within the productive hard clam area located between milepost (MP) 14.2 to MP 19.7.”  I cannot imagine that everyone who raised that issue would give the offshore wind cables a pass to site the underground cables in the same locations.  However, given the expedited review process of renewable energy projects under the Accelerated Renewable Energy Growth and Community Benefit Act those folks may not be aware of the permitting application in time to comment.  Furthermore, the organizations that motivated their members to comment on the pipeline have such a focus against fossil fuels that I believe that they would willingly not notify their members of the underground cable water quality impacts because it is for a “good” cause.

At the October 1, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) described findings from the integration analysis.  These findings underscore the difficulties faced to meet the CLCPA targets.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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 submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline and supply 70% or the electrical energy come from renewable resources by 2030 and by 2040 provide all electricity from zero-emissions sources.  Meeting these targets will require a transition of the entire New York energy system.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  The Council and the advisory panels are composed of political appointees chosen more for their advocacy and politics than their expertise in the energy sector.  In order to address the lack of expertise and assemble a comprehensive strategy New York State Energy Research and Development Authority (NYSERDA) and their consultants are providing technical support by developing an integration analysis.

The integration analysis has developed a reference case and four scenarios that include specific strategies, emission estimates, and costs for Climate Action Council comment and discussion:

• • • Reference Case
      • Currently implemented policies
    • Scenario 1: Advisory Panel Recommendations
      • Aggregate impacts of recommendations from Advisory Panels
      • Scenarios that meet or exceed GHG emission limits, achieve carbon neutrality by midcentury
    • Scenario 2: Strategic Use of Low-Carbon Fuels
      • Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications
    • Scenario 3: Accelerated Transition Away from Combustion
      • Low-to-no bioenergy and hydrogen combustion; Accelerated electrification of buildings and transportation
    • Scenario 4: Beyond 85% Reduction
      • Accelerated electrification limited low-carbon fuels; Additional VMT reductions; Additional innovation in methane abatement; Avoids direct air capture of CO2

According to the presentation in order to meet the targets, there are foundational themes across the scenarios based on findings from Advisory Panels and supporting analysis:

• • • Zero emission power sector by 2040
    • Enhancement and expansion of transit & vehicle miles traveled reduction
    • More rapid and widespread end-use electrification & efficiency
    • Higher methane mitigation in agriculture and waste
    • End-use electric load flexibility reflective of high customer engagement and advanced techs

The schedule for the remainder of the year is ambitious.  The integration analysis will be incorporated into the draft scoping plan by the end of October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

New Findings

I extracted the bullet points describing the new findings of the integration analysis from the October 1, 2021 Climate Action Council meeting presentation.  My reaction to these findings is shown in italics below.

• Achievement of emissions reductions to meet state law requires action in all sectors, especially considering New York State’s novel emissions accounting

Novel emissions reporting refers to the emphasis on greenhouse gases other than CO2, particularly, methane and nitrous oxides.  Novel is another way of saying no other jurisdiction in the world has prepared an inventory of emissions with such an overt and flawed emphasis on natural gas.

• • • Every sector will see high levels of transformation over the next decade and beyond, requiring critical investments in New York’s economy

• Energy efficiency and end-use electrification will be essential parts of any Pathway that hits NYS Emissions Limits
  • • In all scenarios modeled, zero emission vehicles and heat pumps become the majority of new purchases by the late 2020s, and fossil-emitting cars and appliances are no longer sold after 2035
    • 1 -2 million efficient homes electrified with heat pumps by 2030
      • • In 2017 there were 7,302,710 occupied housing units in NYS
        • 2% or 820,554 used electricity for space heating
        • The fraction of heat pumps used is unknown but has to be small
        • To reach 1.5 million heat pump homes requires about 200,000 conversions per year
    • Approximately 3 million zero-emission vehicles (predominantly battery electric) by 2030
      • • 1 million vehicle registrations on file in 2018 so 2030 is 27% EV
        • On 9/2/2021 there were 81,858 ZEVs on the road in NY, 0.9%
        • Over the last 12 months 2.15% of the new vehicles registered were electric vehicles and the greatest month was 4.36%
• Unprecedented rate of adoption of novel and potentially disruptive technologies and measures

Disruptive technologies “significantly alter the way consumers, industries, or businesses operate”.  “To be considered disruptive, technology must be easily accessed by a majority of the population. Revolutionary inventions are often not disruptive because they’re too expensive for the common consumer. In many cases, it’s not until the technology is refined enough to become affordable that it’s considered disruptive to the market. A disruptive technology is one that enters the mainstream and changes the way most people think or behave.

Disadvantages of disruptive technologies:

• • • • • “New technology is typically untested and unrefined during its early stages and development can continue for years.”
        • “Nearly all innovations go through a period of problem-solving.”
        • “It can take time for a disruptive technology to find its place in the marketplace.”

It is incredibly risky to be counting on novel and disruptive technologies to meet the CLCPA targets.

• Consumer decision-making plays a large role, especially important for the purchase of new passenger vehicles and heating systems for homes and businesses through the next decade

The climate act implementation echo chamber has not addressed what will happen when there is an extended outage following an ice storm.  Many folks have a contingency plan for that kind of an event but see no reasonable alternatives when everything is electrified.

• Substantially reduce vehicle miles traveled while increasing transportation access
  • Expansion of transit service structured around community needs
  • Smart growth inclusive of equitable transit-oriented development
  • Transportation demand management

I do not believe that the majority of New Yorkers are aware that the CLCPA will mandate these limitations on personal mobility.  The climate act implementation echo chamber has not explained how this will not have massive impacts to rural areas and the rural poor.

• Wind, water, and sunlight power the majority of New York’s economy in 2050 in all Pathways
  • Even with aggressively managed load, electric consumption doubles and peak nearly doubles by 2050, and NYS becomes a winter peaking system by 2035.

Although the presentation mentions that the reliability standards are included in the scenarios it is not clear to me that is the case because there is so little documentation available.  Furthermore, I think it is likely that there will be new reliability rules that certainly have not been included.

• Offshore wind on the order of 20 GW, solar on the order of 60 GW, and 4-and 8-hour battery storage on the order of 20 GW by 2050

These are extraordinary numbers.  The largest integrated solar-powered battery will be at the Florida Power & Light Manatee Solar Energy Center rated at 409 MW, 900 MWh.  Note that the energy storage facility only provides two hours of storage so over 100 equivalent facilities will have to be built.

• Firm, zero-emission resources, such as green hydrogen or long-duration storage, will play an important role to ensure a reliable electricity system beyond 2040

Long-duration storage does not exist today and green hydrogen has not been deployed at utility scale.  Moreover, as the hydrogen is produced it will have to be stored and transported to where it will be used which is no easy feat.

• Low-carbon fuels such as bioenergy or hydrogen may play a critical role in helping to decarbonize sectors that are challenging to electrify
  • By 2030, initial market adoption of green hydrogen in the following applications: medium and heavy-duty vehicles, high-temperature industrial (sic).

For a technology not yet commercially available expecting any significant market adoption in this time frame is a stretch.

• Additional promising end-use applications include district heating and non-road transportation such as aviation and rail.

In theory these fuels might work for these applications but the technology has not been proven.

• Required transition to low-GWP refrigerants and enhanced refrigerant management by 2050

If these refrigerants and enhanced management were cost-effective,then they would be used now.

• Large-scale carbon sequestration opportunities include lands and forests and negative emissions technologies
  • Protecting and growing New York’s forests is required for carbon neutrality

I get the impression but have not confirmed that one of the control strategies is to convert home heating with wood to electric.  The concept that people do that because they cannot afford alternatives and the probable increase in costs associated with this law suggests that more rather than less people will want to heat with wood.  It is not clear to me how the State would regulate a land owner’s use of wood for home heating.

• Negative emissions technologies (e.g., direct air capture of CO2) may be required if the State cannot exceed 85% direct emissions reductions

This is an absurd statement because it presumes that the New York contribution to the total greenhouse gas levels in the atmosphere can be measured to the point where direct air capture could have an effect.  

• Strategic land-use planning will be essential to balance needs

• Necessary methane emissions mitigation in waste and agriculture will require transformative solutions
  • Diversion of organic waste, capture of fugitive methane emissions are key in waste sector

Easy to say but extremely difficult to implement in practice.

• Alternative manure management and animal feeding practices are key in agriculture

If these practices were cost-effective farmers would be doing them today.  Apparently they are not using them so who pays for farmers to use them?

 Additional innovation will be required in areas such as carbon sequestration solutions, long-duration storage, flexible electric loads, low-GWP refrigerants, and animal feeding, in concert with Federal action (e.g. Earthshots)

Requiring “additional innovation” to ensure that the lights are on, homes are kept warm and people will be able to charge their mandated electric vehicles is extraordinarily risky.  If the risks associated with the effects of climate change that could be changed by New York emissions were compared to the risks of this policy causing a blackout, then I have no doubts that the integration analysis strategies would be rejected out of hand.

 For what it is worth, the Earthshot example refers to the Department of Energy’s “Energy Earthshots” that will “accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade”.  Even if they accomplish a breakthrough the CLCPA schedule is too aggressive to take advantage of it.

• Largest three remaining sources of emissions in 2050: Landfills, aviation, and animal feeding

No comment.

Conclusion

Of particular concern is that the integration analysis acknowledges that disruptive technologies will be required to meet the CLCPA targets.  I explain that these technologies are typically untested and unrefined during early stages and development can continue for years.  These innovations go through a period of problem-solving.  Given that the electric system has a long history of revisions following blackouts to address reliability problems as they arose it is unrealistic to expect that similar problems will not arise in the future. 

In order to meet the CLCPA legal schedule there has been insufficient time to prepare the documentation necessary for stakeholders to evaluate the proposed strategies.  However, given the absolute need to try to avoid catastrophic problems the integration analysis scenarios have to be fully documented.  Climate Action Council meetings have included multiple member statements arguing that the law requires some of the more unrealistic proposals incorporated into the strategies.  The ultimate question for the Climate Act is what happens when stakeholders expose the reliability risks of those strategies.  Will the Hochul administration cave to the special interests or listen to those responsible for keeping the lights on.

At the September 13, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  I agree that this is an important consideration and recently wrote that the European experience reflects not only high energy costs but there are troubling signs that reliability issues can occur even during periods when the electric system is not stressed due to high demand.  This post calls reader’s attention to Minister of Parliament Steve Baker’s recent article on the United Kingdom’s similar plans to reach net zero emissions.   

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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

Steve Baker is a Conservative MP and former Brexit Minister. He is a trustee of the Global Warming Policy Foundation (GWPF).  I wanted to include a description of the GWPF in this section but recent changes have made that difficult.  If you do an internet search for the GWPF, you will get a string of results all branding them as the “United Kingdom’s most high profile climate denier group” but won’t be able to find their own link without searching.   If you get to gwpf.com then you are redirected to Net Zero Watch.  GWPF has set up Net Zero Watch to “provide serious analysis of naïve and un-costed decarbonisation policies.”  They plan to “highlight the serious economic, societal and geopolitical impacts of poorly-considered policies, both domestically and internationally”.

Net Zero Watch has been setup to “highlight and discuss the serious implications of expensive and poorly considered climate change policies”.  A recent energy crisis in Europe foreshadows New York’s future under the CLCPA:

With our domestic shale gas resources sitting untapped under an absurd government ban, gas prices are going through the roof. Net Zero Watch will challenge the wild claims of green activists and policy advisers about this venerable and benign technology, which has brought US gas prices down to a small fraction of those here.  As this year’s weather has shown, our decision to phase out fossil fuels and nuclear power and to rely more and more on wind farms for our electricity supply has had dangerous consequences. We will campaign to put affordability and security of supply back at the centre of the energy debate, and we will expose the risky wishful thinking behind many claims about energy storage.

Baker’s description of the United Kingdom net-zero plan is entirely consistent with my impression of the CLCPA.  The following section quotes Steve Baker’s commentary in italics with my indented and unitalicized comments.  I don’t have many comments because one only has to substitute New York for UK and Albany for Westminster for the most part.

“Winging It” is a Catastrophe Waiting to Happen

The UK’s plans to decarbonise the economy are a classic example of the ancient political strategy of “winging it”. Hard though it is to credit that idea, it’s true; the “experts” in Westminster have been basing your future and mine on a plan that relies, to a very great extent, on a collective crossing of the fingers.

 The CLCPA experts in Albany rely on bureaucrats at the state agencies that have to tailor their results to meet the political agendas of their appointed directors to sustain their careers.

Governments of one shade or another, Whitehall bureaucrats, and their advisers in the Climate Change Committee have been working on such plans for well over a decade now, and it’s fair to say that they still have little or no idea how Net Zero can be achieved, beyond a vague idea that we should electrify everything and have lots of energy from windfarms.

 The description of the scenarios to meet the CLCPA targets at the October 1, 2021 meeting of the Climate Action Council is entirely consistent with this description.

 That’s no more than a starting point, of course. There are enormous practical difficulties (and eye-watering costs) to be dealt with, but such nitty-gritty issues seem of little interest to the experts in Westminster. “Things will become cheaper…” they say “….we’ll invent something”.

 Expert handwaving of this kind has been enough to convince the media and most politicians, but as the legendary physicist Richard Feynman once pointed out, Nature cannot be fooled, and it looks very much as Nature is going to lay her cards on the table this winter.

 One of the key problems is that we don’t have any way to store electricity on a large scale for when the wind isn’t blowing. That can be a few weeks in a normal year, or months in a bad one. The problem has always been there, and we have had no firm answer from the “experts”. We don’t have enough suitable sites for pumped hydro; batteries and hydrogen are far too expensive. As was pointed out in a letter to one of the national newspapers last week, enough batteries to see us through a wind lull lasting just ten days would cost £150,000 per household at current prices.

 There is no reason to believe that New York’s costs to maintain current reliability standards will differ much from the £150,000 per household or $204,000 per household.

 The Climate Change Committee says that we can get electricity through interconnectors from other countries when the wind doesn’t blow here. This is something of a “magic solution” for them, because they can simply claim that we’ll build as much interconnector capacity as we need. However, it again ignores the practical difficulties, such as the fact that if the wind isn’t blowing here, it probably isn’t blowing in most of western Europe either, so assuming (as the “experts” in Westminster do) that everyone follows us down the decarbonisation path, we are all going to get in a bidding war for the few megawatts of power that are left. There is also a national security problem with interconnectors, as was recently brought sharply into focus by French threats to cut the UK off if we didn’t play ball over fishing rights.

 To this point, the CLCPA scenarios avoid the use of imported power and, for the most part, we don’t have to worry about international security issues.  Note, however, that a key component for New York City is a transmission interconnection for hydropower  from Quebec.

 The CCC also says we can get a bit of power from gas-fired power stations equipped with carbon capture and storage (CCS). However, the practical problems are again fairly stark; nobody has yet made a success of CCS – a series of pilot projects have tested the waters on the easier ground of coal-fired power stations, and each has been closed as an economic failure; the power they produce is simply too expensive. And nobody has yet got the technology to work at all for gas-fired power stations.

 New York’s plans include CCS for concrete manufacturing but so far have downplayed its use for power generation.  All of the concerns listed are relevant and don’t note that a suitable location for sequestration is needed.  Incredibly there are members of the Climate Action Council that want to prohibit all forms of combustion which would preclude the use of CCS altogether.

 The other problem with planning for gas and CCS to deliver us from the perils of intermittency is that it appears unlikely we are going to have any cheap gas to feed them with – successive governments, egged on by the CCC, the renewables industry, and the green movement have told us we must “keep fossil fuels in the ground”.

 This was seen in part as a way to encourage the second part of the decarbonisation strategy, namely for people to “invent something”. In other words, if we have no gas and no way to balance the grid, well, someone will come up with some way to fix the problem. So we first made the electricity grid unwelcoming for gas-fired power stations, then we neutered the nascent shale gas industry with absurd regulations, and then we banned it completely.

 This is entirely consistent with New York’s CLCPA implementation.

 Which brings us to where we are today, with the whole country crossing its fingers and praying that someone will “invent something”, or at least find us a way to make it through the winter without the lights going out.

 For twenty years, the vested interests have had their say, and public relations have taken precedence over engineering and economics. But, to return to Professor Feynman, Mother Nature really cannot be fooled, and when she reveals her hand, the results are likely to be horrible.

 Is catastrophe coming? I fear so, unless ministers get a grip and liberate the private sector to go for gas, right now.

 New York’s problems are not so imminent largely because Pennsylvania went ahead with the natural gas fracking and now has an abundance of natural gas to sell to New York.  Nonetheless, National Grid has warned its customers in Central New York that natural gas bills could go up 31% because of increased demand and a global spike in prices.  I cannot help but wonder if New York had developed its natural gas resources if we would be seeing a similar price increase.

 Conclusion

The slow motion train wreck that is the future of New York energy under the CLCPA will only continue to a similar crisis unless it is repealed for all of the reasons shown in MP Steve Baker’s commentary.  To date “vested interests have had their say, and public relations have taken precedence over engineering and economics” but at some point, reality has to be addressed.  The fact is that today’s wind, solar and energy storage technology is not up to the role conceived by the authors of the CLCPA.