Personal Comment Submittals

Before I retired one of my responsibilities was to evaluate proposed environmental and energy regulations and legislation to determine the potential effects on electric generating operations.  From the company standpoint it was necessary that the comments be a dispassionate technically supported argument for changes to increase the likelihood that the comments would be acknowledged much less used to modify the proposal.

Since retirement I have submitted comments as a private citizen and have tried hard to maintain that approach.  I recently realized that I could vent my frustrations in a blog post that explained the proposal, my comments and what I really think is going on.  I can also use the blog as an archive for my comments so that they can be referenced more easily elsewhere.

This page lists posts on this blog that describe and archive my public submittals with the most recent list first.

Response to My Comments on the New York Value of Carbon Guidance January 5, 2021

This post documents the responses to my comments on the New York Value of Carbon guidance

Response to My Comments on Part 496 – CLCPA 1990 Emissions December 27, 2020

On October 26,2020 I submitted comments on the this regulation that proposed a rule establishing the 1990 emissions baseline for the Climate Leadership and Community Protection Act.  This post documents the response to my comments.

My Comments on Cross State Air Pollution Rule December 22, 2020

I submitted comments to the Environmental Protection Agency (EPA) on their latest proposed revision to the Cross State Air Pollution Rule.  EPA has set up a potential problem with their proposed revisions to this rule.  If adjustments are not made to the allowances available and the market is not as liquid as theory suggests, then there could be situations where the only compliance option available to some sources is to limit operations.

My Comments on the New York Value of Carbon Guidance Document November 25, 2020

This post describes my comments  on the draft guidance document “Establishing a Value of Carbon, Guidelines for Use by State Agencies”.  The focus of this guidance document is on use by State agencies but I believe that does not mean that the need for CLCPA implementation guidance should be overlooked. In order to justify the implementation costs of the CLCPA the damages approach of the social cost metrics may seem appropriate but because targets have been set the marginal abatement approach should be emphasized and used wherever possible in New York State going forward.  Documentation should be provided for the general public that describes the social costs approach. It should include a table showing the differences in estimates based on the assumptions used.

My comments on the FERC Carbon Pricing Policy November 18, 2020

I submitted these comments as a private citizen.  The technical conference convinced FERC commissioners that carbon-pricing was an “efficient” market-based tool but nobody asked and no one proved that they work.  In my opinion the first rule of efficient policy is that it works.  I believe that those who support carbon pricing on theoretical economic grounds are overlooking or are unaware of practical issues I have raised.  Cynic that I am, I think the primary value to FERC and the RTO/ISO operators is that the carbon price makes their lives easier.  That it will have significant impacts on consumers and not do anything for the climate is somebody else’s problem.

My Climate Leadership & Community Protection Act Part 496 Comments October 26, 2020

The proposed part 496 regulations defined the 1990 baseline emissions inventory for the CLCPA.  It is important because many of the targets of the CLCPA are based on reductions from this baseline.  In order to meet the “best available science and methods of analysis” criteria of the CLCPA, the DEC documentation should but did not address the current methane debate by summarizing articles on both sides of methodology differences, explain how those differences affect the Part 496 1990 emission inventory relative to previous inventories, and then provide the rationale for picking one approach over the other.  Because this level of detail is not provided, I recommended that the Part 496 inventory re-proposed with that information.

Climate Leadership and Community Protection Act White Paper Comment July 22, 2020

I commented that renewable natural gas should be considered a renewable energy system.

Part 242 Comments – Background and Rationale for Revisions Submitted June 25, 2020

Part 242 Comments on the Regulatory Impact Statement Submitted June 25, 2020

The proposed revisions to Part 242  reflect the RGGI program changes set forth in the updated RGGI Model Rule.  I commented on a couple of the rule changes and reviewed the rationale in the Regulatory Impact Statement.

My Additional Comments on NESE Pipeline Alternatives  April 30, 2020

Department of Public Service Case 19-02328/19-G-0678 is a proceeding related to denial of service requests by National Grid in New York City and Long Island associated with the Northeast Supply Enhancement (NESE) pipeline.  I addressed comments made by others in three separate submittals documented in this post.

Denial of Service Requests by National Grid aka NESE pipeline alternatives – Submitted March 27, 2020

Department of Public Service Case 19-02328/19-G-0678 is a proceeding related to denial of service requests by National Grid in New York City and Long Island associated with the Northeast Supply Enhancement (NESE) pipeline.  I commented on the options to the pipeline presented.

NYISO Grid in Transition Comments – Submitted March 26, 2020

As part of an effort to evaluate the changes needed within the New York State electric system, the New York Independent System Operator (NYISO) sponsored work by the Brattle Group.  Their report entitled “Grid in Transition: Introduction to the Modeling Methodology and First Discussion of Assumptions” included questions that were the focus of my comments.

Reply Comments to New York Resource Adequacy Proceeding – Submitted January 23, 2020

Department of Public Service Case 19-E-0530  fulfills “statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Costs to consumers are a primary and ultimate consideration, recognizing that the necessary investments in resources must have sound economics.”  I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on real world data, developed an example of potential problems with air source heat pumps, and responded to specific questions.

DPS Resource Adequacy Matters Comments – Submitted September 16, 2019