New York's Climate Act Has Always Been A Political Ploy with Little Basis in Reality But the Narrative Lives On
Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.
In a recent post I observed that Governor Hochul is becoming aware that reality always wins relative to New York’s Climate Leadership & Community Protection Act (Climate Act). In particular, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much.
I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.” I also referenced Susan Arbetter’s Capital Tonight interview with a couple of agency heads and noted that there was enough material for a follow up post. This post addresses the agency head’s refusal to address reality.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”
The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, State agencies and the legislature have been attempting to implement the plans.
The original article suggesting that Hochul seems to accept that several recent reports show that implementation of the Climate Act is not going as planned. The Public Service Commission (PSC) recently released Clean Energy Standard Biennial Review Report (“Biennial Report”) compares the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030.
It projects the goal will not be achieved until 2033 when historic renewable resource deployments are considered. The New York State Comptroller Office released an audit of the NYSERDA and PSC implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking. It found that “the costs of transitioning to renewable energy are not known, nor have they been reasonably estimated.”
The final report by the New York Independent System Operator (NYISO) is its annual Power Trends that describes factors influencing New York State’s power grid and wholesale electricity markets. The findings suggest that there will be reliability risks for the Climate Act transition on the mandated schedule. I also referred to a couple of articles suggesting Hochul has broached the possibility that the Climate Act might have to be paused.
Arbetter Interview
Susan Arbetter interviewed NYSERDA President and CEO Doreen Harris and Rory Christian, Chair and CEO of the PSC for Capital Tonight. For me it was a frustrating interview because the responses to the questions posed did not reflect the issues raised in the recent reports.
Arbetter opened the interview obliquely referencing the question on everybody’s minds who is following the Climate Act – how much is this going to cost? She noted that Hochul paused the New York City congestion pricing initiative because as she stated: “Now my job is not to make it harder or more expensive for New Yorkers to live in our state – working hard, make ends meet, raise their families.” Arbetter asked if Hochul was “preparing to pause or delay the state’s clean energy goals”.
Harris did not directly respond to the question. Instead, she said: “we look at our goals objectively.” She referenced the Clean Energy Standard Biennial Review Report and its evaluation of progress towards the 2030 goal of 70% renewable energy saying that it “did reveal specific challenges that we are facing.”
She went on to say that since implementation it has been “tumultuous” with respect to a global energy crisis, Covid and supply chain constraints, etc.”. Then she said that report reveals that “we are making very good progress”. She also admitted that it is not just renewables that are an issue. It is also EV adoption, but she claimed that has improved 400% since 2021.
The Biennial Report admits the schedule will not be met and Arbetter asked if this meant there would have to be a pause. Harris just gave obviously scripted excuses. The final version of the Scoping Plan was completed in the Fall of 2021 at which time issues related to Covid were well known.
The global energy crisis following the Russian invasion of Ukraine started in February 2022 so that could not have been included in the implementation plan. Supply chain issues were triggered by the Covid epidemic, but it should have been obvious that when New York started competing with all the other jurisdictions for limited amounts of renewable energy equipment that delays would be inevitable. So at least two out of the three excuses are marginal.
My bigger issue with NYSERDA and Harris is the use of unverifiable and misleading claims. She claimed EV adoption has gone up 400% since 2021 but did not qualify that to mean the number of EVs sold or the number on the road.
It is a number that cannot be easily checked using the NYSERDA Electric Vehicle Registration Map because the data are presented in diagrams and the original values are not available except in a database with every vehicle registration in the state. A table with EVs sold or on the road by year is not available.
Nonetheless, I was able to compare the Integration Analysis projection that there would be 215,935 battery-electric and plug in hybrids on the road in Scenario 2: Strategic Use of Low-Carbon Fuels to the NYSERDA data. That data indicated that there are only 154,766 EVs presently on the road. Even if sales are up 400% that boast is misleading because they are 28% behind the planned adoption levels.
The Harris response did not address the question, so Arbetter tried again: “I just want make sure that while there are factors that have contributed to the delay in implementation of our energy goals, is there anything leading the Administration to delay this because of cost.” (Note that this is not an exact quote but it is pretty close – check out the video at 1:40/9:00).
Harris responded: “The proceeding that is before the PSC is intended to look at just that.” Harris explained: “How much progress have we made, do we need to make, and specifically they look at all this in the context of consumer cost.”
While this may be apropos of nothing, but a search in the Biennial Report for “consumer” yields three results: one for consumer price index and the other two in a paragraph describing the motivation for deregulating the power sector of New York. That may not disprove the claim that the report looks at all of this in the context of consumer costs, but my review of the Biennial Report so far has not found any sections addressing consumer cost.
During the Draft Scoping Plan review by the Climate Action Council, members Gavin Donohue and Donna DeCarolis repeatedly asked for consumer price cost projections. Co-chair Harris did not provide that information then and appears to be stonewalling now.
Arbetter accepted the claim that the Biennial Review addressed consumer cost and asked when the Proceeding will be finished. Christian responded: “Well it has begun and what we try to do in the released report is to highlight progress to date and the various challenges that we need to overcome.” He went to expand the list of excuses used by Harris saying that rising inflation and interest rates were factors as well as significant load growth. He pivoted the load growth challenge into an argument that load growth represents a “great opportunity” for the economy.
Arbetter paraphrased Christian saying that it is great that the economic development is happening, but it means we must catch up by producing more electricity. He came back with the argument that this means “we have to look at the progress we have made to date and understand what we can do to get to that next step.” He went on to suggest that the load growth was a primary driver of whether the 2030 goal could be met. It “looks like 2033 if the load growth happens the way we are seeing it, but the 2030 goal could still be met if load growth is lower or higher if load growth increases”.
I interpret this to mean that the Christian is arguing that the primary reason that the schedule will not be met is unanticipated load growth since the time the Integration Analysis implantation schedule was developed. One way to compare how the expected load in 2030 has changed over time is to compare the annual energy reports in the NYISO annual load and capacity data report (universally known as the “Gold Book”) from 2021 when the Integration Analysis projections were prepared to projections in more recent years.
The following table shows that load forecasts for New York have increased markedly since 2021 or 2022 for that matter. Regarding Christain’s claim however note that the load projection increased 13,090 GWh in 2030 but that the Biennial Report gap between the 70% goal and anticipated renewable energy is 42,145 GWh. The projected increase in load is less than a third of the expected gap so deflecting blame to unanticipated load growth is misleading.
Arbetter confirmed with Christian that the Biennial Report essentially said that the State is three years behind the 2030 70% renewable energy goal but it could possibly meet it or miss by more. He said that the Biennial Report is part of the planning process and that the released report is not final. It’s “a report highlighting where we are listing a number of recommendations and options for how best to proceed”. As far as I can tell he did not answer Arbetter’s question about the timing of the response to the draft Biennial Report.
In my opinion, at this point the interview switched from asking questions about reaching the Climate Act goals to lobbying support for the Act.
Arbetter said: “When the climate blueprint was created, the overarching reason, the fundamental thing that held it up was that it would be much more costly to do nothing than to actually create this climate transition.” Then she asked if that was still the case.
This is a paraphrase of the cost benefit slogan repeated at every opportunity by Harris: “The costs of inaction are more than the costs of action.” I have argued for years, including my verbal comments on the draft Scoping Plan to Harris and Climate Action Council Co-Chair Basil Seggos, that the slogan is misleading and inaccurate. I described some of the manipulations used to contrive the slogan here. The biggest problem is that it does not account for the full costs to implement the Climate Act targets.
Instead, it only evaluates the costs of the Climate Act mandates and excludes decarbonization programs that were “already implemented.” The already implemented programs included Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030) and the Clean Energy Standard, including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030).
That means that the slogan really means that the costs of inaction are more than the costs of action excluding the costs of 6 GW of behind-the-meter solar, 3 GW of hattery storage and 9 GW of offshore wind among other things.
Harris responded to the setup question that the benefits outweigh the costs: “It certainly is” and “We look carefully at costs but we also look at benefits.” She then claimed that there are very strong reasons for doing what we are doing. In my opinion, NYSERDA’s Scoping Plan evaluation has never been held accountable.
The agency has never responded to technical comments on issues, never addressed my comments on the cost-benefit analysis, and has never reconciled the differences between their projections for the electric system with the NYISO projections. The public should be aware that the costs were underestimated in most instances and the benefits were overestimated in every instance.
Next, Arbetter parroted the common claim that we are already seeing the effects of climate change. She said the “climate is changing in a bad way”. For examples she cited the tornado in Rome, NY, Hurricane Beryl, and Canadian wildfire smoke. “We are seeing this all the time”. After listing the examples of alleged climate change, she went on to say: “This is all costing taxpayers money, Right?”.
Christian agreed saying “We look at these costs in making determinations for what actions to take”. I waited in vain for Arbetter to ask just how much of an effect the Climate Act emission reductions would have on the alleged effects. After all, if the state is looking at the costs of climate impacts, then we should look at the potential benefits for our actions on those climate impacts.
The fact is that the State has never acknowledged that New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. Anything we do will be supplanted by emissions elsewhere in less than a year. Neither has the State estimated how much NY emission reductions would affect global temperatures. I believe that is because the change would be too small to measure.
It gets worse. One of my problems with the existential threat of climate change narrative is the consistent linking of any extreme weather event to climate change.
On my list of articles to write is a review of Roger Pielke, Jr’s multi-part series (Part 1 here Part 2 here, Part 3 here, and Part 4) on climate fueled extreme weather. He explains that “the Intergovernmental Panel on Climate Change (IPCC) spends much time and effort on assessing the science of the detection and attribution of changes in climate.“
Then he notes that “Given widespread popular beliefs and media-friendly experts willing to cater to those beliefs, many are surprised, shocked even, to learn that the IPCC has arrived at conclusions on extreme events and climate change that are completely at odds with conventional wisdom and popular opinion.”
The point that is universally ignored by the Hochul Administratin and, in this case by Arbetter, is “In fact, the IPCC currently concludes that we will not this century be able to detect with high confidence changes in the statistics of most weather events beyond internal variability.” The IPCC concluded that there is no climate change signal for tropical cyclones, severe windstorms, or fire weather. Point of emphasis that means the IPCC says there is no current climate impact signal for any of the weather events cited by Arbetter and confirmed by Christian.
Christian went on to argue that the existing system must be changed: “Very few of us are willing to tolerate technology from the 1950’s” and said the grid today is built on that foundation. He said: “We are modernizing the grid not to just take on the challenge of adopting more renewable energy but to create greater flexibility, greater resiliency and the ability to recover more quickly in the face of these extreme climate events.”
I disagree with all those arguments. Most of us don’t care about the age of the technology. We just want affordable electricity that is always available.
Note this age of technology argument ignores the fact wind power is a centuries old technology so why are we going there? I am not sure how renewables provide more flexibility, so I am not going to respond to that. The claim that the proposed electric system will provide greater resiliency is absurd.
Going from a New York system that is largely unaffected by weather conditions using generating units that independently produce power to the proposed system that relies on wind and solar that are completely at the whim of weather conditions and are strongly correlated with each other is anything but resilient.
I believe that the approach is fatally flawed.
Designing the electric grid for weather related low resource events will always have to consider the tradeoff between practical limitations say for planning based on an event that occurs once every 25 years and the consequences of a catastrophic blackout when a less frequent low resource event inevitably occurs.
The claim that a weather-dependent electric system will be able to more quickly respond to extreme weather events is beyond absurd.
Just imagine what will happen when a hurricane roars through the 9GW of offshore wind turbines. There is a strong possibility that most turbines will be damaged, and some destroyed completely. How long will it take to rebuild them? It boils down to the fact that the Climate Act “solution” do not work all the time and the periods when they don’t work are the times they are needed most.
Arbetter returned to asking questions when she said “Everybody wants this” but specifically asked about the Comptroller Audit report noting that it was critical of some of what they are doing. She asked then if the criticisms were warranted and are you taking corrective action.
Christian responded: “I want to start with where they acknowledged success” citing their “recognition of the efforts that both of our organizations have made in moving us towards those goals.” I am sure that if the Comptroller had given them a participation trophy as part of that acknowledgment, the irony would have gone over his head. He responded to the criticisms by claiming that they are doing many of the things that they are recommending already. He claimed the problems cited were due to miscommunication and said that they will work with them to get the issues resolved.
The Comptroller’s audit report made the following key recommendations:
Begin the required comprehensive review of the Climate Act, including assessment of progress toward the goals, distribution of systems by load and size, and annual funding commitments and expenditures.
Continuously analyze the existing and emerging risks and known issues to ensure they are evaluated and addressed to minimize impact on the State’s ability to meet Climate Act goals.
Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. Periodically update and report the results of the analysis to the public.
Assess the extent to which ratepayers can reasonably assume the responsibility for covering Climate Act implementation costs. Identify potential alternative funding sources.
I have seen no evidence any of those reviews, analyses, or assessments are available anywhere. I have no doubt that the work has been done but the fact is that it does not count if it is unavailable. Moreover, it is not acceptable if questions raised about the assumptions, methodologies and results are ignored. I would bet a lot that the reason these results are unavailable is that they are so damning that if they were released the whole net-zero transition would implode.
I will give credit to Arbetter because she tried again to get an answer whether Hochul was “preparing to pause or delay the state’s clean energy goals.” This time Harris responded:
Absolutely not. And instead, what we are seeing is this market response. Clearly, change takes time but at the same time, when we set these goals, we see the market responding in ways that are truly transforming our economy and, and, benefitting New Yorkers. So, our commitment remains firm.
I cannot help but draw a comparison between this situation and the Biden presidential bid. Bari Weiss masterfully describes the “era of the noble lie” that has created a crisis of trust. With regards to Biden withdrawing from the presidential race she notes: “the reason the most basic elements of the Democratic (and democratic) process are being so dramatically challenged—is because of the lie that everyone around Joe Biden told themselves and then told the public.” Weiss explains
It’s not just that they knew about Biden’s condition and lied about it. They knew they were lying and believed they could dupe their supporters at least through November 5, 2024. In other words: double talk. One message in public. A different message in private. Until it became impossible to sustain.
I think Harris and Christian are doing the same thing.
The implementation of the Climate Act is not going to plan and the costs are so extraordinary that if they were honestly reported the outrage would be universal. Their responses in this interview attempted to dupe the public. They avoided answering the questions directly and responded with platitudes and slogans. They can continue to pretend that this will work but reality is catching up fast.
The remainder of the interview went back to lobbying for the Climate Act. The availability of programs and funding for home electrification were presented.
Conclusion
The Climate Act has always been a political ploy with little basis for reality. This interview was an honest attempt to get substantive answers, but the responses were political theater.
The recent reports hint at the reality to come. The agencies can continue to downplay the obvious and say everything is fine, but reality will inevitably destroy the narrative.
#ClimateAct #NewYork #Climate #NYC #Comptroller #NetZero #Risks #Hochul #ClimateReality
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This post represents his opinion alone and not the opinion of his previous employers or any other company with which he has been associated. Roger has followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and has written over 400 articles about New York’s net-zero transition.
