This is the latest summary update of my recent posts at Pragmatic Environmentalist of New York.
By Roger Caiazza
This is the latest summary update of my recent posts at Pragmatic Environmentalist of New York. I have been writing about the pragmatic balance of the risks and benefits of environmental initiatives in New York since 2017 with a recent emphasis on New York’s Climate Leadership & Community Protection Act(Climate Act). This summary describes each of my recent posts with minimal technical jargon but includes links if you want to read the entire post. If you do not want to be on this mailing list then let me know. Previous updates and a pdf copy of the following information are also available.
Climate Act Synopsis
Edward A. Reid, Jr. is on this distribution list and sent this very good synopsis of the Climate Act implementation plan:
Herman Wouk, in “The Caine Mutiny Court Martial”, described the US Navy as: “a master plan designed by geniuses for execution by idiots”.
It appears that the NYS energy transition is a pipe dream designed by idiots for execution by geniuses. I worry that there might not be enough geniuses to pull it off. 😉
“A goal without a plan is just a wish.”, Antoine de St. Exupery
Ellenbogen: New York State’s Energy Transition
Richard Ellenbogen recently gave an important presentation on New York State’s Energy Transition that details his concerns with the net -zero mandate of the Climate Act. I thought it was important enough that I sent out an interim update alerting my readers about it. If you have not had a chance to view the video or read my summary, I encourage you to do so.
In my summary I concluded that Ellenbogen does a good job describing the many pitfalls and issues with the transition “plan”. We agree that there really isn’t a plan in place because the Hochul Administration has not provided a realistic cost – benefit assessment of the outlined control strategies or a feasibility analysis to show the strategies will work as hoped. Moreover, he points out that completely eliminating New York greenhouse gas emissions will not have a meaningful effect on any of the impacts ascribed to climate change because the state’s emissions are so small that they will be subsumed by emission increase elsewhere across the globe in a matter of weeks.
These points and others that disparage the Climate Act do not mean that we should not do something to reduce GHG emissions. However, we should not “make up fantasies to justify it” and avoid honest conversations about how best to implement a transition to lower emissions. It is time to talk about the implications of this law.
Citizens Budget Commission on New York Cap and Invest
On November 28, 2023, the Citizens Budget Commission released Keys to a Cap-and-Invest Design That’s Earth- and Economy-Focused (“Keys Report”) that examines the potential benefits and problems associated with the New York Cap-and-Invest Plan (NYCI). If you have been wondering about the cap-and-invest program that you have been hearing about, then this is a good overview.
Market-based control programs are a particular interest of mine because I have been involved in so many SO2, NOx, and CO2 programs since the early 1990’s. This article pointed out some nuances that provide context if you want to take a deep dive into this control approach.
The overarching point I wanted to make about NYCI is that its proponents have not figured out all the things that make trying to use this approach for CO2 so different than the other pollutants. The most effective way to reduce CO2 is to switch to a lower emitting fuel (e.g., coal to natural gas). There are no cost-effective control technologies that can be added to an existing source to reduce CO2 emissions, so the only option left is to run less or retire. The design of NYCI has to take those considerations into account or costs will increase higher than expected or there could be a shortfall of permits to operate. If that happens then bad things happen. Power plants won’t provide power or gas stations won’t sell gas. I tried to make the point that in addition to all the concern in the Keys Report there is an underlying uncertainty in New York. The dynamic between those who argue that there are legal requirements than must be met and the reality that the Climate Act schedule was set up arbitrarily without a feasibility analysis will have to play out as NYCI is implemented. Remember when fantasy meets reality, reality always wins.
NYISO Comprehensive Reliability Plan
The New York Independent System Operator (NYISO) released its 2023-2032 Comprehensive Reliability Plan (CRP) in November. The report provides an overview of the reliability issues that face New York’s electric system transition. This is another post that delved in technical details. NYISO has published a summary for anyone who does not want to wade through the document or my review.
In short, the CRP has two main concerns: changing conditions in the electric sector and added risks from new drivers of change. The report notes that fossil generator retirements exceed the pace of new resource additions. There is an added risk inasmuch as the wind and solar resources make “the continual balance of supply and demand more challenging.” The primary decarbonization strategy for the Climate Act is to electrify everything possible so load is going to increase at the same time the generating resources are changing. NYISO expects some new, large industrial customers that increase the expected load even more. Another complication is that peak load is expected to shift from summer to winter.
I have an overarching problem with the energy transition plan. The electric grid is an incredibly complex system best left to experts, but New York politicians and climate activists want to get involved. The hubris of the progressive wing of the Democratic majority in the New York State Legislature that they should get involved in power planning is blatant pandering to favored constituencies. The CRP explicitly calls out a newly passed law that mandates retirement of certain NYPA power plants in New York City but I have no doubts that the decision to retire those units should only be made by those organizations responsible for New York City reliability. If their concerns are over-ridden and there is a devastating blackout then they will be pilloried while the real responsible parties will escape retribution. It will be interesting to see if the adults in the room speak up and say enough is enough we cannot safely short-circuit the protections in place for the Climate Act.
Climate Act Misinformation: Cost Effectiveness Value of Societal Effects
I will admit that I am frequently triggered by the overt propaganda and misinformation peddled by the New York State Energy Research & Development Authority (NYSEDA). The volume of sales pitches and glowing descriptions of any component of the “clean energy” transition is remarkable, but the troubling lack of caveats and context is inappropriate. In addition, there is an overt campaign to disparage any disagreements with the narrative. This post addresses the claims made for the societal benefits of greenhouse gas emission reductions resulting from the Tier 4 renewable energy solicitationto support the petition for contract revisions by developers of four proposed offshore wind projects and 86 land-based renewable projects.
The NYSEDA Tier 4 renewable energy solicitation (“Tier 4 Solicitation”) awarded contracts for two transmission projects. Clean Path New York (CPNY) and the Champlain Hudson Power Express (CHPE) The projects are:
Expected to deliver 18 million megawatt-hours of clean energy per year to New York City, or more than a third of the City’s annual consumption. During their construction and operation, the projects are expected to generate close to $6 billion in overall net societal benefits statewide, inclusive of greenhouse gas reductions and air quality improvements, and over $8 billion in economic development, including investments in disadvantaged communities.
I only addressed the greenhouse gas reduction societal benefits because they are the largest component and they rely on an erroneous methodology. The post explains that the social cost of carbon purports to project the benefits of reducing GHG emissions today by calculating impacts on a variety of societal concerns. The key point is that it is based on the total benefits out to 2300 from a ton of emissions reduced today. The flaw is that New York guidance calculates the benefits over the lifetime of a project. This is akin to saying that because I lost five pounds ten years ago I can claim that I lost 50 pounds.
Using the flawed methodology the Public Service Commission Order Approving Contracts for Purchase of Tier 4 RECs claims that:”NYSERDA and Staff estimate that the combination of the CPNY and HQUS projects would provide a societal benefit of between $2.3 and $5.8 billion, using a net present value based on 2021 dollars.” Properly accounting for societal benefits just once I project the societal benefit is $0.53 billion which is ten times less than the higher societal benefit claimed.
A recent letter to the editor of the Syracuse Post-Standard posed the questions: I wonder why the citizens of our state must be the sole providers of electricity to Micron? Shouldn’t Micron at least share in producing electrical power? The author went on to make recommendations that are inconsistent with the energy density of wind and solar that relate to the viability of the venture. My post addressed the contents of the letter, the letter I submitted in response, and the inevitable tradeoff between competitiveness and aspirations.
Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing facility on 1,400 acres within five miles of my home. Consequently, I have been following this development closely. It would be a great opportunity of this area but I remain skeptical on the prospect that the energy intensive process can compete internationally when the Climate Act increases energy costs as I expect.
The author of the letter proposed that Micron install on-site wind, solar, and hydro so that Micron could share in the production of electrical power. The author has no clue that wind and solar are so energy sparse that covering the entire site with solar panels or wind turbines would provide less than 1% of the energy requirements which are projected to be on the order of the entire states of Vermont and New Hampshire. He also suggested that “hydro generators should be considered for the almost 40 miles of pipeline to and from Lake Ontario”. There are so many things wrong with the concept of hydro as a generating solution using water pumped up about 100’ from Lake Ontario that it was hard to know where to begin in the limited space I had for my rebuttal letter.
My letter agreed that Micron should contribute to providing on-site electric support for the facility but differently. Ellenbogen and I independently decided that co-generation would be the most appropriate on-site energy source. We believe a co-generation facility using natural gas or nuclear power is appropriate. The Ellenbogen presentation proposed allowing Micron Technologies to build a 2 GW combined cycle plant on their property. He points out that with generation on-site, the thermal energy could be used at the plant, and the 500 GWh of annual line loss will be eliminated.
The other point that I addressed in the post was the tradeoff between the aspirations of the Climate Act and the Micron sustainability pledges relative to the reality of energy cost pressures on global competitiveness. The tradeoff between sustainability absolutism, i.e., demanding nothing less than zero, with the extra costs associated with that approach versus the need to keep the Micron facility in New York competitive with the global chip market is an important substantive issue. On-site cogeneration with natural gas is the cheapest alternative for Micron energy requirements. Any other approach is going to increase costs and reduce competitiveness. For all the talk of jobs associated with the energy transition if the energy transition makes the Micron facility unable to compete on the world market, then there will be an enormous hit on jobs. What will the company and the Hochul Administration do when the cost difference becomes clear?
Articles of Note December 10, 2023
This post describes articles that I thought were interesting. Ed Ireland describes the importance of frequency to the gird and the problems associated with wind and solar. Terry Etam recently described a training program open to those who have left prison and wish to be trained as automotive technicians. He explains that this is a pragmatic solution to a problem that has relevance to the Climate Act – insisting on going to zero has downsides that could be avoided if New York could live with just making deep cuts in emissions. I quote a couple of articles about the COP-28 climate extravaganza currently underway. There are also links to an article about lessons from Ontario and temperature trend data.
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Roger Caiazza
Pragmatic Environmentalist of New York
NYpragmaticenvironmentalist@gmail.com
315.529.6711