Why it is important to comment on the Climate Action Council’s Draft Scoping Plan

The Plan being considered will be turned into regulations that will impact how we travel, how we heat our homes, how our electricity is generated and if we will have enough electricity to meet our needs (and much more).  Rural voices are needed!

Background on the Draft Scoping Plan

The Climate Act

The Climate Act (the Act) that went into effect on January 1, 2020, is a State law that mandates that New York meet certain greenhouse gas goals and net zero emissions by 2050. The Climate Act directed the creation of the Climate Action Council. A copy of the law can be found here.

The Climate Council

The Climate Council (the Council) is made up of the heads of state agencies and members who were appointed by the Legislature and then Governor Cuomo.   It was created to work on recommendations as to what the State needs to do to be sure that the greenhouse gas and renewable energy goals in the Climate Act become a reality. They wrote the Draft Scoping Plan.

The Draft Scoping Plan

The Draft Scoping Plan (the Plan), pulled together by the Climate Council, will be used to create an updated State Energy Plan and includes a transformation of the State electricity system, including both the technologies for generating electricity and the transmission infrastructure to deliver electricity to where it is needed. Currently, upstate has more electricity than it needs, and 90% of its electricity is already carbon emission free. Downstate (Westchester, NYC, Long Island) needs more electricity and only 3% currently is carbon emission free. But the transmission infrastructure is too congested to deliver upstate electricity downstate.

The Plan is incredibly complex with over 800 pages of documents including appendices plus multiple spreadsheets. Key assumptions are hidden deep in the voluminous appendixes and is not in a format that can be reviewed and digested easily by citizens.  The summary statements do not have any of the specifics that people need to get a sense as to what is coming.

The Plan will eventually be implemented as new regulations that will have sweeping impacts on every aspect of how we live in New York.  The transformation of the State electricity system is guided by the assumption that gasoline and natural gas will be phased out, along with the automobiles, building heating and air conditioning, and all other appliances that currently use fossil fuels. Adopting the recommendations as drafted represents a huge gamble for New York State. The goals are far more aggressive than any other state in the nation, or any other nation worldwide. The costs and unintended consequences cannot possibly be fully understood at this time. The model proposed for energy generation is highly dependent on sprawling land intensive intermittent large-scale wind and solar sources. The uncertainty of the future energy environment and related costs in NYS may well accelerate the loss of farmland and exodus of businesses and taxpayers.

Comment Period UNTIL JUNE 10

Massive social media pushes are occurring from various groups to get people to comment positively or negatively on the general statements in the Plan. SOS will provide details on several topics so that you can comment more specifically on some of the assumptions and details – or lack of details – in the plan.  This is our one opportunity to give input and without our comments these issues may not be given the attention that they need.

Final Scoping Plan + Update to State Energy Plan + DEC Regulations

Link to the Draft Scoping Plan document (18MB PDF) and how we have listed page references: The entire Draft Scoping Plan found at this link is an 18MB pdf with 861 pages; this includes the Plan and Appendices A-H. You will see references throughout our information which include the document (pdf) page number as well as the specific chapter or appendix page number (found at the bottom of each page).

The Final Scoping Plan will become Regulations

And they will impact all New Yorkers, our environment, and economy!

This Scoping Plan is the result of “goals” that the Climate Council want to turn into law.  The laws will lead to regulations that will impact all  New Yorkers. The two quotes below are examples of references to future regulations. These are found on document page 26 (Chapter 3, page 18).  (How to find page references)

GHG (Green House Gas) Emission Reduction Requirements

…Within four years of the effective date, the Climate Act requires DEC to promulgate regulations to ensure compliance with such statewide GHG emission limits.
(Added note:  the Climate Act went into effect on 1/1/2020)

 

Clean Energy Generation Requirements
…The Public Service Law provisions also codify previously existing ambitious clean energy goals, including a requirement for the procurement of at least 9,000 megawatts (MW) of offshore wind by 2035, 6,000 MW of distributed solar generation by 2025, and 3,000 MW of energy storage by 2030.

 

How to Write a Comment on the Draft Scoping Plan:

There are 9 issues listed below related to energy generation which we feel are most relevant to rural residents. By no means does this represent all the issues contained within the Plan which may be of interest or concern to you.

A summary of each issue and suggested comments are included for your consideration. Hold down your control key and click on any of the issues for a hyperlink to more specific information.

Link to the Draft Scoping Plan document and how we have listed page references: The entire Draft Scoping Plan found at this link is a pdf with 861 pages; this includes the Plan and Appendices A-H. You will see references throughout our information which include the document (pdf) page number as well as the specific chapter or appendix page number (found at the bottom of each page).

Consider writing on one or two of the topics or select your own. You are welcome to copy and paste anything included below.

TO SUBMIT COMMENTS (deadline June 10):

Comments may be submitted via email to scopingplan@nyserda.ny.gov, through the State’s online portal or via mail by using the form and address found at the portal link. The portal asks for the chapter of the Draft Scoping Plan when comments are submitted  so chapter references are listed next to each issue.

List of Issues and Suggested Comments to get you started…

Issue 1 (related to Chapter 5):  The Draft Scoping Plan is not forthcoming about unpopular or problematic aspects of what is being proposed.  For example, the 330-page, 24 chapter Draft Scoping Plan mentions “land-based wind” twice and does not reference any targets. These projects have proven to be highly unpopular and yet, along with large-scale solar, large-scale onshore wind is a foundational component of the draft Plan presented in the charts found in the appendices.

Suggested comment: The Plan should clearly designate the pros and cons with attention given to specific impacts to New Yorkers– both positive and negative. And that includes rural New Yorkers!  Citizens do not want a sales pitch; we want an explanation.  How will new energy generation upstate be delivered downstate? Is the environmental harm of large-scale renewable energy projects in pristine upstate environments worth the meager emissions reduction benefits? (Because the wind and sun are not constant, wind generates 30% of its capacity on average, solar 20%, and this results in the need for reliable gas-fired backup power plants to always be ready.) All presentations must be in non-technical language. Provide links to all the data with clear lists of what items are included in each calculation.  The Draft Scoping Plan is missing these elements and does not answer basic questions.


Issue 2 (related to Chapter 13 – Electricity):  The Plan includes 9.5-11 GW of land-based large-scale wind requiring up to 1.1 million acres of leased land which, given New York geography and population density, is beyond New York State citizens’ willingness to accept.  The more that these large-scale projects are built the harder it will be to site more of them as the “easy” locations are taken and the projects move closer to wilderness areas, wildlife management areas, parks, Native American lands and populated areas.  It is not reasonable to expect that towns must carve out 1.1 million acres to be industrialized for electricity generation.  This is the equivalent of 1700 square miles.

Suggested comment: It is unrealistic to rely upon this scale of wind power given the extensive land requirements and widespread opposition.


Issue 3 (related to Chapter 13 & Chapter 15 – Agriculture):  The Plan includes60-65 GW of solar which will require large-scale solar on agricultural land that is already less available due to other causes. An estimated 225,000 to 315,000 acres will be required to meet this goal in the coming years. Climate change is likely to increase the need for viable agricultural land.

Suggested comment: Most of the land for massive large-scale solar will come from active farmland, significantly reducing this important economic and societal resource at a time when local food sources are in great demand.


Issue 4 (related to Chapter 13):  The Scoping Plan is ignoring the land limitations and the impacts to rural communities that exist in its recommendation to site so many large-scale land intensive renewable projects in New York. The state plans to “educate” the public and provide economic incentives in hopes of gaining more support. These actions will not change the basic geographic limitations and the negative impacts to intangibles such as open space, quiet nights, and close community relationships that drive the opposition to large scale renewables.

Suggested comment: It is foolhardy to base an energy plan on intermittent renewable energy sources that may displace a significant number of rural residents.


Issue 5 (related to Chapter 13):  The Plan moves New York away from stable reliable energy generation. The Plan’s “scenarios” all have a gap in electricity generation during the winter that they propose to fill with currently unavailable but hoped-for future developments like green hydrogen or better batteries which would require even more wind and solar.  A plan without sufficient reliable power is not a reasonable plan. (If reliable nuclear power were part of the Plan, more large-scale renewables may not be needed to achieve the Climate Act’s targets.)

Suggested comment: The Plan must provide options for the possibility that New York does not meet its renewable energy targets, and must recommend technology that is in existence today, such as nuclear, for firm capacity. Hoping that something will be developed is not a reasonable plan.


Issue 6 (related to Chapter 8 – Public Health):  The Plan fails to adequately address the health problems with industrial wind noise and infrasound.

Suggested comment: The Plan acknowledges a negative health impact from wind turbine noise but does not acknowledge the immediate need for solutions to this problem.  The state Department of Health has determined that, in order to protect public health, more stringent noise standards than are being applied in state permitting proceedings are needed. Wind turbines generate over 100 decibels of noise in very quiet areas. It takes over a mile for that level of sound to degrade to tolerable levels.  The Plan must take into account the number of people potentially likely to be harmed by the 1.1 million acres of leased land projected for new wind projects and must include plans for reducing the noise impact on rural communities.


Issue 7 (related to Chapter 13 and Chapter 15 – Ag & Forestry):  The Plan does not address the glaring conflict between the need to preserve (and increase) carbon sequestration by New York’s lands and forests, and the clearing of lands and forests for land-based wind and industrial solar projects.  Existing permitted projects have cleared thousands of acres of forested land.  The new wind and solar projects proposed under this plan will require clearing tens of thousands more.

Suggested comment: It makes no sense to cut down mature forests to make room for wind and solar projects. But the demand for renewables is already causing this to happen.


Issue 8 (related to Chapter 13):  In Appendix G, the Plan acknowledges but does not highlight or include in the summaries the serious risks with the Plan’s proposed transformation of our energy systems.

Suggested comment: There has been a failure to clearly enumerate and highlight the risks of this extremely aggressive plan considering the use of unproven and controversial technologies and the requirement for massive tracts of land. The uncertainty associated with this risk puts the future of the state’s economy into question.


Issue 9 (related to Chapter 10 – Benefits): The economic cost for the state is three trillion dollars over the 28 years of the plan. It is not clear how this will be financed.

Suggested comment: This is an astounding amount of money to commit to this risky plan.


Issues, Suggested Comments and More Details

Issue 1 (related to Chapter 5):  We do not want a sales pitch
The Draft Scoping Plan is not forthcoming about unpopular or problematic aspects of what is being proposed.  For example, the 330-page, 24 chapter Draft Scoping Plan mentions “land-based wind” twice and does not reference any targets. These projects have proven to be highly unpopular and yet, along with large-scale solar, large-scale onshore wind is a foundational component of the draft Plan presented in the charts found in the appendices.

Suggested comment:
The Plan should clearly designate the pros and cons with attention given to specific impacts to New Yorkers– both positive and negative. And that includes rural New Yorkers!  Citizens do not want a sales pitch; we want an explanation.  How will new energy generation upstate be delivered downstate? Is the environmental harm of large-scale renewable energy projects in pristine upstate environments worth the meager emissions reduction benefits? (Because the wind and sun are not constant, wind generates 30% of its capacity on average, solar 20%, and this results in the need for reliable gas-fired backup power plants to always be ready.) All presentations must be in non-technical language. Provide links to all the data with clear lists of what items are included in each calculation.  The Draft Scoping Plan is missing these elements and does not answer basic questions.

More Details:
Why is large-scale wind not mentioned in the climate targets?   Land-based wind does not have a specified quantity enumerated.  It is the only renewable energy source that does not have a GW listed in the Climate Act.  Headlines and speeches do not mention large quantities of land-based wind projects.  And yet, industrial wind is a very large part of the Scoping Plan.  This fact is highly suspicious.  Land-based large-scale wind projects have been opposed in the last decades.  They are generally unpopular.  The Scoping Plan with its public involvement component has not made this unpopular portion of the plan apparent. This shows a lack of transparency and honesty that does not bode well for this massive statewide transformation.
See the list below from document page 27 (Chapter 3, page 17) with no mention of onshore wind:

New York’s Climate Directives

  • 85% Reduction in GHG Emissions by 2050
  • 100% Zero-Emission Electricity by 2040
  • 70% Renewable Energy by 2030
  • 9,000 MW of Offshore Wind by 2035
  • 3,000 MW of Energy Storage by 2030
  • 6,000 MW of Solar by 2025
  • 185 trillion Btu of end-use energy savings

Another example of a failure to mention of onshore wind can be found at document page 761 (Appendix G, Section I, Page 84-85):

Wind, water, and sunlight power most 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. 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. 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.

20 GW of offshore wind, 60 GW of solar, 20 GW of battery storage by 2050. These numbers are enormous but what about onshore wind?  How much does this plan contemplate?  The numbers are buried in the appendix.


Issue 2 (related to Chapter 13 – Electricity):  Land-based wind
The Plan includes 9.5-11 GW of land-based large-scale wind requiring up to 1.1 million acres of leased land which, given New York geography and population density, is beyond New York State citizens’ willingness to accept.  The more that these large-scale projects are built the harder it will be to site more of them as the “easy” locations are taken and the projects move closer to wilderness areas, wildlife management areas, parks, Native American lands and populated areas.  It is not reasonable to expect that towns must carve out 1.1 million acres to be industrialized for electricity generation.  This is the equivalent of 1700 square miles.

Suggested comment:
It is unrealistic to rely upon this scale of wind power given the extensive land requirements and widespread opposition.

More Details:
The amount of land-based large-scale wind is not found in the main portion of the Draft Scoping Plan document but is in Appendix G:
9.5-11 gigawatts (GW) of new land-based industrial wind generation capacity by 2050 – the equivalent of 9500-11000 megawatts (one GW equals 1000 MW).

Chart found at document page 722 (Appendix G, Section I, page 45)

The problem with this massive amount of industrial wind?  It is extremely land intensive. In addition to setbacks for safety and noise, turbines need to be spread out so they each have sufficient wind.  Each megawatt requires 80 to 100 acres or more.  This amount of land-based wind would require between 760,000 and 1,100,000 acres of land.  This will come from approximately 47-55 land-based industrial wind projects (assuming 200 megawatt projects) that would be built in 50-150 rural towns (assuming 1-3 towns per project).

In addition, there is a plan that New York State will import 6.4 GW of land-based industrial wind energy.  Given that some of our existing industrial wind energy “renewable energy credits” are being sold to other states so that they do not have to build their own, it is reasonable to ask where this substantial imported wind energy will come from and how the State can ensure the purchase of imported land-based industrial wind.


Issue 3 (related to Chapter 13 & Chapter 15 – Agriculture):  Large Scale Solar
The Plan includes 60-65 GW of solar which will require large-scale solar on agricultural land that is already less available due to other causes. An estimated 225,000 to 315,000 acres will be required to meet this goal in the coming years. Climate change is likely to increase the need for viable agricultural land.

Suggested comment:
Most of the land for massive large scale solar will come from active farmland, significantly reducing this important economic and societal resource at a time when local food sources are in great demand.

More Details:
The Draft Scoping Plan is not clear about how much of the 60-65 GW of solar will be from large-scale industrial solar projects. That is because many of the charts do not distinguish between distributed solar (generally located close to where it is used and often found on rooftops and businesses) and industrial solar.  However, the total number of 60-65 GW for all types of solar by 2050 is staggering.

There is a statewide goal of 10 GW of distributed solar by 2030.   If the State achieves 20 GW distributed solar by 2050, that leaves 45 GW of industrial solar, at 5-7 acres per MW requiring 225,000-315,000 acres of land for industrial solar. This equals 350-490 square miles of industrial solar projects.   (See https://s30428.pcdn.co/wp-content/uploads/sites/2/2022/01/NY-Smart-Solar-Siting-on-Farmland_FINAL-REPORT_1.31.22.pdf page 10, foot note 2 for solar acres needed per MW).  If each project is 200 MW, then we will need 225 solar projects to meet this goal.  One of the largest solar projects in the State is the Cider Solar project proposed in Genesee County.  It is a 500 MW industrial solar project that is planned to use about 3000 acres of farmland.
The cheapest location for industrial solar is farmland located near transmission lines.  New York lost a quarter million acres of farmland between 2001 and 2016 to development.  https://farmlandinfo.org/wp-content/uploads/sites/2/2022/01/NY-Smart-Solar-Siting-on-Farmland_FINAL-REPORT_1.31.22.pdf  page 8.    This quantity of large-scale solar will double the ongoing loss of agricultural land at a time when climate change is increasing the value of our agricultural region with plenty of water.
There is no effort in the Draft Scoping Plan to spread the land-intensive burden of these projects across the state.  There is a problematic regional impact as the developers will want land that is easily accessible to transmission lines leading to some counties with many industrial landscapes and a reduced percentage of farmland.  Due to the state Office of Renewable Energy Siting (ORES) “Uniform Standards and Conditions” these counties and the host towns will have almost no local ability to limit the number or size of the projects.   The Climate Council does not acknowledge the degree to which ORES has limited the participation of local governments and community groups in siting decisions.  The “Development Mapping” listed on document page 172 (Chapter 13, page 162) will be a waste of town resources as developers, particularly industrial wind developers, have financial reasons for siting decisions and little incentive to consider local concerns when planning a large-scale renewables project.


Issue 4 (related to Chapter 13):  Rural Communities
The Scoping Plan is ignoring the land limitations and the impacts to rural communities that exist in its recommendation to site so many large-scale land intensive renewable projects in New York. The state plans to “educate” the public and provide economic incentives in hopes of gaining more support. These actions will not change the basic geographic limitations and the negative impacts to intangibles such as open space, quiet nights, and close community relationships that drive the opposition to large-scale renewables.

Suggested comment:
It is foolhardy to base an energy plan on intermittent renewable energy sources that may displace a significant number of rural residents.

More Details:
Together land based wind and industrial solar would require up to 1.4 million acres of land to be industrialized and leased for electricity production. These will be large areas of the state changed from rural agricultural to rural industrial.   This does not include the extensive transmission systems that will be required.
One of the strategies listed on document page 164 (Chapter 13, page 154) is “Support Clean Energy Siting and Community Acceptance”. This includes public education as one component of this strategy.

The more that these large-scale projects are built the harder it will be to site more of them as the “easy” locations are taken and the projects move closer to wilderness areas, wildlife management areas, parks, Native American lands and populated areas.  It is not reasonable to expect that any amount of education will make it appear reasonable for towns to carve out 1.4 million acres to be industrialized for electricity generation.

Rural communities reject the stereotype that they are uninformed about climate change.  They reject the premise that a “statewide public education campaign to inform New Yorkers about the climate crisis” and the benefits of large-scale renewables will make industrialization of their communities acceptable.  We have been at the receiving end of developer tactics where negative impacts are downplayed and benefits are inflated to “sell” the project.  We have received through Freedom of Information Requests, documents that show how state agency employees have been influenced by developer lobbyists and have shown disregard for citizen concerns and for any information that is not acceptable to the developers.

To reach its renewable energy State mandate, New York State has created ORES to assure that any renewable energy developer that applies to the State for a permit will get a permit, although there may be some conditions included in the permit.  And the State through its discounting rate and formulas will determine how much money the town will receive to compensate for the industrialization of its town, for the noise, the lights, the loss of wildlife and all the comes with this industrial development.  And the ORES permitting process has been established to happen quickly with little time, and few procedures and few opportunities for a community to discover problems and raise them.  There will be no need for town cooperation.  The system is set to produce these projects rapidly without the blessing of the town or residents.  The recommendations for town and county planning and education serves only to distract from the reality of the system that excludes local government from any authority or choices.


Issue 5 (related to Chapter 13):  Gap in energy generation
The Plan moves New York away from stable reliable energy generation. The Plan’s “scenarios” all have a gap in electricity generation during the winter that they propose to fill with currently unavailable but hoped-for future developments like green hydrogen or better batteries which would require even more wind and solar.  A plan without sufficient reliable power is not a reasonable plan. (If reliable nuclear power were part of the Plan, more large-scale renewables may not be needed to achieve the Climate Act’s targets.)

Suggested comment:
The Plan must provide options for the possibility that New York does not meet its renewable energy targets, and must recommend technology that is in existence today, such as nuclear, for firm capacity. Hoping that something will be developed is not a reasonable plan.

More Details:
The Climate Action Council must not recommend the elimination of natural gas, a firm reliable electricity source without immediately replacing it with a system that is equally reliable.

Even in the unlikely event that the State can build out 1.4 million acres of electricity generation, under this Draft Scoping Plan the grid would still fail without substantial undeveloped baseload electricity generation.  The below quote and chart show a 21-27 GW Zero-Carbon Firm Resource need in pink.  This is a “yet to be developed” hydrogen generation method with a backup plan: future development of better batteries and overbuilding industrial wind and solar to fill those batteries.
“Wind and solar resources are foundational to New York’s decarbonization goals and provide over 75 percent of annual generation.”  See document page 724 (Appendix G, Section I, page 47).

“However, as indicated by the gray contributions in the weekly generation chart, there are also many weeks in the year – especially during the winter – in which the contributions from renewables and existing clean firm resources are not sufficient to meet demand. During cold weeks, as a result of the electrification of building heating needs, electric demand will be much higher in the winter than it is today. Winter months also often coincide with extended periods of low renewable output. During a week with persistently low solar and wind generation, additional firm zero-carbon resources, beyond the contributions of existing nuclear and hydro, are needed to avoid a significant shortfall; Figure 34 demonstrates the system needs during this type of week.”  See document page 726 (Appendix G, Section I, page 49).

Gray indicates electricity need that will not be met without some form of additional “firm capacity”.  It may be hard to see in the lower chart but there are only 11 weeks that show no gray at the top of the column indicating that extra firm capacity is not needed.  For most of the year all the Draft Scoping Plan scenarios have a shortfall where the State does not know how it will provide for energy needs.

The system of renewables that is laid out in the Draft Scoping Plan as a very large deficit that must be filled with some form of firm capacity and right now the only zero emissions option for this quantity of generation is nuclear.

This firm capacity can be placed on the bottom of the above chart (along with existing nuclear and hydro) and it can provide energy to make up for the intermittent renewables.  It will also reduce the overall need for intermittent renewables, saving precious land for agriculture and forests and reducing the need for sprawling electricity generation.


Issue 6 (related to Chapter 8 – Public Health):  Industrial wind noise
The Plan fails to adequately address the health problems with industrial wind noise and infrasound.

Suggested comment:
The Plan acknowledges a negative health impact from wind turbine noise but does not acknowledge the immediate need for solutions to this problem.  The state Department of Health has determined that, in order to protect public health, more stringent noise standards than are being applied in state permitting proceedings are needed. Wind turbines generate over 100 decibels of noise in very quiet areas. It takes over a mile for that level of sound to degrade to tolerable levels.  The Plan must take into account the number of people potentially likely to be harmed by the 1.1 million acres of leased land projected for new wind projects and must include plans for reducing the noise impact on rural communities.

More Details:
Chapter 8 Public Health of the Draft Scoping Plan acknowledges that onshore wind energy will be “increasingly adopted” and that there are unique health impacts caused by industrial wind turbine noise that will need to be dealt with at some future date “as scientific understanding evolves”.

On document page 70 (Chapter 8, page 60), the Draft Scoping Plan spends one paragraph defining annoyance as a negative health effect from the industrial wind turbine noise:
Health concerns associated with onshore generation of wind energy are limited. Physical safety concerns can be mitigated through the choice of appropriate minimum setbacks (the minimum allowable distances between turbines and roads, property lines, or structures). Annoyance, associated with wind turbines producing characteristic sounds or noise as wind passes over the rotating blades, is a health effect according to the Environmental Noise Guidelines for the European Region, published by the World Health Organization in 2018. Data indicates that noise from wind turbines may be more noticeable, annoying, and disturbing than other community or industrial sounds of the same level. Reviewing acceptable noise thresholds for wind turbine siting as scientific understanding evolves will be important as onshore wind energy is increasingly adopted.

This paragraph is insufficient to address the concerns and the impact of 1.1 million acres of industrialized noise spread across the state.  Save Ontario Shores submitted substantial details of the insufficiency of the ORES noise regulations for large scale renewable projects.  The evidence was not considered.  The regulations were written by developer consultants and were unchanged despite documented deficiencies.  This will become a growing problem as these projects are forced into more and more communities.

Issue 7 (related to Chapter 13 and Chapter 15 – Ag & Forestry):  Conflict between industrial renewables and forest preservation.
The Plan does not address the glaring conflict between the need to preserve (and increase) carbon sequestration by New York’s lands and forests, and the clearing of lands and forests for land-based wind and industrial solar projects.  Existing permitted projects have cleared thousands of acres of forested land.  The new wind and solar projects proposed under this plan will require clearing tens of thousands more.
Suggested comment: It makes no sense to cut down mature forests to make room for wind and solar projects. But the demand for renewables is already causing this to happen.

More Details:

Chapter 5.3 lists the following strategies (among other items):

  1. Electrification in buildings and transportation
  2. Zero emissions electricity
  3. Maximizing carbon sequestration in New York’s lands and forests

See document page 41 (Chapter 5, page 31).

  1. 1. One major component of the plan is to electrify energy use by eliminating natural gas and gasoline. This means that electricity will provide the energy to heat homes, operate vehicles, and run all the appliances now operated by gas.  These efforts will double the electricity needs of New York State in the next decades.
  2. The second component of the plan is to have 75% of this electricity generated by wind and solar projects.  Some of the wind projects will be offshore and some of the solar projects will be on rooftops.  However, the increase in electricity use is going to be so great that the plan relies for much of its energy on land intensive wind and solar projects.
  3. An additional strategy is to stabilize and increase forested land in the State to provide carbon storage in the land and trees.  Yet the high need for land for renewable energy generation will conflict with this effort.  The already permitted Alle-Catt Wind project will result in the deforestation of 1500 acres.  And there are many projects that have been permitted in recent years that are adding to this amount.  And yet the Draft Scoping Plan recommends generation that will require two hundred fifty 200 MW solar and fifty 200 MW wind projects or a larger number of smaller projects.  This will create an enormous pressure for land.

The scoping plan fails admit or manage the conflict between setting aside forests for carbon storage and clearcutting for the transmission lines, utility scale wind and solar projects and their associated roads and transmission lines.


Issue 8 (related to Chapter 13):  Substantial risks
In Appendix G, the Plan acknowledges but does not highlight or include in the summaries the serious risks with the Plan’s proposed transformation of our energy systems.
Suggested comment:
There has been a failure to clearly enumerate and highlight the risks of this extremely aggressive plan considering the use of unproven and controversial technologies and the requirement for massive tracts of land. The uncertainty associated with this risk puts the future of the state’s economy into question.

More Details:
The below quote is buried in Appendix G on document page 762 (Appendix G, Section I, page 85).  It lists the very serious risks in the Draft Plan.
Although benefits and costs are in the same range across mitigation scenarios, risk levels differ by scenario. Although all scenarios involve a high degree of transformation across strategies and sectors, very high levels of transformation increase risk of delivering GHG emission reductions. Types of risk include reliance on technologies in early stages of development which require
substantial innovation (e.g., negative emission technologies, carbon capture and storage, advanced low-carbon fuels), reliance on widespread adoption of technologies that are in the early stages of deployment (e.g., zero-emission vehicles, heat pumps), and reliance on strategies that require the highest levels of transformation of social institutions and business models (e.g., land use patterns, mobility practices, waste management).

What is the backup plan if technology does not develop in a timely fashion or world tensions reduce needed raw materials?  What is the back up plan if residents fail to accept the industrialization of over one million acres in small towns across the State?

There are options.  Nuclear is one of them.  Failing to seriously review substantial investment in nuclear energy is an error in this plan.


Issue 9 (related to Chapter 10 – Benefits): Costs
The economic cost for the state is three trillion dollars over the 28 years of the plan. It is not clear how this will be financed.

Suggested comment:
This is an astounding amount of money to commit to this risky plan.

More Details:
Chapter 10 is entitled “Benefits of the Plan”.  It is a chapter about costs and benefits.   Yet the word “costs” did not even make it into the chapter title.  That is a precursor of what is to come.  The discussion of costs and benefits, which is on everyone’s mind, is not presented in a clear manner that enables residents to review and comment.

The chapter uses the Integration Analysis Benefit-Cost Approach and the financial data can be found in Appendix G:  Integration Analysis Technical Supplement, Section I, Chapter 4, Key Findings, Page 84 (document page 761)

The economic cost for the state is three trillion dollars over the 28 years of the plan.  This cost includes the 2.7 trillion dollar cost of the “reference” case number “1” plus the additional $290-$310 million in costs for case numbers 2-4 which are assumed to be in addition to number 1.  It is not clear how much of this is for new items and how much is a replacement for costs that we currently have for appliances cars etc.  There is not much that is clear about the cost description for people who are not accountants or economists.

Some points of reference can help give a sense of the magnitude of the 3 trillion dollar cost:

  • Divided across the 28 years the amount is 107 billion dollars per year.
  • The New York State Budget for 2019-2020 was 175 billion dollars.  https://www.osc.state.ny.us/files/reports/budget/pdf/budget-enacted-2019-20.pdf (see page 4, second paragraph)
  • New York State population is about 19.9 million.  107 billion divided into the population is about $5400 dollars per person annually.
    107 billion is about 6% of the 2019 State GDP.However, the costs will not be spread out evenly.  They will be lower at the beginning of the 28 year period and ramp up as we get closer to 2050, leaving our grandchildren with a huge financial burden as can be seen in the tripling costs between 2030 and 2050 in the below figure found on document page 745 (Appendix G, Section I, page 68):

The financial data is not presented in an accessible manner to citizens.  It does not clarify what are government expenses and what are citizen and business expenses.
The financial data focuses on three scenarios that in many respects are not that different.  Focusing on the differences in these three scenarios distracts from the details of the reference scenario that includes most of the costs.  Many reasonable questions go unanswered.
What is the range of costs for the State government?
How will costs impact education and local governments?
What is the plan to manage escalating electricity and fuel costs as this plan is implemented?
What are the costs for individuals and households?
What are the costs for small and large landlords?  How will this impact rents and the housing market and what will be done to keep both affordable?
What are the costs for agriculture, manufacturing, businesses?
We want low and high ranges on an annual basis for each of these categories.
Who will pay the costs?  How will they pay?  Higher electricity bills? Higher taxes?  Higher cost of appliances, vehicles etc.?  How will this impact other prices, such as food? Will they be paid for with subsidies? Where will the subsidy funds come from?
How will the rising cost of energy prices be managed as the number of natural gas customers is reduced?  Those who do not purchase newer equipment will likely be lower income families. As only a small number of gas customers remain will their costs spike?
What is the cost of making all gas appliances obsolete?
What is the cost of replacing appliances and cars before the end of their useful life? What are the disposal/waste impacts?
Has the cost for replacing the electric car battery every 100,000 miles been factored?
Have the impacts to the used car market been factored?
There is a carbon tax. Where will that money go?  Why is the money from that tax not given back to taxpayers to assist with the costs of transition?

 

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