CLIMATE LAW IMPLEMENTATION TO BE DELAYED OR WATERED DOWN? by Philip Gillemot

Multiple state organizations reported in July 2024 that New York will likely miss a key deadline in the landmark 2019 Climate Leadership and Community Protection Act (CLCPA). Multiple business groups, according to WaterFront have since lobbied Gov. Kathy Hochul to defer or water down the law’s key mandates. Gov. Hochul seemed to be receptive to their efforts. “The costs have gone up so much I now have to say, ‘What is the cost on the typical New York family?’” the governor stated in a July 18 TV interview. “The goals are still worthy. But we have to think about the collateral damage of these decisions. Either mitigate them or rethink them.”

The CLCPA mandates significant decreases in the state’s greenhouse gas emissions that fuel climate change. For example, it requires that the state obtain 70 percent of its electricity from renewable energy sources by 2030; and by 2040 the statewide electrical demand system must be zero emissions.

According to a Draft Clean Energy Review from NYSERDA (New York State Energy Research and Development Agency) released on July 1, "The 70% target envisioned by the CLCPA is extraordinarily ambitious and has subsequently been rendered even more ambitious by the combination of deployment headwinds and load growth tailwinds. The Commission, NYSERDA, and the State as a whole have undertaken an unprecedented mobilization of procurement, permitting reform, workforce development, and complementary actions to drive progress toward the 70% goal. While (NYSERDA's) analysis concludes that a delay in achieving the 70% goal may be unavoidable, the path set out in this Report involves a combination of actions that are realistically achievable and designed to reach the 70% goal as rapidly and cost effectively as possible." 

The Draft Review went on to state that, "Since .... the passage of the CLCPA, and as of October 2023, NYS has awarded more than 170 large-scale renewable projects representing nearly 20,000 megawatts (MW), which if built would reflect more than $55 billion in project investment and add thousands of jobs to the 171,000 jobs already represented in New York’s clean energy sector in 2022. However, on June 7, 2023, the Alliance for Clean Energy New York, Sunrise Wind, and Empire Offshore Wind/Beacon Wind filed separate petitions collectively asking the Commission to authorize NYSERDA to amend existing contracts for 86 land-based large scale renewable projects and four offshore wind projects outside of the competitive process. The petitions argued that the projects had been exposed to unprecedented global and regional supply chain bottlenecks, high inflation, and increases in the cost of capital, driven by rising interest rates. In addition, the petitions identified impacts associated with the war in Ukraine, including increased global demand for renewable energy and resulting shortages and price increases for key components and equipment.” 

The Public Service Commission subsequently canceled contracts associated with 88 projects. Then NYSERDA launched new expedited competitive solicitations for both the Tier 1 (land-based) and Offshore Wind programs to seek new contracts.  The results of this expedited solicitation, announced on April 29, 2024, included provisional awards for 24 solar and wind projects, amounting to more than 2.4 gigawatts (GW) of new renewable energy capacity. 

The Draft Review also stated:

-Regarding the projected need of clean energy to meet the 70% goal, it assumes a 30% attrition rate for already contracted and yet to be procured energy projects. Under the forecast for the 2030 statewide electric load, there is a renewable energy supply deficit of 42,145 GWh that would have to be addressed through future procurements in order to reach the 70% goal amount of 115,437 GWh.

-That to fill the expected gap, three Tier 1 annual solicitations – those for 2024, 2025, and 2026 – are currently scheduled and will seek projects capable of deploying by 2030. However, the amounts procured in these solicitations would need to be tripled to secure the needed quantity of 42,145 GWh. The Report also stated that, "the amounts of Tier 1 project deployment that would be needed in order to achieve the 70% goal in 2030 may far exceed what the renewables industry could be expected to develop in this time frame."

-That NYSERDA carry out further proposals for an increase in distributed generation systems (renewable energy sources, including small hydrobiomassbiogassolar powerwind power, and geothermal power) beyond the current goal of 10 GW by 2030. According to Wikipedia, distributed generation systems are decentralized, modular, and more flexible technologies that are located close to the load they serve, albeit having capacities of only 10 megawatts (MW) or less. 

-That electrical transmission constraints and interconnection costs contribute to the loss of electrical generation projects. To meet the CLCPA goals, transmission infrastructure needs to be in place in a time frame that supports the interconnection of the electrical generation projects.

The Report suggests obtaining authority to extend its allowed time frame for another three years to procure clean energy generation and distribution infrastructure. 

According to a separate report of an audit released also in July by State Controller Thomas DiNapoli, when the Clean Energy Standard (CES) and CLCPA were passed, no State or federal funding was budgeted. Currently, almost all funding to support the CES and Climate Act programs is ratepayer based. New York State ratepayers contributed almost $2.6 billion to the CES program from 2016 through 2021.

The Controller's report stated that, "the PSC is using outdated data, and, at times, incorrect calculations, for planning purposes and has not started to address all current and emerging issues that could significantly increase electricity demand and lower projected generation, such as increased push to transition to electric vehicles by 2035 and the cancellation or delay in renewable energy projects. Between 2005 and April 2023 12% of contracted large-scale renewable projects were cancelled." However, my reading of the NYSERDA report did seem to include the issues that could increase demand for electricity and cancellation or delay in renewable energy projects. The Controller's report was published just two weeks after NYSERDA's.

Furthermore, DiNapoli stated that, "The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated. Moreover, funding sources to cover these costs have not been identified, leaving the ratepayers as the primary source of funding. The lack of alternative funding sources adds additional risk to whether the State can meet its goals timely. Data shows utility costs have already risen sharply over the last two decades and more New Yorkers are having difficulty paying their utility bills."

The Audit Report recommended that the state conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet the CLCPA's goals and assess the extent to which ratepayers can reasonably assume the responsibility for covering its costs and to identify alternative funding sources.

I note that neither report discussed the large sums available for renewable energy goals from the federal Inflation Reduction Act and the federal Infrastructure Act.

Later in July, the New York Independent System Operator (NYISO), which runs the state’s electric grid, warned of projected inadequate electrical supplies in the 2030's.

It was reported on July 30 that The Business Council of New York sent a letter signed by 60 businesses to Gov. Hochul in part stating that they were, "increasingly concerned about the achievability of key CPCPA mandates and what that means for the future reliability and cost of the state’s energy system...While program costs are a growing concern, this isn’t just about costs.  It is also about the practical achievability of key CLCPA provisions and the consequences of basing major policy decisions on unworkable statutory mandates. (My bolding) We are not opposing further state investments in emission reductions, renewable generation, and energy efficiency, nor are we opposing the adoption of a “cap and invest” program. However, the state needs to ensure that its push toward emission reductions and the electrification of major sectors are technically and economically achievable. Responding to climate change is critically important and poses highly complex policy decision.  The Department of Environmental Conservation and NYSERDA have done a great job to assure stakeholder input into their program development, and we appreciate their efforts to make new programs as workable and cost-effective as possible. But we are now at a point where implementation challenges call for a reassessment of the underlying statutory mandates." (My bolding)

State Sen. Tom O'Mara in a column posted in late July in The Odessa File stated that, "...the drumbeats of doubt have continued to grow louder throughout the past few weeks as reality sets in over the ongoing, utopian plan by Albany Democrats to impose sweeping clean energy mandates upon all New Yorkers...to impose one of the world's most radical climate agendas on every citizen..." He went on to state that, "If that answer is nil (that the CLCPA won't make a difference on climate change), we should focus our resources toward resiliency on the effects of climate change." He proceeded to call for a cost-benefit analysis for the CLCPA and other climate mandates. He also posted a comment from Upstate United Executive Director Justin Wilcox to, "reiterate our calls to pause the implementation of the ...CLCPA until critical issues are addressed." (My bolding) O'Mara went on to state that energy bills are increasing (which we all know) and that, "The current strategy is not realistic or achievable." Note that in 2019 that O'Mara and all of the other nine Republican Finger Lakes area state senators and assemblymen voted against the adoption of the CLCPA, according to WaterFront. 

So we see that business and climate change-denying entities are now calling to stop or water down critical elements of the CLCPA due to various arguments of dubious value. Overriding points to know are that:

1) Earth's atmosphere has been heating up and breaking heat records for decades.

2) Carbon dioxide and methane produced by human-caused burning and use of fossil fuels such as coal, oil, gasoline, and natural gas is provoking this global warming.

3) This warming is causing increasingly severe changes in the climate world-wide, such as droughts, fires, floods, loss of coastal lands, landslides, desertification, melting of glaciers and Arctic and Antarctic ice, stressing and threatening wildlife on the land, in the seas, and in the air, crop losses and failures, economic degradation, and massive migration.

4) Scientific consensus urgently tells us that we must very quickly transition away from fossil fuels to clean energy sources to prevent the worst effects of climate change. 

In 2019 the Special Report on Global Warming of 1.5ºC was approved by the Intergovernmental Panel on Climate Change (IPCC) of the United Nations.  The IPCC is the UN body for assessing the science related to climate change. The IPCC assesses the thousands of scientific papers published each year to tell policymakers what we know and don’t know about the risks related to climate change. The IPCC identifies where there is agreement in the scientific community, where there are differences of opinion, and where further research is needed. To produce its reports, the IPCC mobilizes hundreds of scientists. These scientists and officials are drawn from diverse backgrounds.

The Global Warming Report Found

-That a number of climate change impacts that could be avoided by limiting global warming to 1.5ºC compared to 2ºC, or more. The likelihood of the Arctic Ocean free of sea ice in summer would be once per century with global warming of 1.5°C, compared with at least once per decade with 2°C. Coral reefs would decline by 70-90 percent with global warming of 1.5°C, whereas virtually all (> 99 percent) would be lost with 2ºC.

-That warming of 1.5ºC or higher increases the risk associated with long-lasting or irreversible changes, such as the loss of some ecosystems. 

-That limiting global warming to 1.5°C would require “rapid and far-reaching” transitions in land, energy, industry, buildings, transport, and cities. Global net human-caused emissions of carbon dioxide (CO2) would need to fall by about 45 percent from 2010 levels by 2030, reaching ‘net zero’ around 2050. This means that any remaining emissions would need to be balanced by removing CO2 from the air.

-That, “Limiting warming to 1.5ºC is possible within the laws of chemistry and physics but doing so would require unprecedented changes,” said Jim Skea, Co-Chair of IPCC Working Group III.

-That allowing the global temperature to temporarily exceed or ‘overshoot’ 1.5ºC would mean a greater reliance on techniques that remove CO2 from the air to return global temperature to below 1.5ºC by 2100. The effectiveness of such techniques is unproven at large scale, and some may carry significant risks for sustainable development.

-That limiting global warming to 1.5°C compared with 2°C would reduce challenging impacts on ecosystems, human health and well-being, making it easier to achieve the United Nations Sustainable Development Goals.

Robert Howarth, a climate research scientist at Cornell University, recently stated according to WaterFront, “I am appalled at this pushback against the CLCPA by business interests pushing their short-sighted agenda. Climate change is very real. The consequences of climate disruption (floods, droughts, fires, crop failures) are becoming increasing obvious to all. The political leaders of NY understood these dangers when they drafted the CLCPA and its predecessor beginning in 2015…. Due to political delay, we may miss CLCPA targets by a few years.  But the needed trajectory remains clear.” Howarth is a member of the state’s Climate Action Council which passed a plan to implement CLCPA in December 2022. The council had determined that “it was entirely possible and reasonable to meet the CLCPA goals and targets … that would benefit individual homeowners."

“The passage of time does not change the law, and it doesn’t make the climate crisis magically disappear,” state Sen. Liz Krueger, chair of the Senate Finance Committee, posted on X (formerly Twitter) after Hochul’s TV interview was aired July 18. “We are dangerously behind on the science-based mandates in CLCPA. It’s time to redouble our efforts, and build a more affordable, healthier, livable future for New Yorkers.”

Gov. Kathy Hochul will convene an energy summit in Syracuse on September 4 and 5 with state officials and business leaders to discuss reaching New York’s self-mandated climate goals (or is it to cut back on the goals and delay the mandates)? Gov. Hochul is concerned about the cost of the transition to clean energy in New York, but what about the cost of continuing with a fossil fuel- based energy system? How can our state, county and planet live and thrive with increasingly elevated temperatures and with the resultant disastrous effects on our homes, businesses, agricultural systems, communities, and economies? Should it not be our task in light of these threats to find ways to meet our goals in whatever ways we can? In 1961 when our country set the lofty goal to put a man on the moon by the end of the decade, we mobilized and met that historic goal. That time we didn't have a figurative gun held to our head if we failed, but this time we all suffer the rage of a polluted environment that will cause death and destruction if we don't succeed and succeed in time.