Pragmatic Environmentalist of New York Summary Update November 4, 2024 – November 17, 2024 - Highlighted Article

From: Roger's Substack

By: Roger Caiazza

Date: November 18, 2024

Pragmatic Environmentalist of New York Summary Update November 4, 2024 – November 17, 2024

Four articles all document planning problems associated with NY's net-zero transition

This is my fortnightly summary update of 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).  A pdf copy of the following information and previous summaries are also available.  The opinions expressed in these articles do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

DPS Definitions for Establishment of a Renewable Energy Program

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Act is the lack of a plan, and four articles addressed that concern.  The first points out that a plan for the Climate Act would include things like fundamental definitions.  Amazingly while there is a mandate that all electricity must be generated by “zero-emissions” resources by 2040, “zero emissions” hasn’t been defined until now.  On November 4, 2024, the Department of Public Service (DPS) staff finally proposed this definition.

The Staff Proposal definition states: The Commission’s interpretation of this term will lay the foundation for decisions about planning, investments, and more in the run-up to 2040.”  This is an admission that there is no foundation for the current planning process.  Some of the aspects of the definition are more important than others.  My post concentrated on the question whether non-greenhouse gas emissions were also required to be zero.  Practically speaking the issue was related to the use of hydrogen which is the recommended zero-emissions fuel technology for hard to convert sectors and the place holder for the new Dispatchable Emissions-Free Resource (DEFR) that the Integration Analysis argues is necessary.  Everyone agrees that compliant hydrogen should not be produced with fossil fuels, but the question was whether the hydrogen had to be used in fuel cells so that the only emission was water or whether it could be burned to produce energy.  I am sure that the ideologues are having fits over the proposed definition:

Staff recommends that the Commission interpret “zero emissions” to refer to greenhouse gases only and not to emissions of other air pollutants.

In my opinion the support cited for this interpretation was strong and I think that it is a pragmatic approach.  It will be hard enough and expensive enough to produce hydrogen for the uses proposed without adding to the challenge by insisting that it be used in fuel cells.  I expect that the ideological environmentalist organizations will disagree, vehemently.

I noted that the they have finally provided a fundamental definition. The law mandated that a program be established by 6/30/2021 to meet the targets.  The fact that the terms crucial to the development of an implementation plan were defined 28 months after the program was supposed to be established epitomizes the lack of planning throughout the Hochul Administration’s implementation of the Climate Act. (continue reading)

Pragmatic Environmentalist of New York Summary Update November 4, 2024 – November 17, 2024