€¦ · web vieweach page of this file contains one excerpt from the energy plan with commentary...

EACH PAGE OF THIS FILE CONTAINS ONE EXCERPT FROM THE ENERGY PLAN WITH COMMENTARY ON THE FOLLOWING SUGGESTED THEMES. CHOOSE, MIX AND MATCH, USE THE LANGUAGE IF USEFUL.

1. Natural gas may not be abundant or recoverable: Planning for gas as the primary fuel is a mistake

2. It is a mistake to base energy policy on the assumption that natural gas prices will remain low.

3. Invest in electricity-transmission and grid upgrades now to achieve the necessary reliability and efficiency rather than investing in expensive and unnecessary new or repowered plants.

4. Reliance on natural gas as the “backbone of the energy system” brings us the real threat of fracking for gas in our state.

5. Allowing gas-drilling trucks on NY roads would cause fatal damage to our aging transportation infrastructure.

6. Accelerating build-out of gas infrastructure will contribute to climate change. Any energy choice that puts more GHG emissions into the atmosphere is unacceptably damaging to global livability and as such, an unacceptably expensive energy choice.

7. The cost of using more gas should include a metric to assess costs incurred because of climate change, not just prices paid by customers.

8. Increased use of natural gas leads to increased methane in the atmosphere. This is dangerous for the global climate. The New York Draft Energy Plan does not adequately take into account the problem of methane or stress the need for State agencies to measure and prevent methane emissions

9. Ignoring the addition of methane to the atmosphere by burning increased amounts of natural gas, the Plan falsely claims that NY will reduce green house gas emissions by 80%.

10. Energy efficiency evaluation and labeling of buildings is a good idea but low income home owners need more help to achieve acceptable ratings.

11. The Plan reviews many good ideas for encouraging energy efficiency and conservation, but it lacks articulation and implementation strategies..

12. Volume one of the Plan is profoundly misleading, foregrounding the implicit impression that NY is planning to move strongly in the direction of renewable energy. The nuts and bolts of the Plan in Volume 2 do not support this claim.

NY Draft Energy Plan excerpts with theme and commentary: Please use in commentingExcerpts in straight print, commentary in bold italics by Judy Pierpont

13. Not enough emphasis on increasing renewable energy sources.

14.New York is not on track to meet its goals for renewable energy production.

15. Emphasis of new energy tech is on growing the economy rather than on deploying it for energy generation and conservation.


1. Theme: Natural gas may not be abundant or recoverable: Planning for gas as the primary fuel is a mistake.

Vol. 2 End Use Energy[p. 55] The Potential Study evaluates the opportunities for end-use energy efficiency technologies in the context of natural gas commodity prices that are projected to remain relatively low for the foreseeable future due to expanded supplies and improved recovery technologies.

Recent studies are showing that new natural gas sources are not really as abundant as predicted. There is mounting evidence that wells decline more rapidly than was anticipated and that there are more dry wells and fewer sweet spots than anticipated. It is entirely possible that the abundance of gas will prove to be short-lived. Prices may soar once again. Investing our future in gas infrastructure is economically risky.


2. Theme: It is a mistake to base energy policy on the assumption that natural gas prices will remain low.

Vol. 2 End Use Energy

Table 16B on p. 35 compares the projected cost of crude oil and natural gas in 2030: $23.66 MMBtu v. $6.49 MMBtu [million British thermal units]. Although the projections forecast a 3.2% rise in the cost of gas over the 18 years between 2012 and 2030, this cost is projected to be much, much cheaper than oil. The assumption that gas will remain cheap is obviously the reason for developing a plan based on gas. The plan makers have based their predictions on data from the Energy Information Agency, presumably based on historical trends and predictions of recoverable gas.

On p. 55, the Plan cites a “Potential Study” undertaken in the planning process. It assumes that there will be “expanded supplies” and “improved recovery technologies” (horizontal fracking), and that prices will remain low because of these things.

[p. 55] The Potential Study evaluates the opportunities for end-use energy efficiency technologies in the context of natural gas commodity prices that are projected to remain relatively low for the foreseeable future due to expanded supplies and improved recovery technologies. Natural gas commodity prices have a significant impact on both the price of natural gas used on-site by customers for such uses as space heating, and the price of electricity that is centrally generated but delivered by wires for use by individual customers.

It is a mistake to assume that gas prices will remain low. Gas prices are notoriously fickle. We’ve seen huge price swings in gas prices in just a few years. A year ago, prices were below $2.00 and now they are already close to $5.00. To bring the price up, gas companies are intent on exporting gas abroad; there are currently 33 permit applications in with FERC to do just this. If only a few of the export facilities are built, the domestic supply of gas will plummet and the price will spike. Then we will be stuck with an uneconomic fuel and over-built gas infrastructure. Ratepayers will bear the brunt of the cost and we will have lost the opportunity to move quickly to renewable fuels.


3. Theme: Invest in electricity-transmission and grid upgrades now to achieve the necessary reliability and efficiency rather than investing in expensive and unnecessary new or repowered plants.

Vol. 1, [p. 31]Today’s electric systems are designed with assurances to provide reliable service during peak periods, such as the few days of extremely hot temperatures per year. However, the current design and strategy result in low utilization factors and high energy costs. A new strategy of investing in cost-effective smart grid solutions and focusing on active demand management will enable improved utilization of new and existing assets, reduced energy costs, and continued reliability.

It is really critical to transition the electric system to grid solutions and demand management before any new power plants are built or old ones converted to gas burning. The problem outlined is exactly the one that is faced by Cayuga Operating Company in Lansing. The plant is needed, supposedly, to provide reliable service during 500 hours per year of peak need. Meanwhile, keeping it on line results in low utilization and high inefficiency. The new strategy suggested here would be sensible. It would get it off-line as soon as the transmission lines and grid are upgraded to provide necessary reliability, or Nucor in Auburn accepts demand-management agreements.

But this is NOT the strategy that the PSC or the governor seems to be following. They are undermining the goal of working towards efficiency and affordability of electricity for ratepayers. Specifically, in December, Gov. Cuomo decreed that the coal-burning plant in Dunkirk with problems similar to those of Cayuga be repowered with natural gas. Ratepayers will foot the conversion bill for a private corporation and be stuck with gas-powered electricity for decades, perhaps bearing the risk of high-priced gas.

Investing in the expensive and long-term infrastructure of gas powering will move us away from making the sensible smart-grid solutions outlined here that will lead to less need for more big power plants. The plants being repowered with gas now will be producing excess power. (In fact the independent power producers have already said there is too much power for them to stay in business if state-supported plants come on line.) If gas stays cheap, burning it will diminish the incentive to develop renewables. If it increases in price, which is likely, ratepayers will be left to pick up the tab on another uneconomic fossil fuel and useless plants they paid for.

Not to mention the foray into fracked gas that will be required in New York, whether it is extracted here or in PA.

Here in the Draft Energy Plan, there is recognition of how this problem of reliability should be addressed—through grid improvements and agreements with big users to reduce demand during peak-need hours, but what is actually being done right now—keeping inefficient plants burning and/or converting them to gas-- is undermining the


energy future that is envisioned. It’s a chimera.


4. Theme: Reliance on natural gas as the “backbone of the energy system” brings us the real threat of fracking for gas in our state.

See Volume 2,Sources, pp. 65-134, The Natural Gas Report

The Plan details the many new pipelines slated to deliver shale gas from other states or, if permitted, extracted in this state. See Vol. 2, Sources pp. 101-109


5. Theme: Allowing gas-drilling trucks on NY roads would cause fatal damage to our aging transportation infrastructure.

Vol. 2 End Use Energy[p. 76]New York’s transportation infrastructure is among the nation’s oldest, most heavily utilized and also subject to some of the harshest weather conditions. Consequently, infrastructure needs continue to grow. Thirty-two percent of the State and local bridges are currently deficient, meaning they need investment to return to their original design capabilities – it does not mean bridges are unsafe. The average bridge age in New York is 46 years and many bridges are reaching the end of their useful life. The State’s pavement shows similar challenges. Forty percent of our highway pavements are in fair or poor condition. New York ranks 46th among states in terms of pavement condition.

[p. 77][T]he reality of growing needs and the absence of significant new sources of revenues challenge the State…. In recognition of this reality, DOT has made significant changes in its investment strategy. The current focus is on preservation of the existing system. Under a preservation investment strategy, the emphasis is on preserving the infrastructure before it becomes deficient, that is, investing in less costly treatments while the infrastructure is in good or fair condition to maximize what can be achieved with limited resources, and to extend the overall life of the existing infrastructure.

One of the big concerns about allowing fracking in NY has been the threat to our roads and bridges. The plan to maintain infrastructure is to invest in it before it becomes deficient. Allowing fracking trucks and traffic on NY roads would fatally damage our transportation infrastructure.


6. Theme: Accelerating build-out of gas infrastructure will contribute to climate change. Any energy choice that puts more GHG emissions into the atmosphere is unacceptably damaging to global livability and as such, an unacceptably expensive energy choice. Vol. 1 [p. 42]Initiative 08Accelerate securing of critical infrastructure to ensure the safety, security, and reliability of an increasingly complex and interconnected energy system, including transportation, liquid fuels, electricity, and natural gas infrastructure.

The use of the word “accelerate” communicates the strong mandate by New York powers that be to build out natural gas infrastructure. Increased use of gas leads to increased methane in the atmosphere. The Energy Plan downplays the seriousness of methane as a greenhouse gas, which we now know from several recent studies is at least 84 times more potent than CO2 over 20 years. These emissions will hasten climate change and the storms, floods, droughts, agricultural and economic dislocations, and species extinctions that we already see occurring. When we have only a small window of time to decrease GHG emissions to avoid dangerous tipping points in our climate, the policy put forward in the Energy Plan of increasing gas use and consequent methane emissions flies in the face of current science as well as common sense. It is much more urgent to prevent climate chaos than to go for the cheapest fuel. Actually, taking into account the full climate-damaging costs of using gas, gas will turn out to be a much more expensive fuel. We will all pay and pay, and may never be able to pay enough to recover from this decision.


7. Theme: The cost of using more gas should include a metric to assess costs incurred because of climate change, not just prices paid by customers.

The assumption that natural gas will remain “cheap” is obviously the reason for developing a plan with gas as the fuel of choice. The Plan cites a “Potential Study” undertaken in the planning process which predicts that gas prices will remain low because, it assumes, there will be “expanded supplies” and “improved recovery technologies” (horizontal fracking).

Vol. 2 End Use Energy[p. 55] The Potential Study evaluates the opportunities for end-use energy efficiency technologies in the context of natural gas commodity prices that are projected to remain relatively low for the foreseeable future due to expanded supplies and improved recovery technologies. Natural gas commodity prices have a significant impact on both the price of natural gas used on-site by customers for such uses as space heating, and the price of electricity that is centrally generated but delivered by wires for use by individual customers.

The cost to the customer seems to be the only measure of cost evaluated in the choice of gas as the preferred fuel. However, the cost to the consumer, as reflected in the price of the fuel and the electricity generated with gas, doesn’t take into account the huge costs we will all pay as a result of climate change from green house gas emissions--climate related events in particular and global livability more generally. We and our descendants, as well as all animals and plants, will all be paying these costs on into the future. In evaluating energy opportunities and costs, the Plan is shortsighted. If it included a metric to assess costs incurred by all because of climate change, not just prices paid by customers, the cost of using natural gas would be seen as unacceptable.


8. Theme: Increased use of natural gas leads to increased methane in the atmosphere. This is dangerous for the global climate. The New York Draft Energy Plan does not adequately take into account the problem of methane or stress the need for State agencies to measure and prevent methane emissions.

Vol. 1[p.43] Initiative 09Reduce reliance on petroleum products for heating buildings by supporting the use of clean alternatives to heating oil and expanding access to natural gas in the near term while pursuing strategies to reduce natural gas leakage.a. DPS to encourage and support oil-to-gas conversions by collaborating with other State agencies and regulated gas utilities to accelerate investments in natural gas distribution.b. DPS to reduce emissions from natural gas infrastructure by requiring gas utilities to identify and repair leaks of significant magnitude.c. DEC to evaluate regulations to limit methane emissions from natural gas compressor stations on intrastate pipelines.d. NYSERDA to support economic and efficient clean heat options as alternatives to fossil fuel consumption, including solar thermal, geothermal, and the use of sustainably harvested biomass and advanced heating systems.e. DEC, DOH, and NYSERDA to support research to enable the quantification of public health benefits to be incorporated into energy planning and policies.

The initiative here is conversion from petroleum products to natural gas. The Department of Public Service is charged with encouraging and supporting oil-to-gas conversion and accelerating investments in natural gas distribution. I think that the specific rationale is to supposedly reduce emissions both for climate reasons and public health—the emphasis is on transitioning to supposedly clean fuels. But there is no direct acknowledgement that increased use of gas leads to increased methane in the atmosphere and no sense of urgency in preventing its escape. In b and c there is implicit recognition that increased use of gas introduces a bigger problem of methane emissions, but the solution seems to be, “okay require the utilities to find the leaks and repair them if they are ‘significant.’” There is no requirement for monitoring by DEC or regulation of any sort in the picture. For leaks from compressors, DEC is tasked to just evaluate their regulations. But DEC has no funds to take on new monitoring. Will evaluating their regulations keep climate-damaging emissions in check? There is no sense of urgency in any of this to make sure that climate-damaging emissions are controlled. Such emissions must be prevented from escaping into the atmosphere—must be monitored and stopped/prevented. Why is this effort so casual? It is doomed to be ineffectual without more sense of urgency and requirements for enforcement.


9. Theme: Ignoring the addition of methane to the atmosphere by burning increased amounts of natural gas, the Plan falsely claims that NY will reduce green house gas emissions by 80%.

Vol. 1 Vision[p. 23] Environment and Public HealthThe environment and public health are protected by the implementation of clean energy options and the increased adoption of energy efficiency across customer groups and sectors. The State meets health-based air and water quality standards, maintains its leadership in reducing greenhouse gas emissions….

One of the four metrics being tracked is that of green house gas (GHG) emission reductions. The claims for future reductions of green house gases are deceptive, indefensible, as they ignore the potent GHG effect of methane.

[p. 29] Cleaner Environment: Working through innovative public-private partnerships, investments in clean energy strategies will help New York to reduce the intensity of its carbon emissions from the energy sector by 50 percent by 2030 (measured in CO2 emissions per Gross State Product from 2010 baseline), putting New York on a pathway to achieve an 80 percent reduction in total emissions by 2050.

The reductions in emissions, called “total emissions,” refer only to CO2, intentionally ignoring the effect of unburned methane emissions on climate. Of course, the framers are every bit aware that methane is a more potent GHG than CO2

(84X over 20 years), but in the interests of promoting gas use, ignore this. So supporting their “aggressive environmental goals”, they will actually be increasing investment in a methane-driven economy.

Since “clean” energy in this plan includes natural gas, the plan fails to take into account that methane is a potent green house gas and that drilling, transporting, compressing and using natural gas contribute to GHG air pollution. The infrastructure and transport of methane are also a threat to public health.


10. Theme: Energy efficiency evaluation and labeling of buildings is a good idea but low income home owners need more help to achieve acceptable ratings.

Vol. 1[p. 45]Initiative 11Provide improved information and access to energy-related data to support customers’ ability to make educated decisions about clean and efficient energy investments, including labeling mechanisms for commercial and residential buildings.b. NYSERDA and DOS to work with government entities to facilitate disclosure of building energy performance to potential renters and purchasers, benchmarking of energy usage by owners of commercial buildings over a certain minimum size and capture energy efficiency considerations in home and commercial property valuations.c. NYSERDA and DEC to evaluate implementing a labeling mechanism for industrial, commercial, and residential buildings based on the buildings’ energy usage and possibly, their greenhouse gas emissions, allowing customers to easily compare choices.

I excerpted these items since municipalities in Tompkins County are working to develop such a rating and disclosure system to incentivize energy efficiency in buildings. These efforts should be pursued vigorously. But in order for them to work, greater financial and logistical support will have to be made available to low-income homeowners. In fact, as a general principle, without major help, low-income homeowners will lag behind in the effort to conserve energy. They have the least ability to make their houses energy efficient and end up wasting more energy and paying more for heating than those who can afford energy upgrades. Certainly if more homes are slated to be offered natural gas heating, such conversions should only be allowed when a home meets specified efficiency standards in both house tightness/insulating capacity and boiler/burner efficiency.


11. Theme: The Plan reviews many good ideas for encouraging energy efficiency and conservation, but it lacks articulation and implementation strategies.

Vol. 2 End-Use Energy[p.60]The ability to deploy the State’s current energy efficiency resources is highly dependent on customers’ access to energy-related information. Energy customers, including building owners, tenants, and managers, need information about current technologies and energy they use, as well as knowledge about improved systems, products, and practices to help them finance these technologies.

The plan lists a confusing multiplicity of programs, initiatives, codes and studies that target energy efficiency, in the end here acknowledging that customers knowledge of and access to them is crucial. The plan has no plan to provide this missing link, other than “here are some things that would be good to do.” This kind of problem is an overall weakness of the plan.

There is no integrated system to execute the many small pieces and good intentions that together could lead to effective energy saving. Integration and routes to implementation seem to be missing.

These programs lack articulation. How do they relate to each other? Which ones should various constituencies take advantage of? How would eligible energy users find out about them and navigate the choices?


12. Theme: Volume one of the Plan is profoundly misleading, foregrounding the implicit impression that NY is planning to move strongly in the direction of renewable energy. The nuts and bolts of the Plan in Volume 2 do not support this deceptive claim.

The plan starts right out referring to “emerging clean technologies” alongside reference to renewables. But it turns out that natural gas is included in this category of “clean” and that massive increases in the use of gas and build-out of gas infrastructure are planned.

Vol. 1 Vision[p. 1]The Draft 2014 New York State Energy Plan sets forth a vision for New York’s energy future that connects a vibrant private sector market with communities and individual customers to create a dynamic, clean energy economy. We have already made great strides toward this goal. Renewable power sources—hydro, solar, wind, and other carbon-free solutions—continue to grow as a share of the total energy produced in the State.

But 21 pages later:

[p. 22] InfrastructureThe transportation sector has transitioned to greater fuel economy and lower carbon fuels, such as electricity, natural gas, hydrogen, and bio-fuels. Electric and natural gas delivery infrastructure is the secure backbone of the energy system, allowing consumers to easily connect to efficient, affordable, reliable, and increasingly clean energy sources.

It becomes suddenly clear that natural gas is considered a part of the “clean” mix that has been touted again and again. And we see that it is not just part of the mix, but “Electric and natural gas delivery infrastructure is the secure backbone of the energy system….” From this point on, we start seeing how the use of natural gas is promoted but also not fore-grounded; whenever we see “clean” energy, it includes gas. Volume one lacks transparency; it would deceive a naïve reader into believing the source fuels planned for New York will be considerably less polluting, and that New York is moving swiftly towards renewable sources.


13. Theme: Not enough emphasis on increasing renewable energy sources.

Vol. 2 End-Use Energy[p. 21]From 2012 through 2030, total primary energy use is projected to increase by 198 TBtu, or an average annual rate of 0.3 percent. Over this period, natural gas use is projected to increase by 257 TBtu, or an average annual rate of 1.1 percent.

In contrast to the 1.1% projected growth in gas use, renewables are projected to grow by only 0.3% from 2012-2030. It is also troubling that their growth is seen as slowing: 2012-2020 projected growth is 0.6%, 2020-2030 projected growth is 0.1%, for an average of only 0.3% over 18 years. It seems that there is not a substantial effort to create incentives for their growth. Compare this measly progress to what Mark Jacobson and Bob Howrath have shown is possible by 2030—100% conversion to renewable energy.


14. Theme: New York is not on track to meet its goals for renewable energy production.

In the introductory paragraph to the section on End-Use Energy in Volume 2 [p. 18], the percentage use of each fuel is given, followed by projections for the future. No renewable fuels except hydro are mentioned at all as contributing to the sources of energy currently used in NY. At the bottom of the referenced chart on p. 19 is a kind of addendum that says that wood and waste contribute 76 TBtu (Trillion British Thermal Units), ethanol 48 TBtu, and solar and geothermal together 4 TBtu. (It does not look as if NY is on track to meet its goal of 30% renewable energy sources by 2015.)

Vol. 2 End-Use Energy[p. 18]Natural gas represents 1,247 TBtu, or about 34 percent of New York’s total primary energy use. About 36 percent of the natural gas used in New York is used to generate electricity, which is distributed across all the customer sectors. About 32 percent of the natural gas used in New York is used on-site by residential customers (primarily for space heat), while about 24 percent is used on-site by commercial customers. About six percent is used by industrial customers.Petroleum products represent 1,202 TBtu, or about 33 percent of New York’s total primary energy use.Nuclear energy used to generate electricity represents 446 trillion Btu, or about 12 percent of New York’s primary energy use. Hydropower used to generate electricity represents 261 TBtu, or about seven percent of primary energy use. Electricity imported from outside New York represents 232 TBtu, or about 6 percent of primary energy use. Coal represents only 125 TBtu, or about 3 percent of total primary energy use.

[p. 21]From 2012 through 2030, total primary energy use is projected to increase by 198 TBtu, or an average annual rate of 0.3 percent. Over this period, natural gas use is projected to increase by 257 TBtu, or an average annual rate of 1.1 percent.

In contrast to the 1.1% projected growth in gas use, renewables are projected to grow by 0.3% from 2012-2030. It is troubling that their growth is seen as slowing: 2012-2020 projected 0.6%, 2020-2030 projected 0.1%, for an average of only 0.3% over 18 years. The plan does not propose substantial increases in the use of renewables. (Actually, there seems to be more interest in becoming a tech and business hub for research and development and manufacture. The Plan seems more interested in growing the economy and jobs than in actually generating renewable energy.)

The Energy Plan should put much greater emphasis on the increased use of renewable energy and propose robust incentives for their growth. Compare the measly progress envisioned to what Mark Jacobson and Bob Howrath have shown is possible by 2030—100% conversion to renewable energy.


15. Theme: Emphasis of new energy tech is on growing the economy rather than on deploying it for energy generation and conservation.

Strangely, there seems to be more excitement in the Plan in the possibility of producing and selling green energy tech to world markets than in developing sources of renewable energy for use in New York. This section emphasizes the economic advantages to New York of capitalizing on the global demand for new energy technologies—the tech, the jobs, the export, the development of cutting edge industry. There seems to be less commitment to using renewable technologies in New York.

Vol. 2 End Use Energy: Chapter 4 Growing the Clean Energy Economy

[p. 109] Considering that 95 percent of the world’s population lives outside the U.S., tremendous opportunities exist for selling New York invented or manufactured goods and services overseas.

Future Growth Projections are SignificantThe highest growth opportunities in the clean energy economy reside in newer segments such as smart grid, wind, biofuels, solar, energy storage, and energy efficiency. Approximately 25 percent of the 90,000 jobs the Brookings Institute identified in New York’s clean energy economy are in these fastest growing segments.15 A high-level job growth estimate in these segments was developed using information from several sources. Recent estimates concluded that the number of jobs in these sectors could double or triple by 2020.16

If New York can become a major developer and producer of these highly valued technologies, we can also set an example to the world of our use of renewable energy and efficiency technologies. Why only aim for .3% increase in 18 years? NY should aim for a far more dynamic increase in renewable and efficiency technology USE.

[p. 106]In the context of this report, the clean energy economy is defined as “economic activity that produces goods or delivers services designed to increase energy efficiency or generate renewable energy.”

This definition seems to deliberately distinguish the use of the word “clean” from its other, more generic, meanings in the plan. In the definitions section, “clean energy” is not defined.

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