Citizens Guide Costs and Benefits

The Scoping Plan approved by the Climate Action Council on December 19, 2022 makes the claim that delaying climate action will cost New Yorkers more than acting now.  However, that statement is misleading and inaccurate because a semantic trick is needed to make the claim.  More importantly, the Scoping Plan does not include a feasibility analysis to determine whether the citizens of New York can afford the costs of the net-zero transition.  Finally, all the benefits claimed are societal benefits that do not directly accrue to individuals whereas the costs ultimately are passed on to individuals. 


There is no documentation in the Scoping Plan that lists the specific costs of control strategies, the expected benefits, or the expected emission reductions making it impossible to estimate the total costs of the Climate Act.  That information is necessary to determine whether the Integration Analysis projections are feasible.

Scoping Plan Chapter 10: Benefits of the Plan claims that “The cost of inaction exceeds the cost of action by more than $115 billion”.  However, a variation of the following graph is the only documentation for that claim.  I directly addressed this misleading and inaccurate statement in my comments at the Syracuse public hearing but there has been no response or mention of the issues I raised at any Climate Action Council meeting.  In my written Draft Scoping Plan comments I argued that the figure is mis-leading because it presents the numbers relative to a Reference Case rather than a business-as-usual or status quo case that represents a future without decarbonization programs.  I maintain that the true cost of New York’s net-zero transition by 2050 should include all costs associated with all programs designed to reduce GHG emissions.  The authors of the Integration Analysis and Scoping Plan excluded costs that I believe should be included in the true cost of the Climate Act and provided insufficient documentation to enable anyone to determine what is in or out of the Reference Case.  As a result this claim is misleading.


There is another deception that further undermines the claim that the cost of inaction exceeds the cost of action.  I explained in my Draft Scoping Plan comment on benefits that all the benefits claimed are societal benefits that do not directly accrue to individuals whereas the costs ultimately are passed on to individuals. 

The Scoping Plan air quality improvement benefits range between $100 billion and $103 billion for the low values and the high values range between $165 billion and $172 billion.  These benefits are due to an air quality improvement for PM2.5 of 0.35 µg/m3 that is supposed to “avoid tens of thousands of premature deaths, thousands of non-fatal heart attacks, thousands of other hospitalizations, thousands of asthma-related emergency room visits, and hundreds of thousands of lost workdays”. However, the modeled impacts rely on a linear no-threshold model.  The observed PM2.5 reduction in New York City since 2005-2007 is 5.6 µg/m3 and that is 16 times higher than the projected decrease due to the Climate Act.  Using the linear no-threshold model that means that we should be able to observe sixteen times tens of thousands of premature deaths, sixteen times thousands of non-fatal heart attacks, sixteen times thousands of other hospitalizations, sixteen times thousands of asthma-related emergency room visits, and sixteen times hundreds of thousands of lost workdays. 

The Scoping Plan admits that the health benefits from increased active transportation “should be considered a first-order approximation of the benefits of increased active transportation”.  The active transportation health theory claims that as people are forced out of their personal vehicles some will switch to walking and biking.  Those activities are healthier so there is a benefit.  However, the analysis was conducted at the state level, rather than modeling changes in walking and biking activity due to changes in vehicle miles traveled within counties or individual communities.  Because the actual number of places where this strategy could encourage more walking and bicycling to work is small relative to the state as a whole, the $39.5 billion health benefit claim is far too high. 

Most of the health benefits from energy efficiency interventions in Low and Middle Income (LMI) homes are the result of “non-energy interventions”.  The Climate Act intends to transform the energy sector so it is disingenuous to claim health benefits not directly related to energy efficiency programs themselves.  Of the $8.7 billion in benefits claimed $3 billion is due to reduction in asthma-related incidents resulting from better ventilation not directly due to energy efficiency.  The $2.4 billion in benefits from reduced trip or fall injuries and reduced carbon monoxide poisoning benefits are non-energy interventions and should not be claimed as benefits for GHG emission reduction programs. 

The Scoping Plan claims that 2020-2050 societal benefits are greater than societal costs by between $115 and $130 billion.  The largest proposed benefits come from avoided GHG emission impacts on climate change due to emission reductions.  The Climate Act Scoping Plan manipulates the emissions, the emissions accounting, and calculation of social cost of carbon benefits to inflate these benefits to claim that there are net benefits.  In order to maximize the benefits from emission reductions the Scoping Plan uses non-conventional assumptions to contrive increased emission estimates that are 1.9 times higher in 1990 and 2.3 times higher in 2019 than conventional, or UNFCCC, format for emissions accounting used by other jurisdictions.  New York’s Value of Carbon guidance chooses a lower discount rate that places lower value on immediate benefits relative to higher delayed benefits received in the future.  The combined effect of the higher emissions and lower discount rate means that New York’s societal benefits of GHG emission reductions are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions.  Most importantly, it is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. The Value of Carbon guidance incorrectly calculates benefits by applying the value of an emission reduction multiple times.  If you lost five pounds five years you cannot claim that you lost 25 pounds but that is what the Draft Scoping Plan is doing.  Using that trick and the other manipulations results in New York societal benefits more than 21 times higher than benefits using everybody else’s methodology. When the over-counting error is corrected, the total societal benefits range between negative $74.5 billion and negative $49.5 billion.  The Final Scoping Plan should only take credit for societal climate change benefits based on total emission reductions from the baseline, the maximum observed total emissions or the most recent total emissions.

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