Citizens Guide Integration Analysis Strategies Environmental Impacts

The Climate Act only accounts for fossil fuel life-cycle costs and environmental impacts while ignoring the life-cycle impacts of wind, solar, and energy storage technologies.  These “zero-emissions” resources may not have emissions when generating electricity but the volume of materials needed to access dilute wind and solar energy and the rare earth elements necessary for those technologies certainly have environmental impacts when mined and processed.  The large number of wind turbines and solar panels will also create massive amounts of waste when they are retired.  Furthermore, the cumulative environmental impacts of thousands of wind turbines and square miles of solar panels has not been compared to the environmental impacts of current fossil fuel technology. 

Integration Analysis Strategies

The Climate Act mandates reductions of greenhouse gases from all sectors of the economy.  The integration analysis describes different scenarios that will be incorporated into the scoping plan to meet the Climate Act targets.  This background page describes environmental impacts of the strategies that have not been addressed to date by the Climate Action Council.  As a result, the Scoping Plan will not give New Yorkers the opportunity to compare the environmental impacts of the proposed integration analysis scenarios.

Life-Cycle Environmental Impacts

The Climate Act mandates the use of “zero-emissions” energy resources that may not have emissions when generating electricity but the materials necessary for those technologies certainly have environmental impacts when mined and processed.  Mark Mills, Senior Fellow at the Manhattan Institute, did a video for Prager University that explains why there are serious environmental issues associated with wind, solar and energy storage resource development. 

Mills explains that:

A single electric-car battery weighs about half a ton. Fabricating one requires digging up, moving, and processing more than 250 tons of earth somewhere on the planet.  Building a single 100 Megawatt wind farm, which can power 75,000 homes requires some 30,000 tons of iron ore and 50,000 tons of concrete, as well as 900 tons of non-recyclable plastics for the huge blades. To get the same power from solar, the amount of cement, steel, and glass needed is 150% greater.

For the “Strategic use of low carbon fuels” Climate Act development scenario that translates to 3.5 million tons of iron ore, 5.9 million tons of concrete and 106,000 tons of blade material for industrial onshore wind and 19 million tons of iron ore, 31.7 million tons of concrete and 571,000 tons of glass for industrial solar.  This does not consider the additional materials needed for offshore wind and energy storage.

Another troubling environmental aspect is the need for rare earth elements such as cobalt, lithium, and dysprosium.  Mills shows that these will require massive new mining operations and, because those are difficult to site in the United States, they will likely come from countries that do not have the same high standards for environmentally sound mining operations.  Mills states: “Worse is the lack of worker protections: Amnesty International paints a disturbing picture: ‘The… marketing of state-of-the-art technologies are a stark contrast to the children carrying bags of rocks.’”

The large number of wind turbines, solar panels and energy storage batteries will also create massive amounts of waste when they are retired.  Coupled with the fact that these technologies have shorter life expectancies than the fossil-fuel technology the lack of assessment is an embarrassing omission. There is no way to recycle the wind turbine blades and solar panels so the simple mass of the waste disposal requirements is immense.

Cumulative Environmental Impacts

In September 2020 there was an environmental impact analysis for the expected deployment of wind and solar resources.  Potential environmental impacts mentioned include:

The deployment of large amounts of large-scale renewables and distributed solar energy may have adverse environmental impacts. Large-scale solar development may have significant land requirements and may permanently affect existing agricultural land and habitat for grassland birds. Development of new large-scale solar may increase potential impacts to visual resources compared to the Prior SEQRA Analyses. Development of new offshore wind may increase impacts on marine mammals, fish, commercial and recreational fisheries, and birds and bats beyond what was analyzed in the Prior SEQRA Analysis.

The missing piece in the Climate Act environmental assessment is the lack of discussion and consideration of a threshold for unacceptable cumulative environmental impacts.  For example, I compared the impacts of a single industrial wind facility (33 turbines and 124 MW) to potential onshore wind capacity needed to meet the Climate Act target.  Over the 30-year expected lifetime of the example facility the site environmental impact analysis estimates that 85 Bald Eagles and 21 federally protected Eastern Golden Eagles will be killed.  An environmental impact analysis of all the wind energy needed has not been done.  Assuming that the proportion of eagles killed per MW can be applied to the state as whole suggests that for integrated analysis Scenario 2 that 269 Bald Eagles and 66 Golden Eagles per year could be killed.  If a properly done cumulative environmental impact assessment for all the wind energy resources needed comes up with a similar number is that acceptable?

Another environmental impact issue that has not been addressed is the on-going development of wind and solar projects in the absence of a master plan for development.  A NYSERDA analysis on wind power and biodiversity for the New York Natural Heritage Program (NYNHP) and Nature Conservancy found that: “5,430 square kilometers (1.3 million acres) of land in New York that are both suitable for wind power development and avoid areas that are likely to have high biodiversity value. Using an estimate of 3.0 MW/square kilometers, this translates to a megawatt capacity estimate of 16,300 MW (± 9,000 MW) for New York’s terrestrial landscape.” The integration analysis scenarios for wind development range between 10,997 and 13,239 MW so siting the necessary wind and avoiding areas of high biodiversity is possible.  However, the lack of any state-wide plan to incorporate this kind of analysis for both wind and solar deployment planning and environmental impacts means that this criterion is not being considered.


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