My original plan to document Climate Act costs was to provide additional costs to ratepayers for various implementation programs. That information is not provided or is hidden so well that I could not find it for most programs. After a couple of attempts trying to make my own ratepayer cost estimates I gave up. Where I can find those numbers, I will provide them. In order to address other cost considerations I have set up other tracking pages that should be considered as well. The following links are to my Climate Act Tracking Scorecards:
- Typical Residential Customer Costs
- Direct Climate Act Subsidies
- Indirect Climate Act Subsidies
- Climate Act Cost Overruns
- Climate Act Integration Analysis Assumed Costs and Updated Costs Page
It is not possible for me to document all the costs because there are so many subsidies I cannot keep track. Any input from readers who are following rulemakings that list ratepayer impacts would be appreciated. Please refer to the caveat section for additional information.
The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway. At the end of 2022 the Climate Action Council completed a Scoping Plan that makes recommends strategies to meet the targets. The Hochul Administration is developing regulations and proposing legislation to respond to those recommendations in 2023.
Unfortunately, the Scoping Plan is just a conglomeration of control strategies that are projected to provide the emission reductions required. The inadequate documentation does not demonstrate the feasibility of the recommended strategies. Furthermore the costs of the program and potential costs to individual New Yorkers are hidden in a shell game con for hiding the true costs. In the Scoping Plan costs are compared to a Reference Case that includes already “incremented programs”. As a result, the costs that are presented do not include all the costs of the net-zero transition. The expected ratepayer costs are not included.
Cost documentation in Department of Public Service proceedings is not transparent and what is provided can be misleading. For example, the energy storage deployment roadmap described below replicates the Scoping Plan shell game con described above. Similar to the Scoping Plan costs, the Roadmap costs are presented relative to “incremental revenues” as documented below. In both instances the result is a deceptive cost estimate that does not include all the costs for the citizens of New York. It appears that the Hochul Administration goal is hide the expenditure of hundreds of billions of dollars under hundreds of programs and subsidies making it intentionally impossible to capture the total costs to consumers. The true “Total Cost” of the Climate Act will be hidden forever from the public by design.
New York’s 6 GW Energy Storage Roadmap Appendix B: Storage Program Cost Analysis
This is an example of the misinformation in the information provided. This Appendix “summarizes the inputs, assumptions, and analysis methodology underpinning the estimates of incremental program costs associated with achieving the proposed 2030 target of 6 GW of short-duration storage”. The Roadmap states:
The total cost of these proposed procurement programs is estimated at between $1.0 billion and $1.7 billion. This equates to an estimated increase in customer electric bills of 0.32% – 0.54% (or $0.34 – $0.58 per month for the average residential customer) on average across New York for the 22-year period during which these programs would make payments to awarded projects. The range of these projections reflects future uncertainties, most notably those associated with energy and capacity prices.
The way this is written it suggests that the energy storage costs will be manageable because it will only be at most $0.58 per month. However, Appendix B states:
For the proposed bulk storage procurement program, program costs are calculated as the incremental revenue, on top of revenue that storage assets can realize through commercial operation in the existing energy markets, that would allow such assets to reach their cost of capital. This methodology is broadly consistent with that applied to cost studies under the Clean Energy Standard.66 Key assumptions and inputs include the costs of storage projects, the estimates of market revenue available to them, available federal incentives and the cost of capital.
This approach is disingenuous at best. They are not providing all the program costs only the costs above what they think an energy storage owner will have above the expected “incremental” revenue. That incremental revenue has to be paid by someone and that someone is the ratepayers of the state. As I understand it the “incremental revenues” are composed of at least the subsidies that are being proposed for energy storage that are like renewable energy credits. Those subsidies are not paid for in the NYISO’s wholesale energy market but are buried in utility rate cases. Moreover, it is not clear if the Roadmap includes energy storage specific wholesale energy market payments as other “incremental” revenue. In any event, the insinuation that the energy storage cost is only going to be “between $1.0 billion and $1.7 billion” is clearly misleading and inaccurate.