Progressive State Climate Change Playbooks

From Roger Caiazza

On December 12, 2018 the New York State Energy and Research Development Authority (NYSERDA) announced the availability of three “playbooks” produced by the U.S. Climate Alliance, a bipartisan coalition that includes 16 states and Puerto Rico, to address climate change and implement policies that advance the goals of the Paris Climate Accord. Each of these playbooks deserves detailed review and comment but this post only gives an overview based on my initial skim through the reports.

According to the announcement: “The playbooks will serve as implementation resources for states in deploying solar energy, spurring electric grid modernization, and enhancing resilience in the face of climate impacts and natural hazards. The three solutions are highlighted in the following playbooks: solar deployment, non-wire solutions (NWS), and resiliency.”

The Solar Deployment Guidebook, developed in collaboration with the National Association of State Energy Officials (NASEO), was created to assist states and localities in accelerating solar adoption. The guidebook provides “strategies and tools to reduce non-hardware costs of solar deployment, including permitting, zoning, property taxes, and municipal procurement so that solar energy deployment can continue to grow.” Most of this document is a wish list from the solar industry for ways to make solar deployment easier.

The community solar component that is encouraged in this guidebook is more problematic. Community solar refers to local solar facilities shared by multiple community subscribers who receive credit on their electricity bills for their share of the power produced. My problem is that providing homeowners, renters, and businesses who cannot install solar with access to the economic and environmental benefits of solar energy generation claims is that without unlimited funds someone is going to get left out. Why should one segment of society get a benefit paid for by the rest of us?

The Non-Wires Solutions Implementation Playbook, developed in collaboration with Rocky Mountain Institute, highlights how “electric utilities increasingly can reduce their system infrastructure investments and save customers money by employing non-wires solutions to cost-effectively meet growing grid needs.” According to this report, non-wire solutions can be applied in specific locations to defer or eliminate investment in “traditional and costlier ‘wires and poles” infrastructure. Distributed Energy Resources (DERs) are the specific components of a non-wire solution portfolio that can address the inefficiencies of the traditional system according to the authors. Examples include:

• Responsive Building Equipment Controls (e.g., lighting sensors/controls, thermostats, water heater controls)
• Behavioral Demand Response (i.e., human responses to signals sent through various media)
• Energy Storage (e.g., battery, thermal, and others)
• Building Equipment Upgrades (e.g., lighting, HVAC equipment, or appliance replacements)
• Distributed Generation (various renewable and non-renewable resources).

Although the report claims that the utilities invest in traditional distribution infrastructure to make money they overlook the fact that in many places that infrastructure is so old that it needs to be replaced anyway. Unless the proposed non-wires solutions can eliminate the need for the existing system then infrastructure maintenance and upgrade costs will still be required. Because the renewables they claim are necessary are intermittent and diffuse the transmission grid will still be required. The playbook recommends that states require these programs for their utility companies. Note, however, that when the utilities are negotiating their rate cases it is unlikely that they will call out this scam for what it is because they cannot afford to antagonize the political appointees that decide the rate case. When the rate negotiations reduce the amount requested I suspect necessary infrastructure maintenance will be sacrificed to the politically correct playbook “solutions” suggested in this playbook.

The New Governors’ Resilience Playbook provides information to new governors assuming office in January 2019 on how to “minimize climate risk, maximize clean economic growth opportunities and reduce future costs from extreme weather and climate variability”. The playbook proposes a ten-step strategy for new governors to engage local actors and direct state agencies to enhance resilience. According to the introduction “During the next four years, every Governor will likely grapple with critical resilience issues in their state – from extreme weather events and natural disasters to crumbling infrastructure and cyber threats. The human and economic toll of not being prepared is highly consequential to your state’s residents, communities, and the economy. Finding ways to mitigate these costs and threats through effective resilience and climate preparedness strategies are therefore an essential responsibility for Governors.” I agree completely that increased resiliency is a good thing and should be encouraged.

However, the Playbook illustrates its case for the climate risk resiliency with graphs showing the growing burden of uninsured natural catastrophe losses and the number of FEMA disaster declarations. Both graphs are based on Swiss Re analyses. Not to be too cynical but, an insurance company has a vested interest in just such a depiction of societal losses. Roger Pielke Jr.’s work on hurricanes and weather disasters both show that appropriately adjusting the data gives the opposite result. Of course when peer-reviewed literature that does not show the politically correct answer and industrial grey papers does give the answer desired, the inevitable result is to ignore the peer-reviewed standard.

There is another aspect of the resiliency argument to consider. One of the more frustrating aspects of climate mitigation advocates is that they ignore the fact that no one is claiming that if we reduce CO2 to whatever level they think is appropriate that it will mean that there will be no more severe weather. Hurricanes will happen with or without climate change. I believe that it is more cost-effective to harden infrastructure and make it more resilient than to try to reduce impacts by mitigation. Given that our coastlines are a long ways from being resilient then the preferred response seems clear to me.

Roger Caiazza is a retired air quality meteorologist and environmental regulation analyst who blogs at Pragmatic Environmentalist of New York.