The Business Council opposes this legislation, which would provide the Department of Environmental Conservation (DEC) with the mandate to eliminate all greenhouse gas emissions from any emission source in the state by 2050.
The Business Council supports efforts to reduce the carbon intensity of our economy without reducing economic growth. If we are committed to addressing the impact of global climate change on temperature increases and the resultant negative impacts, we must ensure that when New York adopts policies to address in-state GHG emissions they must not lead to carbon leakage. This legislation will lead to massive carbon leakage, meaning its impact on aggregate emissions will be minimal.
When the Business Council addressed the members of the Assembly Climate Change Work Group, we offered to work on the development of reasonable climate change policy. We suggested that the task force focus on specific market failures in areas that can make a significant impact on strategic priorities; catalyze private-sector competition by providing incentives aligned with strategic outcomes; and utilize the most cost-efficient actions to facilitate positive outcomes. Unfortunately the sponsor of this legislation has chosen to head in a different, unproductive direction.
This legislation is simply unworkable and unrealistic for numerous reasons. The legislation is both poorly drafted and poorly conceived. The legislation is blatantly unconstitutional and violates both the New York and the United States Constitution.
If this bill were to become law and could be enforced, it would result in the end of manufacturing, farming, busses, trucks, cars, and finally people. The legislation will require substantial emissions reductions in a relatively short period of time, requiring that in a little more than thirty years that all emissions from the following sources go to zero. Current technology is not available to meet the requirements of this legislation without strict prohibitions.
Simply put, if this legislation was enacted all current sources of GHG would eventually have to stop emitting, including:
- Fuel Combustion including electric generation imported electricity, transportation, residential heating, commercial and industrial heating and onsite electric generation, backup generation, and industrial production.
- Other Source of Carbon including municipal waste combustion, cement production, iron & steel production, limestone use, and soda ash.
- Other Sources of Methane including agricultural animals, landfills, manure management, municipal wastewater
- Other Sources of Nitrous Oxide including agricultural soils management, manure management, municipal wastewater
- Other Sources Perfluorocarbons including aluminum production, semiconductor manufacturing.
It should be noted that New York State is one of the least carbon intensity economies. In 2011, New York produced 155.7 metric tons energy-related carbon dioxide per million dollars of GDP, which is about a third of average carbon intensity nationwide.
If New York were to eliminate all of its C02 emission (211.74 MMtCO2e) it would reduce US CO2 by 3.3% and world emissions by .5%. (In 2012, U.S. greenhouse gas emissions totaled 6,235.10 MMtCO2e and World emissions were 44,815.44 MMtCO2e).
If New York were to try and stop all CO2 emissions it would lead to massive ‘carbon leakage’1 and the bill includes minimal, ineffective language to address this very real problem. Additionally no amount of legislation requiring state agencies to increase employment opportunities and improve job quality will lead produce real world results if businesses cannot produce items or get them to market.
For these reasons and many more too numerous to include here, The Business Council strongly opposes adoption of this legislation.