Natural Resources Secretary Julie Moore: We need real solutions on climate

Editor’s note: This commentary is by Julie Moore, secretary of the Vermont Agency of Natural Resources.

The Legislature’s Global Warming Solutions Act (GWSA) has been a centerpiece of the legislative session. It has become something of a rallying cry, an outlet even, for our collective concern and well-founded worry about our changing climate. Legislators have presented this bill as solving the climate crisis. Sadly, the bill provides little in the way of solutions.

Personally, the impacts of the changing climate have never been more front-of-mind, and I expect that is true for many Vermonters. The news is filled with examples, from the wildfires raging out west, to articles about the accelerated melting of the Arctic and Antarctic ice sheets, to record numbers of tropical cyclones.

Julie Moore, Secretary of the Vermont Agency of Natural Resources

There are also examples closer to home. Vermont is very “climate sensitive,” with some of the things that we are most famous for – maple sugaring and skiing chief among them – inextricably tied to our climate. And nearly every hunter, gardener or hiker has their own example of something they have seen change.

The stated purpose of the GWSA is to create a system through which ordinary Vermonters can use the legal system to compel their state to reduce its greenhouse gas emissions and to create a framework to establish strategies to mitigate climate risks and build resiliency to climate change. These are incredibly important goals and valuable work.

But while the GWSA appears to reflect the sense of urgency so many of us feel, the actual process established is unwieldy and does not provide my agency – the Agency of Natural Resources – with the tools needed to accomplish the work.

In fact, the most significant thing the bill does is to remove from lawmakers and the governor the responsibility to decide how we will address – and pay for – this greatest challenge of our time. The actual solutions necessary will be complicated, difficult, and require input from many voices – none more important than the people of Vermont. Cutting the elected representatives of the people out of the process violates the most fundamental principles of our democracy. That is one of the principle reasons the governor vetoed this bill.

Instead, the GWSA sets up a 23-person Climate Council, designed to represent a wide range of interests and sectors that are either being directly impacted by a changing climate or will bear significant responsibility in efforts to reduce emissions, or both. What the Council is short on is direct expertise. It includes a representative of rural communities, one from small businesses, one from the fuel sector, one from the municipal sector, and these representatives will be asked to take on an enormous amount of work between now and December 2021.

The Legislature has asked the Council to develop a plan to comprehensively reduce Vermont’s greenhouse gas emissions, providing only a staff of three, a budget of $200,000 and about 15 months to complete the work. This mismatch between the work needed to address our changing climate and the resources provided by the Legislature might be too much, even with the proper expertise on the panel.

Equally concerning, is the decision by the Legislature to remove themselves and their successors from having to approve or disapprove what this un-elected council comes up with. That is a failure by lawmakers to do the job they are elected to do.

My team spent considerable time engaging with Legislative leaders over the last year in an effort to find a more workable approach to achieving our shared climate goals. Unfortunately, our input on how the work might be structured to make it more functional was largely ignored. Intentionally or not, the GWSA sets the state up to fail. And when we fail, the only solutions available will be litigation, delay, and ultimately actions which rely heavily on potentially costly regulatory tools.

The moral imperative to do our piece in driving down greenhouse gas emissions is more real and more urgent than it has ever been. We need to accelerate our actions. We need to do so now. And we share the Legislature’s commitment to this work. But it is not enough simply to act. Our actions need to be solutions-oriented. They need to be intentional and effective and certain and sufficient. Unfortunately, the GWSA doesn’t offer much in this regard.

Image courtesy of Bruce Parker/TNR

12 thoughts on “Natural Resources Secretary Julie Moore: We need real solutions on climate

  1. 1) VT-DPS Concocting an Artificial CO2/kWh for Vermont, based on PPAs

    VT-DPS concocted an artificial CO2 emission for the Vermont grid of 34 g/kWh, based on paper power purchase agreements, PPAs, utilities have with in-state and out-of-state electricity producers.
    This concocted value, which has no physical basis, is about 8 times less than the NE grid CO2 value, as determined by ISO-NE.

    GMP, et al., merely signs some papers, and presto, its electricity is certified green, and has low CO2.
    Break out the champaign. The system has been gamed.

    All other Vermonters have to bust their chops, and save hard-earned money, because they are mandated to buy heat pumps, EVs, insulate their homes to be “net zero”, etc., to be certified green

    Physically, almost all Vermont electricity is drawn by utilities from high voltage grids. There is absolutely no reason for not using the NE grid CO2 value, other than deliberate deception. See below explanation.

    2) NE Electric Grid CO2 in 2018, based on Primary Energy

    ISO-NE uses fuel/energy fed to power plants to calculate CO2/kWh; primary energy basis.
    Page 13 of URL shows 658 lb CO2/MWh, or 658 x 454/1000 = 299 g/kWh; PE basis

    ISO-NE does not include CO2 of upstream energy
    Upstream is about 10.2% of PE CO2

    Fed to grid becomes 299 x 1.102 = 329 g CO2/kWh; source energy basis.
    Fed to wall meter becomes 323 x 1.102 = 356 g CO2/kWh, SE basis.

    Imports from Nearby Grids: Imports were 17% of total electricity fed to the NE grid.

    New York State electric grid CO2 was 464 lb/MWh, in 2018, or 211 g/kWh

    Quebec electric grid CO2 was 500 g/MWh, in 2018, or 0.5 g/kWh

    I assumed imports has zero g CO2/kWh, which likely understates the real-world conditions.

    Adjusted for imports 323/1.17 = 276 g/kWh, PE basis
    Adjusted for imports 356/1.17 = 304 g/kWh, SE basis


    In reality, the CO2 reduction of the EAN plan would not be achieved, because the analyses are flawed.

    EAN, with help from VT-DPS:

    – Used fudged emission data for electricity, grams CO2/kWh
    – Did not consider upstream CO2 for heat pumps and electric vehicle analysis
    – Did not consider embodied CO2 of electric vehicles
    – Did not determine the amortizing cost of the short life assets.

    That means:

    EAN claimed a CO2 reduction per EV much higher than in reality.
    EVs compared to 30 mpg vehicles, such as a Subaru Outback, have a CO2 reduction of about 2.13 Mt/y, much less than the 4.50 Mt/y claimed by the flawed EAN method.
    EAN would need 90000 x 4.50/2.13 = 190,141 EVs to achieve its CO2 reduction of 0.405 MMt/y, at 2025

    EAN claimed a CO2 reduction per ASHP much higher than in reality.
    ASHPs, in average Vermont 2000 ft2 houses, have a CO2 reduction of about 2.389 Mt/y per ASHP, much less than the 4.111 Mt/y per ASHP claimed by the flawed EAN method.
    EAN would need 90000 x 4.111/2.389 = 139,385 ASHPs to achieve its CO2 reduction of 0.37 MMt/y, in 2025

    The EAN-claimed energy cost savings per heat pump and per EV were overstated, as confirmed by the CADMUS survey

    Additional explanation is in this URL, which also shows turnkey capital cost estimates:

    EAN performed the flawed analysis likely to:

    – Bamboozle legislators to get them to vote for GWSA (“all we need is this and that, and we will get these fabulous results”)
    – Bamboozle/befuddle most of the rest of Vermonters, who would:

    1) Be suffering GWSA-induced headaches for decades to come
    2) See no discernible effect on the Vermont climate….

    NOTE: I sent this and other articles to VT-DPS, VT-PUC, VT-ANR, and VT Media, who likely do not read them.
    I almost never receive a comment!!

    Artificial Emissions of Vermont Electrical Sector

    The CO2 reduction from 9.99 MMt in 2015 to 9.02 MMt in 2018 was artificially “achieved” by basing the CO2 of the Vermont electrical sector on power purchase agreements, PPAs, utilities have with owners of in-state and out-of-state electricity generating plants.

    All utilities, which draw almost all of their electricity supply from the NE grid, must have such agreements, per ISO-NE requirements, as otherwise they would be stealing from the grid.

    EAN/VT-DPS concocted an artificial value of 34 g CO2/kWh, based on PPAs, about 8 times less than NE grid CO2/kWh, to “evaluate” the CO2 reduction of heat pumps and electric vehicles to make them look extra good!!! Sheer chicanery. See Appendix and URLs


    EAN listed the measures required to reduce CO2 from 9.76, in 2016 to 7.46, in 2025, for a reduction of 2.28 MMt.
    That CO2 reduction has an estimated capital cost of at least $9.25 billion.
    GWSA requires a reduction of 1.56 MMt, by January 1, 2025, i.e., its estimated capital cost would be 1.56/2.28 x $9.25 billion = $6.32 billion.
    See table 1

    Capital Cost Estimate of EAN Plan

    I made a turnkey capital cost estimate of the EAN plan, because EAN did not, but should have.

    EVs: 90,000 x $40000/small EV = $3.6 billion; installation rate 18000/y vs about 750/y, at present
    High-speed in-house chargers: 90,000 x $2000 = $0.18 billion

    “Deep” retrofits: 90,000 x $30,000/housing unit = $2.7 billion
    ASHPs for space heat: 90,000 x $5,000/housing unit = $0.45 billion; installation rate 18000/y vs about 2900/y, at present
    ASHPs for DHW: 90,000 x $3,000/system = $0.27 billion; installation rate 18000/y vs about 1000/y, at present

    Wind turbines: 250000/(8766 x 0.30) x $2.5 million/MW = $0.095 Billion
    Solar systems: 700000/(8766 x 0.14) x $3.5 million/MW = $0.57 Billion
    Expanding/augmenting of the grid: $0.1 billion
    Fortress Vermont to deal with excessive DUCK-curves, due to midday solar surges.
    Energy storage: $0.9 billion
    Curtailment payments: $0.3 billion

    Hydro power plants: 50000/(8766 x 0.40) x $6 million/MW = $0.086 billion

    The turnkey capital cost would be exceeding $9.25 billion, during 2020 – 2025, about $1.85 billion/y.

    NOTE: EAN-proposed solar build-outs would be from 438.84 dc, at end 2019 to at least 1000 MW dc, at end 2025
    Solar is the most expensive electricity on the Vermont grid. It would not be smart to have more of it.
    It requires about 3.5 acres per MW, and is charged to the utility rate base at 11 to 21 c/kWh

    NOTE: Current cost shifting to ratepayers for solar production of 473,686 MWh, at end 2009, was about $64 million.
    The cost shifting would become at least $130 million, if solar production were increased by 700,000 MWh during the 2020 – 2025 period. See table 4 in URL and Appendix

    Amortizing Short-Life Items

    EVs, heat pumps, battery storage systems, etc., have lives of less than 15 years.
    Amortizing the cost of the short-life assets, $5.7 billion, at 3.5% over 15 years, would require payments of $489 million/y for 15 years, more than offsetting the EAN estimated energy cost savings of 800/5 = $160 million/y, during the 2020 – 2025 period.

    Vermont’s existing RE spending is about $210 million/y, including Efficiency Vermont.
    The additional spending, during 2020 – 2025, would be about 489 – 160 = $329 million/y, per EAN plan
    Annual costs would be even higher, because the amortizing of longer-life items has been temporarily excluded.

  4. GWSA 23-Member Council

    The Council likely would be the sole decider how hundreds of millions of $dollars would be spent, each year, for decades, with no relief ever, because:

    The Council make-up would include:

    1) Eight Government Secretaries and Commissioners
    2) Eight members appointed by the Speaker of the House
    3) Seven members appointed by the “Committee on Committees”, C of C
    The members of the C of C are the Lt Governor, Senate president pro tem, and a “third member” elected by the Senate
    See URL

    The Governor’s Secretary of Administration would be the Chairman.
    He/she has the power to call meetings.
    If he/she delays calling meetings, any 12 of 23 members could call a meeting.

    NOTE: The Governor would have only 8 votes, plus may be a few more, but likely not 5, i.e., the Governor could not override the 12 members calling a meeting.

    The action sequence would be as follows:

    Council would approve plans.
    VT Agency of Natural Resources, ANR, would write rules to implement plans,
    Council would approve rules
    Approved rules sent to the Governor’s Interagency Committee on Administrative Rules, ICAR
    ICAR is composed of Governor Appointees
    ICAR can reject the rules, i.e., the Governor can stop the process.

    What happens next likely would be lawsuits
    Any entity, such as the Conservation Law Foundation, could sue the state, if Council decisions would not reduce CO2 in accordance with GSWA/CEP goals.

    Legislators Disenfranchised

    If the Council decides to have a carbon tax, so be it.
    At no time would any legislator be allowed to vote on any plan, or any proposed rules.
    Legislators, and the people who voted for them, would be disenfranchised.
    Legislators would not be voting on GWSA-related increases of taxes, fees and surcharges.
    Legislators would be “off-the-hook”.

    GWSA Likely is Unconstitutional

    On the face of it, GWSA has to be unconstitutional, because the Governor, and his administration, and Legislators, appear to have no effective say in any Council decisions.
    Such extremism could only come about due to the present, veto-proof control by Dem/Progs.
    This is Centralized Command and Control.
    It has nothing to do with Democracy.

  5. Turnkey Capital Cost to Implement GWSA

    Here is a brief summary of the turnkey capital cost of Phase 1, i.e., reduce CO2 by at least 26%.
    Vermont is lucky, because it has the 14-y, GWSA-experience of California as a guide.

    GWSA Financial Implications: Almost no one, including most legislators, have any idea regarding the reductions of CO2 and the turnkey capital cost to achieve them.
    This article has some background numbers regarding GWSA.
    This article includes an analysis of the Energy Action Network CO2-reduction plan for the 2020 – 2025 period

    GWSA-Required Gross Emissions Reductions and Cost

    Phase 1
    26%+ below 2005, i.e., (1 – 0.27) x 10.22 = 7.46 MMt, by Jan. 1, 2025, to “meet Paris”
    The Council would take about a year to develop plans, which means most of 2021 would have elapsed before any action.
    The actual CO2 reduction would be from 9.02, at end 2018 (latest numbers) to 7.46, Jan. 1, 2025, or 1.56 MMt, during the years 2022, 2023, and 2024, effectively a 3-y period.
    The turnkey capital cost would be about $6.32 billion
    The CO2 reduction appears to be a physical and financial impossibility.
    See table 1A and Note.

    NOTE: The EAN plan lists the measures required to reduce CO2 from 9.76, in 2016 to 7.46, in 2025, for a reduction of 2.28 MMt.
    That CO2 reduction has an estimated capital cost of at least $9.25 billion. See table 1
    The estimated capital cost of Phase 1 would be about 1.56/2.28 x $9.25 billion = $6.32 billion.

    Phase 2
    40%+ below 1990, i.e., (1 – 0.40) x 8.59 = 5.15 MMt, by Jan. 1, 2030
    The CO2 reduction would be 7.46, Jan 1, 2025 – 5.15, Jan. 1, 2030 = 2.31 MMt, during the 5-y period

    Phase 3
    80%+ below 1990, i.e., (1 – 0.80) x 8.59 = 1.72 MMt, by January 1, 2050
    The CO2 reduction would be 5.15, Jan. 1, 2030 – 1.72, Jan. 1 2050 = 3.43 MMt, during the 20-y period


    The Vermont House overrode Governor Scott’s veto of GWSA, and sent it to the Vermont Senate for an override vote
    GSWA converts the aspirational goals of the CEP, to mandated goals.
    If mandated goals are not attained, there would be mandated financial penalties, prohibitions (you shall do this; you shall not do that), fees and surcharges.

    The “Fight Climate Change” agitators, many of whom would stand to financially gain from the GWSA mandates, have failed to get a carbon tax enacted for five years.
    With GWSA, they get a bonanza beyond their wildest dreams.
    They labelled GWSA as “this year’s must-pass legislation”.

    A Rational Alternative to GWSA

    For Vermont, the only thing that makes any sense is to stop “emulating” California.
    California passed a GWSA in 2006. The results have been:

    1) Rapidly increasing gasoline prices.
    2) Rapidly increasing electric rates
    3) Out of control DUCK-curves due to midday solar electricity bulges
    4) Rolling blackouts, due to unwisely/untimely shutting down clean-burning gas power plants that were needed, because both wind and solar were minimal during PEAK DEMAND hours. See URL.

    Vermont should immediately scrap GWSA, and concentrate on:

    1) Energy conservation
    2) Energy efficiency
    3) Building net-zero-energy, and energy-surplus houses and other buildings, by the thousands, each year. See Appendix
    4) Provide incentives to buy vehicles that get more than 35 mpg, EPA combined; the more above the limit, the greater the incentive.
    5) Charge annual fees, paid at time of registration, on existing and new vehicles that get less than 25 mpg, EPA combined; the more below the limit, the greater the fee.

    The above 4 items would save money for Vermonters, and make the state economy more competitive
    Most of the other energy measures are just expensively subsidized hogwash that would not make one iota of difference regarding climate change.

  7. I’m so sick of this agenda.
    Anyone that is older than 50 years old grew up at a time when factories dumped Lord knows what right into the rivers. At what point does common sense kick in?

    They’ve got us so over regulated now that a cow can’t fart in peace anymore.
    I mean give it up.. how about focus on hungry people in Vermont that need jobs.
    Wouldn’t you think that would be the main topic?
    The Kabuki Theater Show is really getting old.
    Vote all these Lunatics out of office so we can clean up this mess and go back to living normal decent lives again.
    We owe it to our kids.
    Apparently their plan is to have us all sitting on the couch watching life go by on Zoom.

  8. Hey, Julie what have you been smoking????? While there’s massive evidence that climate change is a real issue, the GWSA will have absolutely no impact on dealing with the problem. The only thing the sponsers’ will accomplish is to make a bunch of mean swellers feel better while hurting the folks with another TAX!!!!!

  9. Natural Resources Secretary Julie Moore, We need ” real ” solutions on climate ??

    Can someone tell me what Vermont has done to the climate, we’ve done literally
    nothing in the scheme of things !!

    But what have countries like Russia, India, China to name just a few and let’s not forget
    states in the US like California, New York big promotors of causing climate issues and no
    solutions, they spew more CO2 in a day then Vermont will produce in the next 100 years.

    Secretary Moore, start by reeling in these countries and states, poor little Vermont is
    doing quite well, our trees produce plenty of O2, and we surely don’t need that GWSA

    I’ve been hearing the sky is falling since ” Al Gore” and his predictions as he flys around
    in his ” Lear Jet ” …..just another hypocrite promoting an agenda !!

  10. Secretary Moore tells us that the GWSA is ” a rallying cry, an outlet even, for our collective concern and well-founded worry about our changing climate.”……..Really?

    Does Sec. Moore understand where the American people stand on climate change? A monthly running Gallup poll tells us that Americans concern with the climate change is very low. The Gallup poll indicates that Americans rank concern with climate change, pollution and the environment 17th among non-economic issues…….A ranking at odds with Sec. Moore’s thinking.


    The Secretary would perhaps better serve the Governor by sticking with his veto that properly labeled the GWSA as bad legislation that offers no solutions.

  11. We will just copy Calizuela’ GWSA, and we will be fine in Hell for decades.

    Just like Bernie’s USSR-style Socialism

    Vermont would implement it better, He says, even though, as Julie Moore says, we don’t have the expertise.

    After 14 years of useless suffering with higher and higher gas prices and electric rates, and rolling blackouts under Calizuela’s GWSA, it made no impact regarding the climate.

    Vermonters’ sufferings and impact of GWSA would be the exactly the same.

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