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New Climate Reality is Passing New York By

Note: For quite a while now I have put my Citizens Guide to the Climate Act article as the top post on the website because it summarizes the Climate Leadership & Community Protection Act (Climate Act). This post updates my current thoughts about the Climate Act and will replaces that post at the top of the list of articles on October 2, 2023

There is a new climate reality and it is passing New York by.  New York decision makers are going to have to address the new reality that proves that the Hochul Administration’s Scoping Plan to implement the Climate Act will adversely affect affordability, reliability, and the environment.  This post highlights articles by others that address my concerns.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and have major unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. 

Climate Science

In the past several weeks there have been multiple articles highlighting issues that call into question the rationale for the Climate Act and Climate Act net-zero transition.   The rationale for the Climate Act is that there is an existential threat due to climate change.  However, the Epoch Times reports that is not a universally held position:

There’s no climate emergency. And the alarmist messaging pushed by global elites is purely political. That’s what 1,609 scientists and informed professionals stated when they signed the Global Climate Intelligence Group’s “World Climate Declaration.”

The article gives a good overview of the World Climate Declaration.  The declaration’s signatories include Nobel laureates, theoretical physicists, meteorologists, professors, and environmental scientists worldwide. The article quotes a few signatories who when asked by The Epoch Times why they signed the declaration stating that the “climate emergency” is a farce, they all stated a variation of “because it’s true.” 

In my case, I signed the Declaration because I do not think we understand natural climate variability well enough to be able to detect the effect of a relatively small change to the atmosphere’s radiative budget caused by mankind’s greenhouse gas (GHG) emissions.  There are so many poorly understood factors at play and the mathematical challenges of simulating the chaotic, non-linear processes are so immense that I think that claiming that Global Climate Models can simulate the atmosphere well enough to make major changes to the energy system of the world is absurd.

There is another important aspect.  One of the key points made in the Declaration is that climate science is overly politicized:

“Climate science should be less political, while climate policies should be more scientific,” the declaration begins. “Scientists should openly address uncertainties and exaggerations in their predictions of global warming, while politicians should dispassionately count the real costs as well as the imagined benefits of their policy measures.”

It seems to me that every day there is another mass media story attributing any extreme weather event to climate change and insinuating that the “science” has unequivocally shown that there is a link to mankind’s GHG emissions has made the weather more extreme.  The fact is that the latest research and the Intergovernmental Panel on Climate Change are finding that as Roger Pielke, Jr. explains the “projected climate futures have become radically less dire”.  He argues that the consensus has accepted a large change in expected warming due to a doubling of GHG emissions — from 4oC to 2.5oC or less.   Pielke notes that he has documented this trend  for years and has “been talking about the incredible shift in expectations for the future” recently.  Unfortunately he also notes: “Despite the growing recognition that our collective views of the future have changed quickly and dramatically, this change in perspective — a positive and encouraging one at that — has yet to feature in policy, media or scientific discussions of climate.”   He concludes “That silence can’t last, as reality is persistent.”

Affordability

I think this is the one issue that might force political change to the Climate Act net-zero transition.  A coalition of business organizations have called for a “reassessment” of how the Climate Act is being implemented highlighting current policies to determine “what is feasible, what is affordable and what is best for the future of the state.”  In response, Department of Environmental Conservation Commissioner Basil Seggos told Capital Tonight that “the costs of inaction are much higher.”  He goes on: “Listen, we know from two years of very intensive research that the cost of inaction on climate in New York far exceeds the cost of action by the tune of over $100 billion”. I disagree.

The Scoping Plan that documents this claim by Seggos has been described as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”.  No where is this more evident than in the tortuous documentation for this cost claim.  I documented the issues with costs and benefits in my  comments (social cost of carbon benefits, Scoping Plan benefits, and electric system costs).  In brief, the Hochul Administration has never provided concise documentation that includes the costs, expected emission reductions and assumptions used for the control strategies included in the Integration Analysis documentation making it impossible to verify their assumptions and cost estimates. 

The claim that the costs of inaction are more than the costs of action compares real costs to New Yorkers relative to societal benefits that can be charitably described as “biased high” or more appropriately “cherry picked” to maximize alleged benefits and, more importantly, do not directly offset consumer costs.  The benefits claimed are also poorly documented, misleading and the largest benefit is dependent upon an incorrect application of the value of carbon.  The plan claims $235 billion societal benefits for avoided greenhouse gas emissions.  I estimate those benefits should only be $60 billion.  The Scoping Plan gets the higher benefit by counting benefits multiple times.  If I lost 10 pounds five years ago, I cannot say I lost 50 pounds but that is what the plan says.  The cost benefit methodology was duplicitous because the cost comparisons were relative only to Climate Act requirements that did not include “already implemented” programs.  For example, this approach excludes the costs to transition to electric vehicles because that was a requirement mandated before the Climate Act.  I maintain that the total costs to transition to net-zero should be provided because that ultimately represents total consumer costs.  

It is also frustrating that the State ignores that other jurisdictions are finding costs are an issue.  In a recent article I noted that the Prime Minister of Great Britain, Rishi Sunak, said he would spare the public the “unacceptable costs” of net zero as he scaled back a string of flagship environmental policies. The fact is that every jurisdiction that has tried to transition away from fossil-fueled energy has seen a significant increase in consumer costs.  For example, Net Zero Watch recently published a report that describes six ways renewables increase electricity bills that makes that inevitable.   The article explains:

In order to reduce bills, a new generator generally has to force an old one to leave the electricity market — otherwise there are two sets of costs to cover. But with wind power, you can’t let anything leave the market, because one day there might be no wind.

The article goes on to explain that as well as adding excess capacity to the grid, renewables also have a series of other effects, each of which will push bills up further:

Renewables need subsidies, they cause inefficiency, they require new grid balancing services that need to be paid for; the list of all the different effects is surprisingly long. There is only one way a windfarm will push your power bills, and that’s upwards.

Reliability

Another flawed aspect of the Climate Act narrative is that a transition to a zero-emissions electric system is straight-forward and there are no significant technological challenges.  Terry Etam summed up the issues evident in the German transition that will also occur in New York.  In an article about the ramifications of the energy requirements for implementing artificial intelligence applications, he argued that the fossil-fired energy growth in the developing nations has been discouraged by the G7 nations.  However, those nations are pushing back on anything that is not in their best interests.  He writes:

The second big tectonic shift was on full display at the recent G20 summit. The African Union was admitted as a member, which was kind of a big deal, particularly for Africa, but also for the world in general. The addition acknowledges that other voices need to be on the world stage, a sense of humility the G7 has long lacked. The final communique issued at the end of the G20 summit included doses of common sense lacking from typical utterances of the G7: “We affirm that no country should have to choose between fighting poverty and fighting for the planet…It is also critical to account for the short-, medium-, and long-term impact of both the physical impact of climate change and transition policies, including on growth, inflation, and unemployment.” 

Contrast that with the west’s bizarre self-lobotomization when it comes to energy, as best personified by the entity furthest along the rapid-transition path, Germany: the dwindling economic powerhouse is chained to a green freight train it insists is under control, has shut down nuclear power plants with no low-emissions baseload to replace it, and in a final stunning swan dive to the pavement, is orchestrating the installation of 500,000 heat pumps per year to the grid, which will be in most demand in cold weather and will perform worst in cold weather, and will add a potential 10 gigawatts of cold-weather demand at the very instant the grid is least able to afford it, and for which there is no supply available anyway. A German energy economic university think tank says the additional cold-weather demand could only be met by new gas-fired power plants, which are not being built. In sum: Germany has shuttered its cleanest, most reliable energy; it has or is trying to banish hydrocarbons and replace them with intermittent power; and finally, is hastening adoption of devices that will function very well in 80 percent of conditions when it doesn’t matter much but will fail in a spectacularly deadly way at the point in time when they are needed the very most, because heat pumps will be turned up to 11 at the very time the grid will be the most taxed. German engineering isn’t what it used to be.

In the last several years I have concluded that intermittency of wind and solar is the fatal flaw for that technology.  The most important consideration is the need for energy storage.  Francis Menton writing at the Manhattan Contrarian summarizes energy storage problems in a recent post on a new British Royal Society report “Large-scale energy storage.”  This report suffers from the same problems afflicting the Climate Act Scoping Plan.  Menton explains:

Having now put some time into studying this Report, I would characterize it as semi-competent. That is an enormous improvement over every other effort on this subject that I have seen from green energy advocates. But despite their promising start, the authors come nowhere near a sufficient showing that wind plus solar plus storage can make a viable and cost-effective electricity system. In the end, their quasi-religious commitment to a fossil-fuel-free future leads them to minimize and divert attention away from critical cost and feasibility issues. As a result, the Report, despite containing much valuable information, is actually useless for any public policy purpose.

I believe that the insurmountable problem with energy storage backup for wind and solar is worst-case extremes.  The Royal Society report notes that “it would be prudent to add contingency against prolonged periods of very low supply”.  This contingency is the theoretical dispatchable emissions-free resource that the Integration Analysis, New York State Independent System Operator, New York State Reliability Council, and Public Service Commission in the Order Initiating Process Regarding Zero Emissions Target in Case 15-E-0302 all acknowledge is necessary.  Incredibly, the loudest voices on the Climate Action Council clung to the dogmatic position that no new technology like this resource was necessary and excluded any consideration of a backup plan to address the contingency that a not yet commercialized technology might never become commercially viable and affordable.

If New York State were to embrace nuclear energy, then there might be a chance to significantly reduce GHG emissions without affecting reliability.  Instead, the Scoping Plan placeholder option for this resource is green hydrogen.  Menton describes the hydrogen option proposal in the Royal Society report:

Since hydrogen is the one and only possible solution to the storage problem, the authors proceed to a lengthy consideration of what the future wind/solar/hydrogen electricity system will look like. There will be massive electrolyzers to get hydrogen from the sea. Salt deposits will be chemically dissolved to create vast underground caverns to store the hydrogen. Hydrogen will be transported to these vast caverns and stored there for years and decades, then transported to power plants to burn when needed. A fleet of power plants will burn the hydrogen when called upon to do so, although admittedly they may be idle most of the time, maybe even 90% of the time; but for a pinch, there must be sufficient thermal hydrogen-burning plants to supply the whole of peak demand when needed.

The Scoping Plan proposal is slightly different.  It envisions that the electrolyzers will be powered by wind and solar to create so-called “green” hydrogen.  Menton and I agree that the biggest unknown is the cost.  He raises the following cost issues:

  • How about the new network of pipelines to transport the hydrogen all over the place?
  • How about the entire new fleet of thermal power plants, capable of burning 100% hydrogen, and sufficient to meet 100% of peak demand when it’s night and the wind isn’t blowing.
  • They use a 5% interest rate for capital costs. That’s too low by at least half — should be 10% or more.
  • And can they really build all the wind turbines and solar panels and electrolyzers they are talking about at the prices they are projecting?

It gets worse in New York.  Ideologues on the Climate Action Council have taken the position that “zero-emissions” means no emissions of any kind.  They propose to use the hydrogen in fuel cells rather than combustion turbines because combustion turbines would emit nitrogen oxides emissions.  This adds another unproven “at the scale necessary” technology making it even less likely to succeed as well as adding another unknown cost.  In addition, it ignores that there are emissions associated with the so-called zero-emissions technologies that they espouse.  All they are advocating is moving the emissions elsewhere.

Environmental Impacts

I addressed the implications that the Scoping Plan only considers environmental impacts of fossil fueled energy in my Draft Scoping Plan Comments.  The life-cycle and upstream emissions and impacts are addressed but no impacts of the proposed “zero-emissions” resources or other energy storage technology are considered.  The fact is that there are significant environmental, economic, and social justice impacts associated with the production of those technologies. Furthermore, the most recent cumulative environmental impact analysis only considered a fraction of the total number of wind turbines and area covered by solar PV installations proposed in the Scoping Plan.  As a result, the ecological impacts on the immense area of impacted land and water have not been adequately addressed.

One of the more frustrating aspects of the Hochul Administration’s Climate Act implementation is the lack of a plan.  For example, consider utility-scale solar development.  There are no responsible solar siting requirements in place so solar developers routinely exceed the Department of Agriculture and Markets guidelines for protection of prime farmlands.  My solar development scorecard found that prime farmland comprises 21% of the project area of 18 approved utility-scale solar project permit applications which is double the Ag and Markets guideline. 

I am particularly concerned about environmental impacts associated with Off Shore Wind (OSW).  This will be a major renewable resource in the proposed Climate Act net-zero electric energy system.  The Climate Act mandates 9,000 MW of Off Shore Wind (OSW) generating capacity by 2035.  The Integration Analysis modeling used to develop the Scoping Plan projects OSW capacity at 6,200 MW by 2030, 9,096 MW by 2035 and reaches 14,364 MW in 2040.  I summarized several OSW issues in a recent article that highlighted an article by Craig Rucker titled Offshore Wind Power Isn’t ‘Clean and Green,’ and It Doesn’t Cut CO2 Emissions.  He explains:

A single 12 MW (megawatts) offshore wind turbine is taller than the Washington Monument, weighs around 4,000 tons, and requires mining and processing millions of tons of iron, copper, aluminum, rare earths and other ores, with much of the work done in Africa and China using fossil fuels and near slave labor.

Relying on wind just to provide electricity to power New York state on a hot summer day would require 30,000 megawatts. That means 2,500 Haliade-X 12 MW offshore turbines and all the materials that go into them. Powering the entire U.S. would require a 100 times more than that. 

These numbers are huge, but the situation is actually much worse.

This is because offshore turbines generate less than 40% of their “rated capacity.” Why? Because often there’s no wind at all for hours or days at a time. This requires a lot of extra capacity, which means a lot more windmills will have to be erected to charge millions of huge batteries, to ensure stable, reliable electricity supplies.

Once constructed, those turbines would hardly be earth or human friendly, either. They would severely impact aviation, shipping, fishing, submarines, and whales. They are hardly benign power sources.

The environmental impacts on whales of the OSW resources necessary to meet the net-zero transition are especially alarming.  Earlier this year I described the Citizens Campaign for the Environment virtual forum entitled Whale Tales and Whale Facts.  The sponsors wanted the public to hear the story that there was no evidence that site survey work was the cause of recent whale deaths.  I concluded that the ultimate problem with the forum was that they ignored the fact that construction noises will be substantially different than the ongoing site surveys and will probably be much more extensive when the massive planned construction starts.  The virtual forum noted a lack of funding for continued monitoring necessary to address the many concerns with massive offshore wind development to allay the concerns of the public.   Since then, the Save Right Whales Coalition (SRWC) has found issues with the incidental harassment of whales associated with the noise levels associated sonar surveys done in conjunction with OSW development.  I am very disappointed that the Hochul Administration is not investing in an adequate monitoring program that confirms that whales are not being harmed. 

Conclusion

This article was intended to summarize my current concerns about the impacts of the Climate Act transition on affordability, reliability, and the environment.  There is a growing realization that the alleged problem of global warming is not as big a threat as commonly assumed. Combined with the fact that New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990 the rationale for doing anything is weak.  It may not mean that we should not do something, but clearly we have time to address the affordability, reliability and environmental impact issues.

The Scoping Plan has not provided comprehensive and transparent cost estimates so New Yorkers have no idea what this will cost.  I explained why the Hochul Administration claim that the costs of inaction are more than the costs of action is misleading and inaccurate.  I believe that all New Yorkers should let it be known that they need to know the expected costs so they can determine if they support the transition.

When the energy system becomes all-electric the reliability of the electric system will be even more critical than today.  The State plan is to proceed as if there are no implementation issues.  The rational thing to do would be to develop demonstration projects to prove feasibility and cost of the new technology needed before dismantling the current system.  Francis Menton explains why this is necessary and how it could work.  There is no sign that is being considered.

It is particularly galling that organizations who claim to be in favor of a better environment have failed to support comprehensive cumulative environmental impact assessment and on-going impact monitoring assessment to potential impacts from wind, solar, and energy storage development on the scale necessary for the net-zero transition.  Maybe they don’t want to know that the concerns are real.

Mark Twain said: “It is easier to fool someone than it is to tell them they have been fooled.”    The politicians who support the Climate Act net-zero transition have been fooled into thinking it is affordable, will not affect reliability, and benefits the environment.  Unfortunately, it is very difficult to slow down, much less stop the unfolding train wreck of these policies.  I encourage readers to keep asking for a full cost accounting of all the proposed programs as the most obvious concern.

Articles of Note May 12, 2024

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered.   This is a summary of articles that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Videos

The Biden administration has approved a slew of projects that could result in hundreds of offshore wind turbines being placed right in the middle of the North Atlantic Right Whale’s habitat. As you likely know, the North Atlantic Right Whale (Eubalaena glacialis) is one of the world’s most endangered whales. Only about 360 individuals are left. So why are so few climate NGOs speaking out against the industrialization of our oceans and the danger that offshore wind poses to the whale?

The Climate Industry’s Misdirection Campaign

Jessica Weinkle has written a highly recommended description how institutions are being delegitimized in the name of climate catastrophism. She concludes:

Dark money may or may not be a problem the public wants to address.

Concerning however is the extent to which the sprawling empire of the multifaceted climate industry has managed to discredit critique of its methods.

Those who do are dubbed obstructionists, and in no insignificant part by the billionaires moving money around in opaque ways.

Policymakers unwilling to acknowledge this dynamic are also turning their back on genuine problems in scientific integrity, misleading policy, courts, public health research, and threatening food security and development. The public is left with a sea of technocratic propaganda and limited ways to engage because the expertise barrier is too high.

Robbins claimed that “it is not what you look at that matters… It’s what you see.” All around us we look at the massive influence of the climate industry on climate change science and public messaging. But what most see are flashy graphs, dire futures, and get rich quick investment opportunities.

All the while, the legitimacy of our democratic and scientific institutions are being snatched before our very eyes.

Climate Change Reality

The CO2 Coalition published a paper prepared by Richard Lindzen, William Happer, Steven Koonin on April 16, 2024 titled Fossil Fuels and Greenhouse Gases Climate Science that is an excellent summary of reasons why there is no climate crisis.  Three sections are included: There will be disastrous consequences for the poor, people worldwide, future generations and the west if fossil fuels, co2 and other ghg emissions are reduced to “net zero”; The IPCC is government controlled and thus only issues government opinions, not science; and Science demonstrates fossil fuels, CO2 and other GHGs will not cause catastrophic global warming and extreme weather.  John Robson at Climate Discussion Nexus also praises the paper: “The paper does not break new ground, but summarizes the grounds for skepticism about the real impact of climate policy, the credibility of the IPCC, the reliability of climate computer models and claims that CO2 has made the weather worse and will only continue to do so”.

Judith Curry gave a great presentation Climate Uncertainty and Risk to the Global Warming Policy Foundation.  Video of the presentation [here].  Powerpoint slides can be downloaded here [ GWPF uncert & risk (2)].  She makes the point that the political strategy by the UN and New York’s Climate Act is “deeply polarizing, whereas the strategy on the right seeks to secure the common interest of communities.”  She concludes that:

Once you separate energy policy from climate policy, the way forward for energy policy is fairly straightforward. A more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation.  The goal is abundant, secure, reliable, cheap & clean energy.

The problem with climate policy is that it is a “wicked problem” that necessitates an approach that recognizes the deep uncertainties we have associated with climate understanding.  Of course those concerns are routinely ignored by the advocates for the Climate Act.

Social Cost of Carbon

The Social Cost of Carbon (SCC) is a contrived parameter used to justify policies that are designed to eliminate fossil fuels.  It is a difficult parameter to describe and show how it is used.  Jonathan Lesser from the National Center for Energy Analytics wrote an excellent article that describes it well. 

Electric Vehicles

Ford lost a lot of money on each electric vehicle it sold in the first quarter of 2024.  CNN claimed that Ford sold 10,000 electric vehicles for a loss of $132,000 per vehicle but Robert Bryce said Ford sold 20,233 electric vehicles for a loss of “only” $65,272 per vehicle.  Words fail to describe this madness.

Chinese EV manufacturers are poised to flood the American car market with cheap, high-quality SUVs by exploiting loopholes in tariff laws utilizing plants built in Mexico as the jumping-off point.  This will happen even sooner.  Chinese-owned carmaker Volvo (a subsidiary of China’s Geely) is about to beat the competition as soon as this summer with the introduction of a small battery electric SUV, the EX30, in the US. 

The EX30 will directly compete with the Tesla Model Y in terms of performance and features, but at a price tag of $35,000, $8,000 less than the Model Y’s current cost. Reuters writes that, “[t]he competitive price reflects an unusual combination of Geely’s China-specific cost advantages and Volvo’s ability to skirt US tariffs on Chinese cars because it also has US manufacturing operations.” Even better, Volvo says that, even at that market-undercutting price, it expects to realize a 15-20 per cent profit margin on the EX30, meaning it has room to cut the price further should Tesla or other companies find ways to meet its initial price tag.

Used EV timebomb – Many EVs could become almost impossible to resell because of their limited battery life.

Experts said that the average EV battery guarantee lasts just eight years. After this time, the battery may lose power more quickly and so reduce mileage between charges.  Many EVs will lose up to 12 per cent of their charge capacity by six years. Some may lose even more.

The cost of a replacement battery can be more than the value of the car.  As a result used EVs have little value which increases the total lifetime cost of an EV compared to a internal combustion engine.

Irina Slav describes the possible last straw for EV that i wrote up for Watts Up With That.  She notes that governments need to start thinking about a tax to replace their lost income from fuel duty collection when EVs predominate.  There is no option that will not either add to the purchase price or be regressive.  Her conclusion sums it all up:

For the umpteenth time, then, we have our dear Western governments try to have their transition cake and eat it, too, and not gain a single ounce of extra weight. They wanted combustion engine cars out but forgot that these cars bring in billions in tax income. They wanted a fully electrified transport but forgot it wouldn’t bring in money unless they made it more expensive. They wanted a revolution but forgot rule #1 for revolutions: the successful ones never start from the top. They start from the bottom.

Separating NRDC “Facts” From Fiction Reality Check

The lead to the Natural Resources Defense Council (NRDC) blog post Separating Fact from Fiction: Setting the Record Straight on New York’s Climate Law states “Don’t be fooled by the fossil-fueled campaigns to delay climate progress. The Climate Leadership and Community Protection Act is New York State’s chance for a cleaner, healthier future.”  It goes on to refute four claims allegedly pushed by fossil fuel industry.  I am only going to respond to one of the responses.

I have followed the Climate Leadership & Community Protection Act (CLCPA) since it was first proposed, submitted comments on the CLCPA implementation plan, and have written over 400 articles about New York’s net-zero transition. I am convinced that the CLCPA will adversely affect affordability, reliability, and that the environmental impacts of the proposed transition are greater than the possible impacts of climate change.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The CLCPA established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The CLCPAion Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. 

The NRDC blog post describes the Scoping Plan framework as “pathways for a planned and orderly transition to a clean, resilient energy future.”  The Scoping Plan is just a list of potential control strategies that when combined are supposed to meet the CLCPA mandates.  A feasibility analysis has never been completed to show that the list of strategies is practical.  Furthermore, transparent accounting for the costs of the transition have not been provided and the Cumulative Environmental Impact Assessment has not been updated to account for the Scoping Plan estimates of the wind, solar, and energy storage resources needed.

NRDC Setting the Record Straight

The blog post Separating Fact from Fiction: Setting the Record Straight on New York’s Climate Law includes responses to four claims:

  1. The CLCPA will result in higher energy costs for ratepayers because it is costly to implement.
  2. The CLCPA will reduce the reliability of energy delivered to homes and businesses.
  3. Your gas stove is going to be taken away from you.
  4. There will be an adverse impact on the state’s overall economic climate that will discourage new investments and job growth.

I am only going to address the response to the second claim that the CLCPA will “reduce reliability of energy delivered to homes and businesses”.  The response to that claim states:

The framework outlined by the CLCPA-mandated Scoping Plan provides pathways for a planned and orderly transition to a clean, resilient energy future. The idea of a regenerative rather than an extractive economy strikes fear in the fossil fuel industry, which has been making record profits from recent price fluctuations and market volatility; in reality, reliability failures are often due to fossil-fueled superstorms and the historical lack of investment in our nation’s aging infrastructure. By contrast, homegrown renewable energy can and will be more resilient, more plentiful, and more cost-effective than finite oil and gas resources.

I will address each of these statements.  The first sentence states “The framework outlined by the CLCPA-mandated Scoping Plan provides pathways for a planned and orderly transition to a clean, resilient energy future.”  As noted previously there has never been a feasibility analysis to determine if the components of the Scoping Plan are practical.  The Climate Action Council never resolved the discrepancy between the Council faction that believed that no new technology is needed for the transition and the experts responsible for the system that argued otherwise.  A recent technical conference showed that the work of  Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell; Zach Smith, VP System Resource Planning, New York Independent System Operator; and Kevin Steinberger, Director, Energy and Environmental Economics all found that a new resource that can be dispatched when needed, is firmly available, and has no emissions is needed.  Technologies to meet this requirement are not commercially available at this time.  Moreover, no jurisdiction anywhere has been able to convert their electric system to one that relies on wind, solar, and energy storage.  Given the myriad technical issues that must be overcome to provide electricity when it is needed most, I think the most prudent course of action would be a demonstration project because the transition to the energy system mandated by the CLCPA would be unprecedented.

The second sentence unnecessarily questions the motivations of those who worry about reliability “The idea of a regenerative rather than an extractive economy strikes fear in the fossil fuel industry, which has been making record profits from recent price fluctuations and market volatility; in reality, reliability failures are often due to fossil-fueled superstorms and the historical lack of investment in our nation’s aging infrastructure.”  The concern about profiting from price fluctuations and market volatility is naïve.  When the electricity market is dominated by weather dependent generating resources the variability of wind and solar output will increase price fluctuations.  The New York Independent System Operator will have to modify the electric market to address this volatility as they learn how this new aspect of the system affects prices.  I have been involved with the weather-related impacts on the electric system for over 40 years and it has always been true that extreme weather has the greatest impact on system outages.  A common theme throughout this blog post is that all weather events are necessarily related to climate change without acknowledging that extreme weather events exactly like those before the climate change would still have major impacts.  Any increase in severity due to climate change is just a tweak and not the primary driver.

The final sentence got my attention: “By contrast, homegrown renewable energy can and will be more resilient, more plentiful, and more cost-effective than finite oil and gas resources.”  I wondered how the author managed to claim that extreme weather will have more of an effect on today’s generators in weather proof buildings than the exposed wind turbines and solar panels.  The more resilient reference was to the Babcock Ranch a Florida “solar town” that fared well during recent hurricanes.  The article claims the town came out of Hurricane Ian “almost unscathed and notes that one resident says they survived ‘by design.’  Florida Power and Light is proud of the Babcock Ranch solar system:

Babcock Ranch’s clean energy efforts were taken to the next level when FPL created the largest solar-plus-storage system operating in the U.S. today. Each of the ten large gray steel battery storage units at the FPL Babcock Ranch Solar Energy Center can store 1 megawatt of power and discharge for 4 hours. The adjacent 440 acres with 330,000 solar panels can generate up to 74.5 megawatts of power. Currently the solar installation generates more power than the town needs, so the surplus goes into the electric power grid. The new battery storage system ensures a steady output of power even on partly cloudy days.

There are two resiliency features that matter: Babcock Ranch was built 30 feet above sea level and all power lines are buried underground to keep them safe from strong winds.  New York’s net zero transition does not include buried power lines.  The Babcock Ranch website refutes the claim that “homegrown renewable energy can and will be more resilient”:

Electric power always flows from the nearest generation, so during the day the town will use energy from the FPL Babcock Ranch Solar Energy Center. When the sun goes down and the solar plant is not generating energy, Babcock Ranch will pull electricity off the grid from the closest FPL natural-gas power plant.

Babcock Ranch is not clean energy self-sufficient as the Climate Act envisions the entire state will be. The NRDC response also claims that renewable energy is more plentiful and more cost-effective than finite oil and gas resources.  It may be true that solar and wind energy is free but harvesting those resources, storing them for when they will be needed during an extended period of light winds in the winter when solar resources are low is an extraordinary challenge that requires the new resource described above.  Like all the Green Energy solutions advocated by the NRDC, wind and solar may work well most of the time but when you really need them, they don’t work at all.  The concern about finite oil and gas resources ignores the value of their storable concentrated energy and whether running out is a concern in the foreseeable future.

Conclusion

I believe I have shown that the NRDC fact-check claims that the CLCPA energy transition does not threaten reliability are invalid.  Ignoring the mounting evidence that this may be an insurmountable challenge is not in the best interest of New Yorkers.  At a minimum, CLCPA implementation should be delayed until we are sure that we can afford the CLCPA mandates, prove that the transition will not adversely affect reliability, and understand all the cumulative environmental impacts.

As is typical, whenever someone is screaming about misinformation it usually means that they are guilty of that charge.  In addition, trying to respond to this tripe takes an order of magnitude more work to respond.  Finally, whenever I make the effort to check the numbers I find the alarmists have their thumbs on the scale and are peddling a narrative to support their livelihoods.  I only wish that they could be held accountable when reality slaps their aspirational net-zero transition dreams back to earth.

“Powerless in the storm” Climate Industry Misdirection

A version of this post appeared at Watts Up With That

I came across a paper that concludes “The US power grid is proven to be highly reliable in general; however, the resilient and reliable grid operation is increasingly challenged by severe weather events–events that are increasing in frequency and magnitude due to climate change.”  I have many issues with this paper, but I am only going to discuss one.  Apparently peer reviewed papers today require marginal support for claiming increasing severity because everyone knows that climate change affects the frequency and magnitude of severe weather events

This analysis is typical of the reports used to justify the Climate Leadership & Community Protection Act (Climate Act).  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. This post explains why the connection between this work and climate change is tenuous.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Powerless in the Storm

The paper in question is  “Powerless in the storm: Severe weather driven power outages in New York State, 2017–2020” (Flores NM, Northrop AJ, Do V, Gordon M, Jiang Y, Rudolph KE, et al. (2024) Powerless in the storm: Severe weather-driven power outages in New York State, 2017–2020. PLOS Clim 3(5): e0000364. https://doi.org/10.1371/journal.pclm.0000364)

The only proof cited to “support climate change is increasing weather variability” is the reference to this sentence: “The power grid’s vulnerability to severe weather events becomes even more critical in the context of climate change, which is expected to increase weather variability and prevalence of extreme events (e.g., storms, wildfires, heatwaves, floods)”.  The reference included cites the latest Intergovernmental Panel on Climate Change report: IPCC, 2022: Climate Change 2022: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Portner H.-O., Roberts D.C., Tignor M., Poloczanska E.S., Mintenbeck K., Alegrı´a A., Craig M., Langsdorf S., Lo¨schke S., Mo¨ ller V., Okem A., Rama B. (eds.)]. Cambridge University Press. Cambridge University Press, Cambridge, UK and New York, NY, USA, 3056 pp., https://doi.org/10.1017/9781009325844

The Other Side of the Story

However, if the authors were to look at the actual IPCC report rather than what they assumed it would say about the example weather events (storms, wildfires, heatwaves, floods) the narrative falls apart.

The CO2 Coalition published a paper prepared by Richard Lindzen, William Happer, Steven Koonin on April 16, 2024 titled Fossil Fuels and Greenhouse Gases Climate Science.  Richard Lindzen, Professor of Earth, Atmospheric, and Planetary Sciences, Emeritus  Massachusetts Institute of Technology; William Happer Professor of Physics, Emeritus Princeton University; and Steven Koonin  University Professor, New York University, Senior Fellow at the Hoover Institution reviewed what the IPCC documents actually said about these extreme weather events.  The paper explains:

Hurricanes. A deep analysis of the facts reveals that “the data and research literature are starkly at odds with this message” — “hurricanes and tornadoes show no changes attributable to human influences.” Id. pp. 111-12. Further, “There has been no significant trend in the global number of tropical cyclones nor has any trend been identified in the number of U.S. land-falling hurricanes.” U.S. Global Climate Research Program, 3rd National Climate Assessment, Appendix 3, p. 769 (footnotes omitted).

Wildfires. There is a powerful new source of data on wildfires, “Sophisticated satellite sensors first began monitoring wildfires globally in 1993.” Id. p. 142.

The result of this new source of data is totally contrary to what is in the news. Unsettled cites NASA data and others that show the global area burned by fires declined each year from 1998 to 2015:

“Unexpectedly, this analysis of the images shows that the area burned annually declined by about 25% from 1998 to 2015.” Further, “Despite the very destructive wildfires in 2020, that year was among the least active globally since 2003.” Id. p. 142.

Heat Waves. On extreme temperatures in the U.S., we all agree: “The annual number of high temperature records set shows no significant trend over the past century, nor over the past 40 years.” Koonin, supra, p. 110.

Flooding: US data shows “modest changes in US rainfall during the past century haven’t changed the average incidence of floods.” Globally, data from the IPCC shows that there is “low confidence regarding the sign of trend in the magnitude and/or frequency of floods on a global scale.”  We all agree with the summary in Unsettled: “we don’t know whether floods globally are increasing, decreasing, or doing nothing at all.” Id. p. 137.

Discussion

I have nothing to add to the main point that the authors of this paper just assumed that the IPCC found that extreme weather events were increasing despite evidence in the latest report to the contrary.  The peer review process did not call them out on this. 

For the record the authors, their roles and affiliations follow:

Nina M. Flores

ROLES Conceptualization, Data curation, Formal analysis, Writing – original draft, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Alexander J. Northrop

ROLES Conceptualization, Data curation, Writing – review & editing

AFFILIATIONS Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America, Vagelos College of Physicians and Surgeons, Columbia University, New York, New York, United States of America

Vivian Do

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Milo Gordon

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Yazhou Jiang

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Electrical and Computer Engineering, Clarkson University, Potsdam, New York, United States of America

Kara E. Rudolph

ROLES Conceptualization, Methodology, Writing – review & editing

AFFILIATION Department of Epidemiology, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Diana Hernández

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Sociomedical Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Joan A. Casey

ROLES Conceptualization, Funding acquisition, Methodology, Writing – review & editing

AFFILIATIONS Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America, Department of Environmental and Occupational Health Sciences, University of Washington, Seattle, Washington, United States of America

One final point is that my impression of the analysis is that the authors had pre-conceived conclusions in mind and tortured the data to get the results desired.

Conclusion

I have to assume that this is an example of the Climate Industry’ Misdirection Campaign described recently by Kip Hansen.  All of the authors are associated in some way with public health departments at universities.  I doubt that any of them has any background in climatology or meteorology beyond a possibly a class or two in introduction to Climate Change – The Existential Threat.  Today it is sufficient to just note that extreme weather is getting worse due to climate change to hype the results claimed because the peer reviewers know that is “true”.

Facebook Post that Gets It

Pragmatic Environmentalist of New York Principle 6 is Roger Pielke Jr’s: Iron Law of Climate: “While people are often willing to pay some price for achieving climate objectives, that willingness has its limits.”  A recent Facebook comment to a National Grid Facebook social media campaign post provides a perfect example related to New York’s Climate Leadership & Community Protection Act (Climate Act).

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  There is growing evidence that the state will be unable to achieve its goals without significantly affecting the cost of living and doing business in New York and harming the reliability of its electric grid.

National Grid

In my opinion no company doing in business can publicly question the Climate Act narrative without facing the wrath of emotion-driven activists and getting crosswise with the Hochul Administration.  Although the Public Service Commission utility rate-making process to establish “just and reasonable” rates is supposed to be apolitical, the old days when governors appointed Commissioners from both parties to maintain balance are gone.  I have no doubt whatsoever that any utility that does not encourage electrification to save the environment at every opportunity would find itself not getting their rate case proposals approved.  Moreover, an electric utility has incentives to sell more electricity.  The problem is that electrification everywhere is not a pragmatic solution.

I am in the former Niagara Mohawk Power Corporation service territory now served by National Grid New York. Given the political climate of New York it is no surprise that National Grid advocates for the “Journey to net-zero”.   I am not a big social media person but do get on Facebook occasionally.  Frequently, there are posts from National Grid advocating for the latest and greatest gadgets for electrification. For example, the following recently showed up.

There were options for different “learn more” links.  What caught my eye was the following comment to this post. It the perfect example of Pielke’s Iron Law:

The Iron Law can be described as wallets have limits.  Beyond the simple cost impacts there is another concern.  The National Grid Upstate New York Residential Gas Heating program is paused and not accepting rebate applications. National Grid is forgoing efficiencies now to encourage adoption of cold-climate heat pumps.  This is disservice to National Grid ratepayers because it does not acknowledge thatthe State’s Scoping Plan to implement the Climate Act notes that not all homes will be able to electrify home heating safely and affordably.  Exactly the case in this example. It is not only that there is a cost factor but there is a safety factor for electrification.  Removing incentives for homeowners that have no other choices is short-sighted.

Conclusion

Implementation of the Climate Act is going to affect affordability and safety.  The public is starting to catch on to these impacts.  It is time to pause implementation until the Hochul Administration provides comprehensive and transparent cost estimates for the transition and the Public Service Commission provides a plan to ensure safe and reliable service to electric customers for an electric system that relies on wind and solar.  The utility industry is not going to step up and ask for an implementation pause so it is up to the voters of the state to make their concerns known.

Ronald Stein –  Net-Zero Transition Lesson from Germany

Ronald Stein’s Energy Literacy Newsletter is an excellent resource.  This post reproduces his latest article.  He says:

As the United States follows Germany’s green deal, YOU should anticipate uncontrollable electricity prices. If you think your electricity prices are high now, brace yourself for what’s coming!

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. Proponents of the Climate Act refer to Germany’s transition as an example to emulate but show no sign of understanding all the issues.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Ron Stein Overview

Stein’s newsletter provides an overview of his primary concerns:

My books have a common theme as they address the elephant in the room that the ruling class and the media refuse to talk about, i.e., the lack of products in the future, and the lack of fuels for planes, ships, militaries, and space programs, manufactured from the fossil fuels that built the world from 1 to 8 billion people in less than 200 years.

Without a planned replacement for crude oil to make those same products, limiting the supply of the products and fuels manufactured from crude oil will inflict shortages and inflation in perpetuity on current lifestyles.

Energy literacy starts with the knowledge that Crude oil is the basis of our materialistic society… All the components and equipment for the generation of electricity by wind, solar, coal, natural gas, nuclear, and hydro are all made from the oil derivatives manufactured from crude oil !

For the 8 billion on this planet that are quite dependent on food and medications, those wind turbines and solar panels cannot manufacture any of the fuels for 50,000 ships, 50,000 planes, militaries, and space programs, nor can they make the 6,000 products in our daily lives. Enhancing ones energy literacy will empower individuals to have conversations on energy at the dinner table with friends and co-workers.

Net-Zero Transition Lesson from Germany Uncontrollable Electricity Prices

The remainer of this post reproduces his latest newsletter article:

Germany was the first country to go “green”. Today, Germany now has some of the highest prices for electricity in the world and the number of Germany’s corporate insolvencies in March 2024 reached the highest level on record as the Great Green Electricity economic debacle continues.

The push to “green” electricity from wind and solar, and away from conventional sources, began in earnest under the government led by Germany’s Angela Merkel and her CDU center right party. The latest Socialist-Green coalition government, led by Olaf Scholz and Robert Habeck, have since pushed further draconian policies that have only exacerbated Germany’s economic and electricity woes.

In addition, high electricity prices in Germany and inflation are sapping consumers’ purchasing power, which further aggravates the economic situation. Currently, Germany is resorting to restarting several mothballed coal plants to keep the lights on as their wind industry continued its long record of failure to live up to promised performance and cost levels.

Shockingly, most of America and the Western Countries are following the German green movement, and are forging ahead with shuttering their generators of reliable, continuous, and uninterruptible electricity generation, that may be dispatched at short order as required by the network load, and adding more weather-dependent variable renewable electricity with almost no regard to electricity reliability or affordability to support hospitals, airports, offices, manufacturing, military sites, data centers, the general consumer public and telemetry, that all need continuous uninterruptable supplies of electricity.

Of the six electrical generation methods, occasional generated electricity from wind and solar cannot compete with reliable, continuous, and uninterruptable electricity from hydro, nuclear, coal, or natural gas:

  • Wind and solar generate occasional electricity, due to the time of day and the inherent vagaries of weather.
  • Hydro, nuclear, coal, and natural gas generate continuous uninterruptible electricity.

Solar and wind generators, as currently widely employed by the dreamers in Germany, America, Australia, and the UK, are inherently unreliable and cannot ever provide the continuous, uninterruptable, and reliable electric power as is generated by coal, oil, nuclear and hydro systems. Their use, under mandatory policies of governments, is forcing the consumer to subsidize net-negative dreams of intermittent electric power from breezes and sunshine. Such speculative ventures should not be funded by the taxpayer, they should be required to obtain funding from commercial entities and independent investors.

It is incomprehensible that twenty-three states in America have adopted goals to move to 100 percent “clean” ELECTRICTY by 2050. The elephant in the room that no policymaker understands nor wants to discuss is that:

  • The nameplate generation capacity of both solar and wind equipment is a total farce. Time of day solarization and the vagaries of weather determine the power output of both systems, this has no relationship whatsoever with the nameplate capacity value. As these systems also exhibit frequent mechanical failures due to wear and damage from weather conditions, they should be subject to penalties for periods of inactivity. Further, they should be subject to additional penalties for failure to provide adequate back-up generation during periods when there is no sun illumination, or the wind speed level is inadequate.
  • Occasional electricity generated from wind and solar CANNOT ever support hospitals, airports, offices, manufacturing, military sites, data centers, computers, and telemetry, that all need continuous uninterruptable supplies of electric power.
  • Wind and solar CANNOT manufacture anything as neither the occasional electricity from wind turbines nor solar panels, can replace the supply chain of products from crude oil that are the foundation of our materialistic society demanded by the 8 billion on this planet.

Practically every wind turbine or solar panel requires a backup from coal, natural gas, or nuclear, thus understanding electricity generation’s true cost is paramount to choosing and prioritizing our future electricity generating systems.

When we look outside the few wealthy countries, we see that at least 80 percent of humanity, or more than six billion in this world are living on less than $10 a day, and billions living with little to no access to electricity.

Politicians and policymakers in the few wealthy countries are pursuing the most expensive ways to generate intermittent electricity. Electricity poverty is among the most crippling but least talked-about crises of the 21st century. We should not take electricity for granted. Wealthy countries may be able to bear the cost of expensive electricity and fuels, but those that live under conditions of “electricity poverty” cannot do so.

Germany was the first country to go “green”. Most Germans used to be enthusiastic supporters of the country’s Energiewende (transition to renewable electricity from wind and solar), especially in the early days when they were brazenly misled about the endeavor’s humungous costs and technical limitations. Those days are gone. Finland, France, China, Japan, and others are not following the lead of Germany that now has the highest cost for their electricity, and that electricity generation is occasional as it depends on breezes and sunshine.

Finland already gets about a third of its electricity from nuclear generation and has joined France, UK, China, Japan, and others as they pursue dependable, reliable, affordable, and zero emission electricity by ramping up their nuclear power generations capabilities. The Finnish government has announced that the first order of business is expanding Finland’s nuclear power generation capacity as soon as humanly possible.

Solar and wind power are specified by the state government to be critical to meeting California’s ambitious requirement to switch to 90% carbon-free electricity generation by 2035 and to 100% by 2045. This policy has resulted in the state continuously shutting down coal, natural gas, and nuclear generating stations that provide continuous uninterruptible electricity in favor of occasionally generated electricity from renewables However, in spite of the policy and renewable stations built, California now imports more electric power than any other US state, more than twice the amount in Virginia, the USA’s second largest importer of electric power. California typically receives between one-fifth and one-third of its electricity supply from outside of the state.

Most experts argue that the government hasn’t been fixing problems, rather it has been making them far worse. It simply refuses to acknowledge the reality and participate in conversations regarding the real verifiable science of the world’s climate changes. 

A situation is developing in the US where personal debt and homelessness numbers are increasing at an alarming rate. The average debt in this country is greater than $100,000 per person (across credit cards, mortgages, auto loans and student loans), and with more than half of Americans living paycheck-to-paycheck, society is facing an unsustainable problem where those “financially challenged” will never pay off their continuously increasing debt.

Further, the loss of employment resulting from failed businesses, the failure of which is mostly caused by impossible increases in power costs, has forced many more people into a homeless situation. It is not possible to forecast the rate of rise of homelessness, but it will increase substantially as power prices continue to escalate under a failed renewable electricity policy.

The question that must be answered is how the electric power process can be brought back to sustainable levels to halt the failure of businesses and the resultant increases in poverty and homelessness.

Wind turbines and solar panels are recipients of free breezes and free sunshine, plus humongous government subsidies, so the question needs to be asked of those in charge of electricity policy in the governments of the USA why are ELECTRICITY PRICES ESCALATING AT AN ALARMING RATES?

Conclusion

Everything in Stein’s article is applicable to New York’s Climate Act.  It cannot end well.

If you like this article sign up for Ron’s newsletter here.

Articles of Note

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered.   This is a summary of articles that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Videos

  • Good news about climate  Judith Curry explains why the climate and environment is going fine.
  • More praise for Climate Change the Movie.   Fergus Kelley writes “A rare and refreshing rebuttal of that incredibly powerful climate change conspiracy.”
  • Climate Discussion Nexus has a “backgrounder” video look at “how scientists use temperature proxies to estimate past climate conditions … and in some cases misuse them because they’re so sure what the evidence should say that they ignore what it does say.”
  • Steve Milloy discusses the economy-killing ‘climate’ agenda with Stuart Varney on FOX Business.

Zero-Emissions Freight Sector Fantasy

Charles Rotter wrote a masterful takedown of the latest net-zero transition fantasy – the national goal of a zero-emissions freight sector. 

The Biden-Harris zero-emissions freight initiative, with its lofty ambitions and sweeping promises, is emblematic of a broader trend in contemporary environmental policymaking: prioritizing grandiose goals over grounded feasibility studies and economic realism. This plan, rather than being a practical roadmap for any type of environmental improvement, is a political statement intended to signal virtue rather than effectuate its stated goals.

In summary, this “strategy” is nothing more than a modern-day environmental quixote, tilting at windmills of pollution with a lance of impracticality and a shield of buzzwords like “environmental justice.”

The Climate Act is no different than this strategy.

Impact of NYS GHG Emissions on Global Temperature

Parker Gallant Energy Perspectives published Actual Impact of CO2 Emissions On Global Temperature that was written and researched by Pav Penna.  Penna researched the Intergovernmental Panel on Climate Change’s most recent teport:

IPCC estimates that the impact on temperature of a trillion tonnes of atmospheric CO2 emissions is “likely in the range of 1.0 to 2.3°C” – a very broad range indeed. This is equivalent to 0.00001 to 0.000023°C per megatonne. IPCC’s “expert opinion” suggests a “best estimate” of 1.65°C per trillion tonnes of CO2.

Using that number, if New York’s 2021 GHG emissions were eliminated the impact on global temperature would be 0.00044 deg C.  A quantity that cannot be measured.

Net-Zero Transition Issues

Epic Emissions Engagement:  Irina Slav describes the inevitable collision of the Big Tech companies who are counting on carbon credits to achieve net-zero status and the staff at the Science Based Targets initiative that these companies fund.  She concludes:

It’s a catastrophe unfolding in slow motion and it was unavoidable. Call it a case of Frankenstein’s monster and while the monster of climate activism cannot run away from its corporate creators and wreak havoc on the global village, taming it has become increasingly hard. The monster has developed an overwhelming sense of mission that has trumped any and all other considerations, including survival. The fight between green money and green muscle may end up being the show of the decade.

Mark P. Mills – When Politics and Physics Collide.  The belief that mandates and massive subsidies can summon a world without fossil fuels is magical thinking. 

While policies can favor one class of technology over another, neither political rhetoric nor financial largesse can make the impossible possible. Start with some basics. It’s not just that currently over 80 percent of our energy needs are met directly by burning oil, natural gas, and coal—a share that has declined by only a few percentage points over the past several decades; the key fact is that 100 percent of everything in civilized society, including the favored “green energy” machines themselves, depends on using hydrocarbons somewhere in the supply chains and systems. The scale of today’s green policy interventions is unprecedented, targeting the fuels that anchor the affordability and availability of everything.

Bjorn Lomborg explains that Trillions in taxpayer subsidies haven’t made wind and solar power cheaper or better for Americans:

A new study looking at the United States shows that to achieve 100% solar or wind electricity with sufficient backup, the US would need to be able to store almost three months’ worth of annual electricity. It currently has seven minutes of battery storage.  Just to pay for the batteries would cost the US five times its current GDP. And it would have to repurchase the batteries when they expire after just 15 years.

Francis Menton describes a report by Thomas Pyle of the Institute for Energy Research put out a list of “200 Ways the Biden Administration and Democrats Have Made it Harder to Produce Oil & Gas.”  He goes on to show there is not much to show for all those efforts.  He concludes: “Our current rulers think that they have infinite ability to tell the people how to live, and infinite money to force the people to change their ways. They are wrong, and reality will catch up to them, if only gradually.”

Electric Vehicles

Robert Bryce has been skeptic about electric vehicles for 14 years and prepared ten charts that explain the current situation.  Also of note is that electric car demand plunges across Europe.

Natural Climate Change

One of the main points in Climate the Movie is that clouds are a major driver of climate change.  This article describes a theory that explains long-term solar variation and its effects on clouds. Javier Vinós concludes that there are two pieces of good news.

The first is that solar activity cannot rise above the 20th century maximum. It is not like CO₂, which can keep going up. The Sun’s activity can stay high or go down, but it cannot go up, so the warming should not accelerate and should not be dangerous.  The second piece of good news is that if much of the 20th century warming is due to the Sun, then there is no climate emergency.

Ellenbogen On NY Heats

According to New York climate activist non-governmental organizations New York is “failing to lead on climate.”   Sane Energy Voice claims that following Governor Hochul’s scrapping of major offshore wind projects, Assembly Speaker Heastie’s decision to ditch the popular NY HEAT Act signifies New York’s failure to lead on climate.  Richard Ellenbogen responded to the press release with an email that I reproduce here.

Richard Ellenbogen recently submitted comments as part of the record for the Department of Public Service Proceeding 15-E-0302 related to the net -zero mandate of the Last spring          “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.   His comments discuss “a viable, affordable, and rapidly executable  Plan B to assist NY State in reducing its carbon footprint  using technologies that actually exist at scale, unlike the technologies proposed by the CLCPA which only exist at scale in the fantasies of its proponents.”  I think it is important that his message gets out to all New Yorkers to try to avert the inevitable collision between aspiration and reality.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Leadership and Community Protection Act (CLCPA). I have published other articles by Ellenbogen, a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”,  another video presentation he developed describing problems with CLCPA implementation and a summary of his submitted comments as part of the record for the Department of Public Service Proceeding 15-E-0302 related to the CLCPA net -zero mandate.  There are only a few people in New York that are trying to educate people about the risks of the CLCPA with as much passion as I am, but Richard certainly fits that description.  He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences.  He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk.  

CLCPA Overview

The CLCPA established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation and legislation.  For the most part that did not happen so in 2024 organizations like Sane Energy Voice  are lobbying for various legislation to advance their agendas.

NY Heats

According to a report released by NY Renews, the if the full NY Home Energy Affordable Transition bill were passed “the 25% of New York residents who have high energy burdens would cut their bills by over 44% and save an average of $136 a month.” The mission of Sane Energy Project is to replace fracked gas infrastructure with 100% democratically controlled, renewable energy in New York State. We build every campaign through a lens of racial, social, and ecological justice.

Richard Ellenbogen responded to this press release:

In a one-two punch this past week, a small group of corporate-backed Democratic legislators brought us closer to climate catastrophe by bowing to fossil fuel lobbyists and lawyers in shaping New York’s energy and economic policy. Now, more than ever, it’s time to fight hard and resist this insidious takeover.

Last Friday, under the leadership of Governor Kathy Hochul, the New York State Energy and Resource Development Authority (NYSERDA) rejected three major offshore wind projects that Sane Energy Project had championed since 2015 when we led the campaign to stop the construction of a massive offshore liquefied fracked gas port complex near the  Rockaway Peninsula and Long Beach that would have foreclosed the development of these wind projects.  

Also on Friday, the final New York State budget omitted the critical NY HEAT Act, which over 100 legislators co-sponsored. The New York Home Energy Affordable Transition Act would have facilitated an orderly transition from expensive and toxic fracked gas by ending subsidies that enrich the gas industry. Moreover, it would have capped energy bills for low- and middle-income households at 6% of their income, a crucial measure for safeguarding vulnerable New Yorkers. 

Every year in Albany, a handful of officials determine the state’s future. Swayed by energy industry lobbyists, they disregard scientific evidence, the climate law, and constituents’ demands. Our elected officials’ failure to champion sound energy policy sets a dangerous precedent.

Kim Fraczek, Director of Sane Energy Project, said, “Governor Hochul and Assembly Speaker Carl Heastie have chosen to prioritize corporate interests over the well-being of New Yorkers by scrapping significant offshore wind projects and excluding the crucial NY HEAT Act from the state budget. Their inaction is further underscored by National Grid’s egregious proposal to increase monthly bills for downstate residents by at least $30 to maintain their outdated, polluting gas system. We hold Hochul and Heastie responsible for future utility bill hikes and climate disasters, as their decisions blatantly ignore the urgency to transition to renewable energy and protect the most vulnerable communities.”

Current negotiations surrounding National Grid’s proposed rate hike threaten to tighten the fossil fuel industry’s grip on New Yorkers. Sane Energy Project is focused on state regulators, who can choose energy efficiency and investment in thermal energy networks or perpetuate wasteful investments in National Grid’s antiquated gas system.  

Before I describe Ellenbogen’s response I want to address the offshore wind projects.  The emotion laden description of recent events: “Swayed by energy industry lobbyists, they disregard scientific evidence, the climate law, and constituents’ demands” is at odds with reality.  NYSERDA did not want to reject the three major offshore wind projects.  Instead, “GE Vernova’s decision to alter its offshore wind turbine product from the initially proposed 18 MW Haliade-X platform to a 15.5/16.5 MW platform resulted in significant changes to the projects proposed into the solicitation.”  When NYSERDA announced the contract awards last October all the subcontractor agreements should have been clearly identified and signed off by all parties involved in the work, including things like what equipment, what labor costs, you name it.  After an award there is some negotiation but that should not be a big lift because the details were already identified in the proposal/budget.  The size of the turbines should have been specified in the proposal. If GE as a subcontractor then changed the deal it would make the whole proposal unfundable.  This is the last thing NYSERDA and Governor Hochul wanted because it means a big delay in the timeline as they need to have go back for another round of approvals and new contracts.

Ellenbogen on NY Heats

Other than a few formatting edits the following is all by Ellenbogen.

While I appreciate your passion, the  science behind your email is misguided.  As someone that decarbonized my home and business over two decades ago as the two following links document, I can assure you that there is nothing “sane” about NY Heats.  It will literally be a death knell for both NY State residents and the state economy with absolutely no benefit to the environment.  FYI, I have absolutely no interests in the fossil fuel industry but as an engineer for over forty years,  I have a firm belief that all public policies have to be based upon scientific accuracy.  NY Heats and the CLCPA throw science and math out the window.

In a climate like NY State’s, NY Heats defies the Laws of Thermodynamics beyond there also being enormous logistical issues with implementing  it.

  1. It will double or triple the load on every transformer in the state meaning that they will all have to be replaced, except those transformers don’t exist and there is an acute transformer shortage in the entire US at the moment.  The doubling or tripling of load will also mean replacing all of the wires in NY State which will take about 60 years.  Further, that will require an enormous amount of aluminum and there isn’t enough aluminum available to make beverage cans, let alone millions of miles of electrical conductors.  Three aluminum smelters have closed in the United States in the past two years because their electric rates were too expensive, which is indicative of a shortage of electricity driving up the prices.  There have been numerous articles written recently that indicate that the United States is running out of energy.
  • That same electric shortage will also provide insufficient energy to operate the heat pumps that would be installed under Local Law 97 and NY Heats.  Despite everyone’s wishful thinking, renewables are too intermittent and have too low of an energy density  to successfully operate the expanded utility system that would be required under NY Heats.  The NYS Public Service Commission is desperately looking for DEFR’s (Dispatchable Emission Free Resources) except with the exception of Nuclear which takes 17 years to get approved and sited, that technology does not exist and it is decades away so any increases in load that would result from NY Heats will increase fossil fuel generation where it is far less efficient than the onsite combustion of Natural Gas.  The NYISO is already having difficulty meeting the scheduled deadline for closing the fossil fuel peaker plants and has extended their closing dates.  That is going to be repeated extensively because there just isn’t enough energy and adding more solar panels and wind turbines will complicate that effort after a certain point.  Look at what is currently happening in California.  They are dumping solar because they over subsidized it and there is too much.  The storage technology needed to utilize it is far too expensive to implement at that scale.  If you look at NYSERDA’s 6 GW Enregy Storage report from 2022, they indicated that 1000+ hours would be needed to support the system.  Even at 1000 hours for 6 GW at the price of storage in the report, that would cost $3.5 Trillion, or 15 times NY State’s annual budget and those batteries would last only ten years and have to be replaced.   While battery costs have come down slightly since 2022, it has not been nearly enough to make them cost effective.  The physics and the economics just don’t work.  It has also been clearly documented that air source heat pumps double utility bills.  That higher cost is a function of the holistic system wide energy inefficiencies of the air source heat pumps.  Hydrogen storage technology is decades away at the utility scale needed.  It is very difficult to store and transport and it presents its own GHG issues if it leaks.
  • There is insufficient labor to execute the plan.  There is a shortage of both electricians and plumbers and worse, there are not enough people to train even if they could develop the training programs.  There are currently 500,000 open manufacturing jobs in the US, the same cohort of people that would be used for renewable and heat pump installation.  The unemployment rate is near historic lows.   Further, one thing that no one should want is inexperienced people handling the refrigerants involved with heat pump installation as those have carbon footprints 300 – 1000 times higher than CO2 and 10 – 30 times higher than methane.  The leakage that will result from inexperienced workers handling refrigerants would be devastating.  A Columbia University study indicated that one-half of Arctic ice melt resulted from the use of refrigerants.
  • Regarding Offshore Wind, those bids were declined because the costs were far higher than the current electric rates.  If the state has any hope of decarbonizing, alienating 60% of its population downstate with exorbitant electric rates is not the way to do it.  That is especially true when 1.2 million downstate utility customers are already $1.8 billion in arrears.  Further, the ships needed to install the offshore wind don’t exist at present.  The first Jones Act compliant ship, the Dominion Charybdis left dry dock last week.  The $650 million vessel is taking five years to build and will not be ready until late 2024/ early 2025.  If they start another now, it will not be ready until 2028- 2029.  The lack of the ships raises the installation costs far above where they otherwise would be which explains why the bids here are about double those in Europe where they have about 16-18  available jack ships.  The balance of the world’s approximately 50 jack ships are in Southeast Asia.  Energy cost increases resulted in the repeal of the Ontario, Canada energy plan after only 10 years.  The same thing will happen in NY State if they aren’t careful.

Decarbonization is necessary but it must follow the Laws of Physics and be mathematically possible to implement.  The NY State plan doesn’t adhere to those requirements.  There are things that adhere to science and mathematical accuracy that can be done to reduce the state’s carbon footprint but the CLCPA and NY Heats do not fall within that criteria.

Conclusion

In an email Ellenbogen concludes that “For anyone that understands energy math, the bill is a farce.   The points made in it also don’t adhere to economic reality for the residents of NY State.”  I completely agree with his conclusions.

Comments on the New York Part 490 Projected Sea-Level Rise Amendments

The New York State Department of Environmental Conservation (DEC) has proposed Amendments to Part 490, Projected Sea Level Rise and Comments that are due on April 29.  This post describes my comments on the proposed amendment and requests that New Yorkers who reading this before April 29 submit comments.  Don’t worry, I will give language.

The proposed amendments revise the projections of future sea-level rise required by New York regulations.  It is flawed because the methodology estimates an unrealistically high projected sea-level for the Community Risk and Resiliency Act flood risk management applications that will use the projections.  Unless more realistic estimates are used permitting applications in areas near tidal zones will be required to incorporate flood levels that will not be expected in the lifetime of the project.  That would be a hidden cost for the net-zero  transition of the Climate Leadership & Community Protection Act (Climate Act).

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The summary of the Part 490 proposed amendments states that: “The goal of the proposed amendments is to provide up-to-date science-based projections of future sea level rise.”  This is another example of the many ways that the Climate Act is intruding on many aspects of society.  The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation but implementation is behind schedule.  The proposed amendments to the sea-level projections are a hidden aspect of the Climate Act that has significant potential impacts.

Part 490 Projected Sea-Level Rise

The Regulatory Impact Statement (RIS) for this proceeding describes the regulation’s statutory authority and legislative objectives, the proposed changes, needs and benefits, and costs.  It explains:

On September 22, 2014, the Community Risk and Resiliency Act, Chapter 355 of the Laws of 2014 (CRRA), was signed into law. CRRA, among other things, established Environmental Conservation Law (ECL) § 3-0319. ECL § 3-0319 requires the Department of Environmental Conservation (Department) to adopt regulations establishing science-based sea level rise projections for New York State and to update them no less than every five years. The Department established a new Part 490 of Title 6 of New York Codes, Rules, and Regulations (6 NYCRR), “Projected Sea-level Rise” (Part 490) in February 2017 and is updating the regulation through the current rulemaking.

The proposed amendments are an update of the 2017 sea-level rise projections.  While I am not absolutely sure I believe the reason that this amendment was delayed was because the primary reference, New York Research & Development Authority New York State Climate Impacts Assessment, was not available within the five-year period.  Even so, the documents for the Assessment are all marked “Interim Version for Public Release” which calls into question their use for a policy document.

The summary of the Part 490 proposed amendments states that:

The goal of the proposed amendments is to provide up-to-date science-based projections of future sea level rise. Part 490 does not create a mandate on local governments. Part 490 does not impose any compliance obligations on any entity.

While technically and legally correct, the excuse not to include costs and the argument that there are no compliance obligations or mandates on local governments has significant ramifications.  The fact is that there are compliance obligations that are affected by the Part 490 rulemaking.  DEC selectively chose to emphasize analyses that support the “high-end storyline” without regard to how the sea-level rise projections will be used. There are relevant, plausibility, timing, and cost implications that I believe should be added to the Regulatory Impact Statement.

Mandates on Local Governments

The CRRA as amended by the Climate Act clearly creates indirect mandates on local governments.  The New York State Flood Risk Management Guidance for Implementation of the Community Risk and Resiliency Act  includes “recommendations” for the use of sea-level rise that are essentially mandates.  In another example where the projections are used, the DEC webpage Mainstreaming Consideration of Climate Change includes the following:

Consideration of future physical climate risk

As originally enacted, the CRRA required applicants for permits or funding in a number of specified programs to demonstrate that future physical climate risk due to sea-level rise, storm surge and flooding had been considered in project design, and that DEC consider incorporating these factors into certain facility-siting regulations.  The CLCPA amended the CRRA to include all permits subject to the Uniform Procedures Act. The CLCPA also expanded the scope of the CRRA to require consideration of all climate hazards, not only sea-level rise, storm surge and flooding, in these permit programs. 

In my comments I argued that that while Part 490 may not directly create a mandate on local governments, all permits must consider the sea-level rise climate hazard which is essentially a mandate affecting all governmental agencies.

Part 490 Proposed Amendments

The RIS description of the proposed sea-level rise projection amendments with my annotated comments follows:

Table 4. Updated projections of sea level rise for three tidal regions of New York State, based on the Department’s proposed methodology. Projections are in inches, relative to a 1995-2014 baseline, and are based on a combination of the SSP2-4.5, SSP5-8.5-medium-confidence and SSP5-8.5-low-confidence projections, with the addition of a RIM scenario.

Part 490 is intended to give permitting authorities information on the full range of potential sea-level rise.  In reality the CRRA design considerations that use the sea-level rise projections focus on the highest values.  New York State Flood Risk Management Guidance for Implementation of the Community Risk and Resiliency Act  states that “Applicants and programs are also encouraged to consider the following during project siting, design and review” states:

Applicants for projects involving new or replacement critical infrastructure should consider the full range of projected flooding, including the highest adopted projections of sea-level rise, during the expected service life of the project. Where adherence to the highest guideline is not feasible, due to practicality, costs, risk tolerance, and/or environmental effects, applicants should carefully describe and justify designs not adhering to the most restrictive guideline.

Note the requirement to use “the highest adopted projections of sea-level rise” includes the caveat to consider the “expected service life of the project”.  That is  missing piece in the RIS.   The RIS emphasizes the point that the Intergovernmental Panel on Climate Change (IPCC) has not indicated the relative probabilities that any of the illustrative scenarios included in the latest assessment report (AR6) will occur.  However, CRRA infrastructure applications need to consider the likelihood of sea-level rise levels to determine practicality, costs, risk tolerance, and/or environmental effects.  The RIS argues that focusing on the most probable outcome has risks and warns of much higher potential sea-levels. 

Furthermore, Hinkel et al. (2015) warn that sea level rise projections based on process-based models, such as those used by IPCC, are primarily intended for the purpose of understanding earth system physics and are not appropriate for risk-based decision making as they do not fully incorporate the effects of accelerated ice melt. They warn that projections based on the IPCC AR5 projections of mean global sea level rise of 11 to 39 inches by 2100 may not be adequate for risk management due to the intolerably high residual risk associated with rapid ice melting Parris et al. (2012) also cautioned that focusing only on the most probable outcome could lead to vulnerability or maladaptation.

The reference to “intolerably high residual high residual risk associated with rapid ice melting” ignores the expected service life of the project consideration.  The RIS explains that the decision makers need to understand the full range of potential risk but does not acknowledge that their presentation of results discourages the use of anything but the high projections.  The result is that development near the tidal shoreline is planning for extremely high projected sea-level rise.  A New York City project to increase a park to handle 8 to 10 feet of sea-level rise is include in “a $1.45 billion flood protection project that backers say befits the nation’s largest city, a massive project that will include the construction of a 2.4-mile system of walls and gates along the East River”.  That is only a fraction of the harbor front in the City so it makes sense to use more reasonable estimates of sea-level rise given the need to protect the entire harbor of New York, but it is easier for DEC to just recommend the biggest number to “be safe”.

Decision makers, including residents and local leaders, should understand the full range of potential risk. Communities and stakeholders in New York State that have been presented with the ClimAID projections have tended to adopt and plan for high levels of sea level rise rather than more moderate levels. These stakeholders have placed a high degree of importance on ensuring the viability of proposed infrastructure investments and the social and economic fabric of their communities from even unlikely eventualities.

The “science-based” regulation and the guidance did a disservice to New Yorkers because the risk management approach did not adequately address tradeoffs between costs and likelihood of “unlikely eventualities”.  The sea-level rise projections rely on cherry-picked studies and ignoring any work that does not fit the extreme scenario used and that is not “science”. Unlikely things that just might happen in the distant future are not “eventualities”. All the extreme sea-level rise projections use the implausible high emissions scenario embodied in Representative Concentration Pathway (RCP) or Shared Socio-economic Pathways (SSP) RCP/SSP8.5.  There is overwhelming evidence that the coal use, population growth, and neglect to consider any decarbonization policy assumptions in those scenarios are inconsistent with observed reality.  The National Oceanic Atmospheric Administration (NOAA) Geophysical Fluid Dynamics Laboratory (GFDL) description of their globcal climate modeling approach that states “SSP5-8.5 is a very high greenhouse gas emissions scenario – and unlikely to happen – where carbon dioxide emissions triple by 2075″ and does not use it for their recommended projections.

Notwithstanding the arguments in the following paragraph from the RIS trying to justify its use, the fact is that using these projections are inappropriate to use in this context.  I do not dispute that the potential for rapid ice melt exists that would cause a spike in sea levels.  However, I maintain that is improper to use in this context because it is a low probability event but that in the time frame of CRRA infrastructure projects it is a much lower possibility. The argument that Part 490 guidance must address sea level rise that will “likely occur at some point” without consideration of the use of the projections is inappropriate.  The State simply cannot afford the ramifications of the insistence to remove risk entirely.

Finally, as explained above, sea level rise will continue for many centuries as the earth system comes into equilibrium over many centuries or even millennia. Thus, the question for decision makers is not if a critical sea level will be reached, but when. Strauss (2013) calculated that historic emissions have already committed the globe to a mean sea level rise of 6.2 feet. Levermann et al. (2013) estimated that the current international target of 2°C warming will result in an eventual mean global sea level rise of more than 15 feet after 2000 years. Thus, a full range of projections in Part 490 that includes higher values is appropriate to allow for consideration of a level of sea level rise that will likely occur at some point, even if the timing of such occurrence is uncertain. The Department acknowledges that current GHG emissions policies would result in actual emissions lower than projected by SSP5-8.5. Thus, the inclusion of higher projections of sea level rise, especially those based on SSP5-8.5, could lead to consideration of conditions that are unlikely to occur, at least in the more immediate future. Unfortunately, current literature does not provide a basis for assessment of the emissions levels at which ice shelf and marine ice cliff instability, important factors in sea level rise in high emissions scenarios, such as SSP5-8.5, become significant.

This paragraph characterizes my concern that the purpose of the sea-level rise projections was not considered enough.  Preparing for the next 2000 years for a city that was founded only 400 years ago is silly.

This gap in the literature, however, does not relieve decision makers from the responsibility to at least consider the potential consequences of future events about which scientific uncertainty remains. Adoption of several levels of projections allows for consideration of risk tolerance in decision making. The high or RIM projections might be used for long-term projects for which there is low risk tolerance, for example, while lower projections may be appropriate for consideration in situations in which risk tolerance is high. Inclusion of low-confidence, but plausible, projections provide benchmarks against which long-term decisions, e.g., those regarding critical infrastructure and land-use change, can be evaluated for high-consequence events. If Part 490 did not include higher projections of sea level rise, decision makers would not be able to even consider the possibility of such levels occurring. The Department proposes, therefore, to adhere to the recommendation of Stammer et al. (2019) to include “high-end storylines,” that reflect physical processes about which high uncertainty exists, i.e., the RIM scenario, with probabilistic projections.

The last paragraph in this section clearly describes the misguided DEC approach.  There is no question that decision-making when there is high scientific uncertainty is difficult.  From a risk management perspective all factors must be considered.  In this instance, the recommendation to use the higher sea-level rise projections for long-term projects does not consider CRRA infrastructure life expectancies which are shorter than the time frame of the high-risk impacts.  Furthermore, it can be argued that the “low” confidence sea-level rise estimates are “no” confidence events because they rely on SSP-8.5 which is implausible.  I do not believe that a “high-end storyline” approach is appropriate for regulatory guidance.

Summary of My Comments

My detailed comments describe the observed sea-level rise at the Battery monitoring station in New York City, the methodology used to project sea-level rise, and compare the sea-level rise projections and observations (table below).  The following table compares the projected sea-levels using the observed from 1850 to present and 1984 to present with the projections of sea-level rise. Importantly the observed sea-level rise is less than the 50th percentile, “medium confidence” Part 490 sea-level projections.  In other words, the observations indicate that the medium confidence projections are conservative estimates of sea-level rise.  I also found that comparing the acceleration of sea-level rise necessary to comport with the projected rates with the observations indicates that there is no sign that the “high-end storyline” projections are realistic.

Compare 2024 proposed sea level rise projections (inches of rise relative to 1995-2014  baseline) to sea-level rise projected using observed trends since 1850 and 2014 at the Battery Monitoring Station

The RIS argues that observed sea-level rise projections are not appropriate to use for future estimates because they do not account for projected global warming.  To address this concern the Energy and Environmental Alliance of New York proposed a “pledge and review” alternative approach in 2016.  My comments argue that this is a better approach.  Given the uncertainties of modeling both global warming and the associated sea-level rise along with the model over-estimates of warming it is prudent to assume that the sea-level trend observed over the last 150 years will continue until the observations indicate otherwise. 

There is a section in my comments that describes how the sea-level rise projections are intended to be used for flood risk management.  The RIS does not consider that flood risk management must incorporate probability of occurrence.  The Part 490 sea-level rise projections do not because of the emphasis on the “high-end storyline”.  Even though the RIS appropriately describes all the scenarios and how the data were collected and used, the RIS risk analysis is flawed because it does not weigh potential results against benefits and consequences.  The comments describe a more appropriate risk management approach. 

Summary of Recommendations

The sea-level rise projections in the proposed amendment need to be reconsidered.  The over-arching problem is that the low-likelihood, high-impact storyline that incorporates the rapid ice melt scenario is dependent upon the RCP/SSP 8.5 high emissions scenario and does not account for the near-term applicability of the sea-level projections for CRRA applications.  Even the RIS acknowledges that “current GHG emissions policies would result in actual emissions lower than projected by SSP5-8.5.”  Because the high greenhouse gas emissions are a necessary condition for the rapid ice melt low-likelihood, high impact scenario, that emissions scenario should not be used for sea-level rise recommendations.  Furthermore, the timing of the rapid ice melt scenario is extremely unlikely to occur in the time frame of infrastructure projects in the New York State Flood Risk Management Guidance for Implementation of the Community Risk and Resiliency Act  guidance that refers to Part 490 sea-level rise.  

The RIS claims that because Part 490 “will not impose any costs on any entity because the regulation consists only of sea level rise projections and does not impose any standards or compliance obligations” that no costs are associated with Part 490.  However, the pertinent cost issue is the difference between the recommended alternative and the alternatives described in the RIS. The “high-end storyline” approach has an impact on costs and the failure of the RIS to address them is a disservice to the citizens who will have to foot the bill.  The RIS should be modified to compare costs with the alternatives included.

Any projection that uses the RCP/SSP 8.5 high emissions scenario overestimates sea-level rise values.  Given the acknowledged uncertainties with sea-level projections and the over-predictions of global warming with current global climate models, the pledge and review approach should be used to determine if accelerated sea-level rise consistent with the “high-end storyline” projections are observed.  The sea-level projections consistent with SSP2-4.5 should be used because these sea level rise projections are associated with the most likely conservative estimates of potential emissions and the numbers are consistent with observed sea-level rise.  If future observations indicate that this scenario is no longer conservative then the projections can be modified accordingly.

How To Provide Written Comments

I encourage my New York readers to submit written comments by the 5:00 PM April 29, 2024 deadline. I have prepared a detailed explanation of the process at this link.  The link also includes a condensed comment that addresses the key points described above.

The link provides the recommended comment. 

  1. Enter the following address in your address line: climate.regs@dec.ny.gov
  2. Put Comments on Part 490 in the Subject line
  3. Copy the comment text in the link into the body of your email. 
  4. Submit it

If you are inexperienced with the DEC rulemaking process let me explain what happens next.  If you are lucky, you will get an acknowledgement that your comment was received.  DEC staff are required to read the public comments and the rulemaking requires a response to comment document.  At some point there will be a document that includes a response to each comment and recommendation.  It would be especially useful if you have a specific example of a concern related to the projections to include that in your comments. If you prepare your own comments, then they will have to respond to that separately, but all the comments submitted using my recommendation will be consolidated.  Reading comments and writing a response does not mean DEC will change anything in their proposed rulemaking.   

I have submitted comments for countless proceedings over the last 40 years.  Sadly, over the years DEC has become more and more politically driven to the point now that all rulemaking policy decisions are ultimately decided by the Administration regardless of the science.  To increase the chance that any of the comments and recommendations will actually be implemented, I suggest sending a copy to your legislators.  Like most of the Climate Act implementation components very few people know what is happening and the ramifications of the actions.  If the legislators start asking the Administration questions about the use of implausible scenarios that will make development near the shorelines more expensive, there may be a political response towards consideration of tradeoffs.  Absent that the only solace is the record will show that the State was warned that their policies were ill-advised when the proposed sea-level recommendations fall far below the observed rise.

The rule-making process includes a perfunctory public hearing.  The Part 490 hearing was held on April 22.  The hearing officer described the rule making process and Mark Lowery from DEC went through the following slide.  That was all over in ten minutes.  Two people signed up to give comments.  I signed up but could not talk because of a persistent cough.  The other person’s comments were totally unrelated.  She wanted to thank DEC for setting up raptor nesting boxes.  For the record all comments are considered equally so nothing was lost.  In fact, I showed up for a hearing one time and a friend from DEC who was working on the proceeding basically said the hearings were a waste of time and that they preferred the written comments.

Conclusion

Given the poor turnout for the public hearing, there does not appear to be much interest in this rulemaking.  I doubt that these comments and recommendations will have any effect on the rulemaking because there is too much institutional inertia.  The record for some rulemakings makes a big deal about the number of comments that support their position.  If the negative comments outweigh those supporting the proposal, then it will be interesting to see how the documentation spins that.  In order to find out please, submit a comment.  Thanks.

Articles of Note April 14, 2024

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered.   This is a summary of articles that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Videos

  • Weekly dose of climate insanity – electric logging trucks
  • John Robson at Climate Discussion Nexus has prepared a new video that addresses why loony climate decisions keep getting made. In his latest “Fact Check” video “When Backroom Met Zealot” he shows how green zealots spewed misinformation at an Ottawa City Council committee that then voted unanimously and without debate in favour of their proposal. He debunks the zealots, so you will know what to say when they show up in your town.
  • Hurricane threats to offshore wind turbines  There is a summary of the video and links to documentation available here.  Spoiler – The New Jersey  Board of Public Utilities in charge of permitting offshore wind projects said that the Atlantic hurricanes are a significant potential threat.  More alarming is that the BPU has stated that there’s been really little technical research um about the effects of hurricanes on the offshore wind projects.

State of the Climate

Honest Story of Climate Change Guus Berkhout & Kees de Lange explain why there is no climate crisis.

Proposed Alternate Strategy Guus Berkhout & Kees de Lange propose a gradual energy transition to nuclear

Swiss Climate Decision

According to a recent decision by the European Court of Human Rights (ECHR) Switzerland has failed to comply with its duties to stop climate change.  Chris Morrison makes the case that:

The “real plaudits for the recent idiotic climate change verdict from the European Court of Human Rights (ECHR) belong to the elite billionaire paymasters behind lawfare activists such as Greenpeace and Client Earth. Greenpeace bankrolled the Swiss ladies and Client Earth supplied some of the legal arguments. The case is likely to throw a spotlight on the role that a few moneyed forces are playing in using the judicial system to enforce their insane Net Zero collectivisation on populations around the world. 

Always insightful and rational, Judith Curry has prepared a response “to help innoculate us from this fresh new climate hell of litigation.”.  The entire article is worth a read.  Her summary states:

There will be a continuing need for fossil fuels.  Rapid restrictions to fossil fuels before cleaner energy is available interferes with more highly ranked sustainability goals – no poverty, no hunger, affordable and clean energy, and industry-innovation-infrastructure. There is no human right to a safe or stable climate. Apart from the lack of an international agreement, such a “right” contains too many contradictions to be meaningful.

Defending the Narrative

When it comes to reporting on climate-related issues please be aware that the Associated Press makes no attempt to provide any information that contradicts the climate alarmist narrative.

Facebook Censorship due to a Science Feedback: “Fact Check”  Andy May notes that Facebook’s “independent and nonpartisan fact checks” of “Climate: The Movie.” is totally out of hand.

Reality is the Narrative is Falling Apart

Illustrating The Absurdity Of New York’s Energy Transition: Francis Menton highlights some of my findings from a lengthy blog post at this site and a somewhat different version that also appeared on Watts Up With That at about the same time. Tom Shepstone also re-published the article.

The Absurdity of the Electric Vehicle Transition:  The Institute for Energy Research explains the flaws in the Biden Administration emissions tailpipe rule that will force electric vehicles on us all.  To which I can add an anecdote.  I have a friend in the car business who is familiar with the electric vehicle market.  He told me this weekend that Tesla announced a 50% increase in the cost of replacement batteries.  This makes buying a new one more viable and fosters the sales of EVs.  All the regulations require new EV sales but there are no incentives to keep them on the road. 

Joke of the Week – well maybe a tragic commentary on these times.  ‘Spirit Whales’ (which ‘no-one believes exist’) hold up Australia’s most expensive energy project.  “If the gas project was to go ahead, the Spirit Whales would be endangered. And if the Spirit Whales were killed, none of the creatures of the sea would know what do to. Short of Aqua Man stepping in to save the day, the planet would be sunk. How did the Federal Court know all of this? Raelene Cooper! Ms Cooper, or as her activist friends like to call her, the Custodian of Whale Dreaming, speaks to the Spirit Whales. And they speak to her. Seriously. This was in evidence presented to the Federal Court.”

Natural Climate Variability

A recent Associated Press story noted that “For the 10th consecutive month, Earth in March set a new monthly record for global heat — with both air temperatures and the world’s oceans hitting an all-time high for the month, the European Union climate agency Copernicus said.”  It went on to state that “Climate scientists attribute most of the record heat to human-caused climate change from carbon dioxide and methane emissions produced by the burning of coal, oil and natural gas.”  This post provides evidence that human-caused climate change was not the primary cause for the records.

The rationale used for New York’s Climate Leadership & Community Protection Act (Climate Act) that reducing GHG emissions will affect climate is of special interest to me.  However, I question whether we know enough about natural climate variability to legitimately make that claim.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Observed Climate Variability

The video Climate the Movie: The Cold Truth includes a very good description of historical temperatures and CO2 trends.  It provides examples why claims that today’s observations indicate unprecedented heat in earth’s history are wrong.  In geologic time scales temperatures today are not at all unusual and because we are in an ice age all previous non-ice age geologic epochs were warmer.  Over the last 2,000 years there also have been periods of warmer temperatures.  The video goes on to compare CO2 trends over those periods to show that there is no link. 

In a recent post I addressed the basic tenet of anthropogenic global warming catastrophists, like the authors of the Climate Act, that the correlation between CO2 and global warming evident since 1976 proves that CO2 is the control knob for climate.   Andy May prepared an Annotated Bibliography for Climate the Movie that includes a section titled “From 1945 to 1976 the world cooled”.  It includes the following plot of global temperatures and carbon dioxide.  Climate Act proponents believe that increasing temperatures since the end of the Little Ice Age are caused by increases in CO2.  This graph does not support that claim.  From 1850 to 1910 temperatures trend slightly down and CO2 trends slightly up.  From 1910 to 1944 there is little change in the CO2 trend but the temperature trends up markedly.  CO2 emissions don’t start to rise significantly until the end of World War II in 1945 but from 1944 to 1976 the global temperature trends down.  For the remaining two periods shown in the graph temperature and CO2 correlate well.

The caption highlights the key point.  There is good correlation between CO2 concentrations in the atmosphere after 1980 but the correlation is poor before that.  I believe this shows that natural climate variation caused the 1910 to 1944 warming.  I do not believe that anyone has proven that the same natural climate drivers are not affecting the recent warming. 

The National Oceanic and Atmospheric Administration (NOAA) recently posted a comment that contradicts the existential threat narrative and supports those who argue natural climate variability is the main driver of climate change.  It states that “The amount of CO2 in the atmosphere today is comparable to around 4.3 million years ago, when sea level was about 75 ft higher than today, the average temp was 7 degrees F higher than in pre-industrial times, & large forests occupied areas of the Arctic that are now tundra.”  Climate the Movie shows that going back further in time that CO2 levels were much higher than today. It is not clear to me why there is supposed to be an existential threat to society when temperature and CO2 concentrations were higher in the past and the ecosystems survived.

Recent Warming

The claims for recent global temperature records reference NASA satellite data.  This data set only goes back to 1979 but it provides the greatest representative coverage of the globe because it does not depend on randomly spaced surface measuring stations.  In the following graph note the large spike in recent months.

Note that the spikiness in these measurements is not reflected in the atmospheric concentrations of CO2 measurements.  According to NOAA’s CO2 measurements:

The global surface concentration of CO2, averaged across all 12 months of 2023, was 419.3 parts per million (ppm), an increase of 2.8 ppm during the year. This was the 12th consecutive year CO2 increased by more than 2 ppm, extending the highest sustained rate of CO2 increases during the 65-year monitoring record. Three consecutive years of CO2  growth of 2 ppm or more had not been seen in NOAA’s monitoring records prior to 2014. Atmospheric CO2 is now more than 50% higher than pre-industrial levels.

If CO2 really is the control knob, then why is there so much inter-annual variation in temperature at the same time there is so little variation in the CO2 trend?  The only possible explanation activists have is that there are some natural variation processes.  Picking and choosing CO2 as the cause of the increasing trend while simultaneously acknowledging that there also are natural processes affecting the observed temperatures does not seem to be a particularly strong position to me.

Most Recent Warming

The Associated Press article claimed that “Climate scientists attribute most of the record heat to human-caused climate change from carbon dioxide and methane emissions produced by the burning of coal, oil and natural gas.”  The reality is that not all climate scientists support the claim that most of the record-breaking heat was caused by anthropogenic greenhouse gases.    

Javier Vinós described the recent warming explaining that this spike in temperatures marked the warmest period recorded by instruments and that the recent change was exceptional.  He found that “the temperature increase from the previous record was the largest in 153 years, at +0.17°C. This level of increase from previous records is remarkable, even for a year that has been recorded as the warmest on record.”  If there had been a spike in GHG emissions that preceded this warming spike, then I would be more supportive of the CO2 is the control knob theory.  It turns out that there was no spike in human emissions but there was a natural spike.  The Tonga-Hunga underwater volcanic eruption blasted unprecedented amounts of water vapor into high levels of the atmosphere.  Water vapor is more effective than CO2 as a greenhouse gas so this could be part of the reason for the recent warming spike.

There is another natural phenomenon likely responsible for some of the warming.  Surface water temperatures in the Pacific Ocean oscillate between warm (El Niño) and cold phases (La Niña ) of the El Niño-Southern Oscillation or “ENSO”.  The winter of 2023 occurred during an El Niño when the ocean releases heat into the atmosphere and has been associated with marked increases in global temperatures.  However, the 2023 El Niño was a weak year so its contribution to the observed warming was minimal.

In an article entitled “State of the climate – summer 2023“, Judith Curry examined the top of the atmosphere radiation balance.  As of June 2023, her analysis suggests that the water vapor increase in long-wave radiation warming from the Tonga-Hunga underwater volcanic eruption was offset by the short-wave aerosol particle cooling.  She gave other reasons for the observed warming records:

The exceptionally warm global temperature in 2023 is part of a trend of warming since 2015 that is associated primarily with greater absorption of solar radiation in the earth-atmosphere system.  This increase in absorbed solar radiation is driven by a slow decline in springtime snow extent, but primary by a reduction in reflection from the atmosphere driven by reduced cloudiness and to a lesser extent a reduction in atmospheric aerosol.  Any increase in the greenhouse effect from increasing CO2 (which impacts the longwave radiation budget) is lost in the noise.

She lists three reasons for the warming.  The slow decline in springtime snow extent has been linked to the warming trend as we come out of the Little Ice Age.  Clouds affect global temperatures.  Within the atmosphere more low clouds reduce temperatures by reflecting more sunlight but increased high clouds increase temperatures.  Particles or aerosols also scatter light and can affect temperatures by blocking sunlight.  She attributes the observed warming to the reduction in reflection from the atmosphere driven by reduced low-level cloudiness and to a lesser extent a reduction in atmospheric aerosol particles.  Low-level cloudiness trends are not well understood and are not included in climate models.  The aerosol changes are attributed to changes in the sulfur content of ship fuel. Most importantly, she points out that increasing CO2 effects are “lost in the noise” which directly contradicts the Associated Press article.

Conclusion

The rationale for the multi-billion Climate Act net-zero transition is the alleged link between climate change and greenhouse gas emissions.  Undoubtedly the emissions increases have some greenhouse effect on global temperatures, but the effects of natural climate variability not only must have been responsible for all of the historical variations in global temperatures but also appear to be the primary driver even during the most recent period when carbon dioxide emissions and global temperatures are well-correlated. The rationale for the Climate Act transition is weak at best.