Great Lakes Vineyard Confronts Climate Change

There are two aspects of the recent presentation Great Lakes Vineyard Confronts Climate Change that need to be considered: scare mongering by anecdote and Bandolini’s BS principle. It is a sad commentary on the media today that this presentation had so little substance other than anecdotal “evidence” that climate change is adversely affecting vineyards in the Great Lakes. Showing that the presumptions in the presentation are weak is a perfect example of Alberto Brandolini’s BS principle: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”

Anecdotal Evidence

Angelica A. Morrison’s newscast claims that “Problems from disease, like powdery mildew, and pests arise when temperatures extremes become the new way of life.” Interviewing a farmer who shows her some diseased plants purportedly shows the effects of the climate change in western New York. The evidence for extreme weather change is the farmer’s recollection: “We’ve had a very mild winter [in 2016] so almost everything survived,” he said. “But prior to that, the winter of 2014 to 2015, were extremely cold temperatures that I’ve never seen before. “And it killed a lot of vineyards that in the past we’ve had success with. We’ve done a lot of replanting and we try to choose varieties that can survive the winter.”

The presentation explains that the vineyard in question is in the Lake Erie Concord Grape Belt, which starts in western New York and extends to Pennsylvania and goes on to note that the area depends on Lake Erie to moderate temperatures. “The lake is supposed to be our great protector,” says Tim Weigle of the Cornell Cooperative Extension’s Lake Erie Regional Grape Program. The presentation notes that “Weigle, who advises grape farmers and works with them on managing their crops, says the lake doesn’t freeze over like it used to. When temperatures are prematurely warm, crops come out of dormancy, making them vulnerable to frost. ‘If the lake freezes then we don’t have those problems, but since it hasn’t been freezing all the time, we have run into more problems with frost and freezes,’ he says.”

Hypothesis

There are two claims in this presentation. The first is that in the winters of 2014 and 2015 there were extremely cold temperatures that the farmer has “never seen before”. The second is that when Lake Erie freezes over temperatures don’t warm up prematurely so crops are not damaged coming out of dormancy before the last killing frost of the season.

Analysis

In order to prove or refute the claims in this presentation complications immediately arise. There is no question that there is a warming trend in this region but what causes winter damage in the first claim? If damage occurs because of the lowest temperature of the year that can be checked easily but if it is the duration or number of days below some threshold temperature, the analysis gets more complicated quickly. For the second claim, if the problem is a period of temperatures so warm and so long that dormancy is broken followed by a killing frost the trends analysis for that is even more complicated.

The second claim confuses me. In particular, this statement “If the lake freezes then we don’t have those problems, but since it hasn’t been freezing all the time, we have run into more problems with frost and freezes”. Lake Erie moderates air temperatures because the seasonal lake temperature lags behind the seasonal air temperature. As a result, in the fall frosts don’t occur as early because the warmer lake tempers the freezing air. In the spring there is moderation for warming and cooling. The lake is generally cooler and slows the plants coming out of dormancy but also protects them if a cold snap comes along because its temperature is above freezing. My problem with the presentation statement is that those effects are eliminated when Lake Erie freezes over. When Lake Erie freezes over downwind air temperatures are not moderated by a source of above freezing water and as a result temperatures are not moderated and, most visibly, the Lake Erie lake-effect snow machine is cut off. Therefore, the moderating effect on frosts and freezes should be enhanced if the lake does not freeze over.

Numbers

The New York Climate Change Science Clearinghouse is described by its supporters as “a regional gateway to data and information relevant to climate change adaptation and mitigation across New York State. It provides climate science data and literature and other resources for policy-makers, practitioners, and the public, to support scientifically sound and cost-effective decision making”. I tend to be a little more cynical about its contents because it is biased towards alarmism. However, it does provide anyone with easy access to relevant climate data.

The Climate Data Grapher – Station Temperature includes annual average minimum temperature for Fredonia, NY in addition to the other following parameters:

  • Daily maximum temperature (F)
  • Daily minimum temperature (F)
  • Daily average temperature (F)
  • Growing degree day accumulation, base 50 F
  • Heating degree day accumulation, base 65 F
  • Cooling degree day accumulation, base 65 F
  • Counts of days with max temperature above 90 F
  • Counts of days with max temperature above 95 F
  • Counts of days with max temperature above 100 F
  • Counts of days with min temperature below 0 F
  • Counts of days with min temperature below 32 F
  • Growing season length (days)

All of these parameters show what we would expect in a warming climate: daily minimum, maximum, and average temperatures are increasing, cooling degree days, growing degree days and growing season length are increasing, heating degree days are decreasing, the counts of warm days are increasing and cool days are decreasing.

With respect to claim number one that during the winters of 2014 and 2015 there were extremely cold temperatures that the farmer has “never seen before”, we can check the claim by looking at the count of number of days below 0 F. Unfortunately the Fredonia monitoring site stopped operating in 2011 so I used the nearby Buffalo airport site. In 2014 there were six days of below zero temperatures and in 2015 there were 12. In 1979 there were 11 days and looking back there is nothing that unusual about six days that suggests “never seen before” is verified. In fact between 1976 and 1985 there was only one year that was below six days.

Unfortunately, none of the parameters on the Climate Data Grapher can be used to necessarily support or refute the second claim about ice cover and dormancy. A graph of annual maximum ice cover for Lake Erie (available from the NOAA Great Lakes Environmental Research Lab) does support the claim that the lake does not freeze over as much as in the past but as is the case with readily available temperatures it may be the duration and timing of ice cover that affect crop dormancy.

As I explained above I don’t think ice cover affects dormancy but to determine if there is a trend in dormancy that analysis is a bigger deal than I can handle. First you would have to determine the conditions that break dormancy: temperature and duration of temperature above some threshold. If the potential effect is exacerbated by frozen ground that has to be included.  Daily maximum and minimum temperature data are readily available but you would need to develop a program to analyze that data to determine the annual end of dormancy and the date of the last killing frost. If you can show that the end of dormancy is coming earlier in the year and the date of last killing frost is not also coming earlier that would support the claim. If the date of the last killing frost is also coming earlier then that would not support the claims. More importantly, would be to see how often a late frost caused problems with plants historically.

Conclusion

This presentation illustrates problems with the media relative to climate change reporting. This furthers the narrative that climate change effects are happening now for the public who has neither the time nor expertise to evaluate the claims. I heard it on NPR – it must be true.   It is a sad commentary on the media that this presentation had so little substance other than anecdotal “evidence” that climate change is adversely affecting vineyards in the Great Lakes. On the other hand if anyone wants illustrations of two of my pragmatic environmentalist principles it offers vivid examples. Clearly this is a sound bite environmental news report and refuting its baloney took at least an order of magnitude more work. If you wanted to support or refute the dormancy claim it would be another order of magnitude of effort.

My Comments on New York Proposal to Incorporate Carbon Pricing in Wholesale Markets 2

New York’s energy planning process continues its efforts to meet the aggressive goals of a remodeled energy system that relies on renewable energy. The latest boondoggle in that effort is a plan to price carbon in the wholesale electric market. I have not been able to let that go by without throwing in my two cents so this post describes my second submittal in the formal proceeding. I have been submitting my comments because I am convinced that all these efforts will cost extraordinary amounts of money but will have no discernable impact on global warming or any of the purported effects.

As part of the release of Pricing Carbon into NYISO’s Wholesale Energy Market to Support New York’s Decarbonization Goals (hereinafter the “Brattle Report”) there was an introduction authored by Brad Jones, President & CEO of the New York Independent System Operator (NYISO) and John Rhodes, Chief Executive Officer of the New York State Department of Public Service (DPS). The introduction described the rationale for the report:

In this regard, the NYISO began a project through its stakeholder process in the fall of 2016 to examine the potential for using carbon pricing within wholesale markets to further New York’s energy goals. Initially, The Brattle Group was retained by the NYISO to evaluate conceptual market design options for integrating the social cost of carbon, a widely recognized regulatory standard, into competitive wholesale energy markets administered by the NYISO. That analysis explored how carbon pricing can align wholesale markets with state energy policies and looked at several factors, including the effect on customer costs and emissions reductions.

The Executive Summary of the Brattle Report notes that “Harmonizing state goals and the operation of wholesale electricity markets could leverage market forces to more efficiently meet both state goals and traditional electric system goals of providing affordable, reliable supply.” This statement makes for a nice slogan, but the reality is different. In this post I show that there are barely enough electric sector emissions available to meet the 2030 goal and nowhere near enough for the 2050 goal. Because the proposed carbon price is on only one sector of the economy, the theory that increasing the price of carbon will drive the market to less carbon intensive alternatives fails. Instead, driving up the price of electricity makes the conversion to electric based residential heating and transportation more difficult. I consider these fatal flaws to the proposed initiative.

The Reforming the Energy Vision (REV) state energy goals in 2030 are a 40% reduction in Greenhouse Gas (GHG) emissions from 1990 levels and a 50% renewable generation. In 2050 the goal is an 80% Reduction in GHG emissions from 1990 levels. The NYSERDA Patterns and Trends document notes that the 1990 Carbon Dioxide equivalent (CO2e, standing in for GHG) emissions were 235.8 million metric tons so the 2030 goal is 141.5 million metric tons or a 94.3 million ton reduction. In 2050 the goal is 47.2 million metric tons which is a 188.7 million metric ton reduction.

Figure 1 shows the trends in New York State CO2e emissions, energy (TBtu) and CO2e intensity which is the emissions divided by the energy. Note that the energy used in New York rose until 2005 and has since started to drop while the pattern of CO2e has ebbed and flowed more but has also dropped since 2005. The question is whether pricing carbon in the electric sector can affect these trends to meet the state goals. In order to do that we have to look at what drove the trends.Figure 1 NYS CO2e, Energy and CO2e Intensity

In order to reduce GHG emissions there are three direct approaches:

  1. Replace energy sources that generate GHGs with ones that don’t
  2. Energy efficiency – use energy more effectively
  3. Energy conservation – use less energy

In addition there are a couple of indirect ways: reduce the population and reduce the gross state product or economic growth. I mention those two methods to point out that neither approach is politically palatable as an approach to reduce GHG emissions and that historically the gross state product has increased and population has stayed relatively constant.

The NYSERDA Patterns and Trends document contains the energy and emissions data by sector needed to evaluate the causes of the observed reductions. Figures 2 and 3 show the trend of primary energy consumption by the residential, commercial, industrial, transportation and electric energy production sectors by total energy use (TBtu) and % of total. Residential has bounced around but is effectively the same since 1080 and the commercial sector trended up but has trended down to roughly the same levels as 1990. Given the growth in the economy it appears it appears to me that investments in conservation and efficiency have produced some results. The most notable decrease has been the industrial sector, down over 200 TBtu since 1980. While efficiency and conservation have helped with that it is more likely a result of the decline of the industrial sector in New York. Transportation energy use has grown consistently since the mid-80’s. The electricity sector grew until approximately 2005 and has since dropped. It does not appear on the basis of historic trends that energy conservation and energy efficiency will be major factors for compliance with the emissions goals.

Fig. 2 Trend NYS Primarary Consumption of Energy (TBtu) by SectorFig 3 Trend NYS Primarary Consumption of Energy (%) by Sector

That leaves carbon emission reductions to make the majority of the reductions necessary. Figures 4 and 5 show the trend of GHG emissions by the residential, commercial, industrial, transportation and electric energy production sectors and % of total. Note that these are emissions from fuel combustion only so the totals are not the same as shown before. The emissions trends for residential, commercial, industrial and transportation sectors are similar to the energy trends. Residential and commercial are roughly the same, industrial is down, and transportation is up. Electricity sector emissions are down more than the total energy. This is the only sector the proposed price on carbon will affect.

Fig 4 NYS CO2e Emissions (million metric ton) by Sector TrendFig 5 NYS CO2e Emissions by % Sector Trend

Because the electric generation sector is the only sector that will be affected by the proposed carbon price we need to evaluate the sources of electricity generated in New York. Figure 6 shows the percentage of electricity provided by different sources: coal, natural gas, petroleum (residual oil and distillate), hydro, nuclear, imports, other (landfill gas & biomass), wind and solar. Coal and petroleum have gone down significantly since 1990. Natural gas has increased significantly as has imports. After Nine Mile Point unit 2 came on-line nuclear has stayed about the same as has hydro. In the past few years enough solar and wind have come on line to appear on the chart. Figure 7 shows the total energy provided by the same categories. Clearly the biggest changes have been the reduction of coal and petroleum fuel use and increase of natural gas and imports.

Fig 6 NYS Electric Generation by % Fuel TypeFig 7 NYS Electric Generation by Fuel Type (GWh)

In order to determine how much the carbon pricing program can directly affect CO2e emissions we need to look at the electric sector emissions relative to emissions from the rest of New York State. Figure 8 shows the trends and Table 1 NYS Trend of CO2 by electric sector and rest of state shows the data. Statewide coal and electric sector oil have gone down 55 million metric tons but since 1990 natural gas has gone up. It can be argued that for the most part the major decreases in coal and oil were the result of changes in the relative cost of fuel and had nothing to do with New York State policy. Moreover, the State has drafted regulations to eliminate the use of coal so carbon pricing will have no effect on those emission and there are only 3.9 million metric tons of reduction available anyway. With respect to electric sector emissions, no further oil use reductions are expected because the current levels represent the minimum emissions necessary to maintain oil as a backup and emergency use fuel. That leaves natural gas emissions.

Fig 8 NYS Trend of CO2 by electric sector and rest of state

Overall, the total emissions in 2015 are only down 18% to 169.5 million metric tons and the 2030 target is 141.5 million metric tons so further reductions of 28 million metric tons are necessary. Putting a price on electric sector carbon could, in theory, reduce the total sector emissions of 29.2 million metric tons. However, the primary way to reduce emissions from the other sectors is to replace fuel combustion with electricity. The unintended consequence of the carbon price then will be to increase the price of electricity making those conversions less attractive.

On one hand carbon pricing is touted as a market-based solution to carbon reductions. However, that only works when the tax is applied to the entire economy. The proposed New York carbon pricing approach is only for the electric generation sector, so market intervention will be required to subsidize the electrification conversions necessary to meet the targets if only because the proposal increases the cost of electricity making conversions less attractive. As soon as that happens the elegant market-based solution devolves into special interest lobbying at the expense of the general public.

Already labor unions, community groups, environmental organizations, faith communities, and environmental justice advocates are supporting just such a carbon tax scheme. While the New York State Climate and Community Protection Act (CCPA) (S.8005 / A.10342) covers all sectors it specifically proposes to not only return the revenues to ratepayers but also includes subsidies to renewable energy sources in general and targeted subsidies as well and worker and community support.

While the intent of carbon pricing to harmonize state goals and the operation of wholesale electricity markets to leverage market forces to more efficiently meet both state goals and traditional electric system goals of providing affordable, reliable supply makes for a nice slogan the reality is different. There are barely enough electric sector emissions available to meet the 2030 goal and nowhere near enough for the 2050 goal. Because the proposed carbon price is on only one sector of the economy, the theory that increasing the price of carbon will drive the market to less carbon intensive alternatives fails. Instead, it drives up the price of electricity which makes the conversion to electric-based residential heating and transportation more difficult.

My Comments on the New York Proposal to Incorporate Carbon Pricing in Wholesale Markets 1

New York’s energy planning process continues its efforts to meet the aggressive goals of a remodeled energy system that relies on renewable energy. The latest boondoggle in that effort is a plan to price carbon in the wholesale electric market. I have not been able to let that go by without throwing in my two cents so this post describes my first submittal in the formal proceeding. I have been submitting my comments because I am convinced that all these efforts will cost extraordinary amounts of money but will have no discernable impact on global warming or any of the purported effects. My comments are submitted as a private retired citizen. They 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.

I am motivated to submit these comments to make the point that the majority of New York State ratepayers are unaware of the ramifications of this proceeding and have never heard of the Social Cost of Carbon (SCC). I doubt that if they understood the SCC as the basis for this initiative that they would favor its implementation as proposed. Therefore, I recommend that the carbon pricing initiative consider a range of SCC values including the proposed value and the values included in the Regulatory Impact Analysis for the Review of the Clean Power Plan: Proposal.

The SCC is the present day value of projected future net damages from emitting a ton of CO2 today. In order to estimate the impact of today’s emissions it is necessary to estimate total CO2 emissions, model the purported impacts of those emissions and then assess the global economic damage from those impacts. The projected global economic damage is then discounted to present value. Finally, the future damage is allocated to present day emissions on a per ton basis to get the SCC value.

Because of the huge uncertainties of the SCC providing a range of values is appropriate. The SCC future net damages includes impacts out 300 years. It is an act of extreme hubris to claim that any projection of how the world will operate in 100 years, much less 300 years, should be used to guide current actions simply because no one could have imagined the technology available in today’s society in 1917. In addition, the SCC relies on a complex causal chain from carbon dioxide emissions to social impacts that are alleged to result from those emissions. Richard Tol testified that these connections are “long, complex and contingent on human decisions that are at least partly unrelated to climate policy. The social cost of carbon is, at least in part, also the social cost of underinvestment in infectious disease, the social cost of institutional failure in coastal countries, and so on.”

The current value of the SCC proposed for use in this initiative was developed by the US Interagency Working Group (IWG). There are three technical reasons that the single value the IWG developed and proposed for use in this initiative should not be used exclusively: global benefits, discount rates and equilibrium climate sensitivity.

The IWG SCC value considers global benefits and impacts not just New York State benefits impacts. In other words New Yorkers are being asked to pay today for some estimated far future impact elsewhere. Given that the State has limited resources to provide benefits to New Yorkers today is reason enough to consider a range of the SCC for a program that could increase costs to ratepayers. The EPA RIA for the revised Clean Power Plan includes a domestic rather than international social cost of carbon value. Putting aside for the moment the question whether a New York only policy should only consider benefits to New Yorkers, it nonetheless seems obvious that the policy should at least limit benefits to the United States in any calculation on the value of the program to New Yorkers.

The IWG SCC value did not follow Office of Management Budget Circular A-4 guidance that states that regulatory analyses “should provide estimates of net benefits using both 3 percent and 7 percent.” The 7 percent rate is intended to represent the average before-tax rate of return to private capital in the U.S. economy. The 3 percent rate is intended to reflect the rate at which society discounts future consumption, which is particularly relevant if a regulation is expected to affect private consumption directly. The EPA RIA for the revised Clean Power Plan follows this guidance by presenting estimates based on both 3 and 7 percent discount rates in the main analysis.

Equilibrium climate sensitivity (ECS) is the expected change in temperature when the atmospheric CO2 concentration doubles. The costs of this warming are dominated by the higher possible values of the ECS. The ultimate problem is that the IWG did not use the most recent values of the ECS for the value that the price of carbon initiative proposes to use. On July 23, 2015, Patrick Michaels presented relevant testimony to the House Committee on Natural Resources.  Excerpts:

“In May 2013, the Interagency Working Group produced an updated SCC value by incorporating revisions to the underlying three Integrated Assessment Models (IAMs) used by the IWG in its initial 2010 SCC determination. But, at that time, the IWG did not update the equilibrium climate sensitivity (ECS) employed in the IAMs. This was not done, despite there having been, since January 1, 2011, at least 14 new studies and 20 experiments (involving more than 45 researchers) examining the ECS, each lowering the best estimate and tightening the error distribution about that estimate. Instead, the IWG wrote in its 2013 report: “It does not revisit other interagency modeling decisions (e.g., with regard to the discount rate, reference case socioeconomic and emission scenarios, or equilibrium climate sensitivity).”

“Clearly, the IWG’s assessment of the low end of the probability density function that best describes the current level of scientific understanding of the climate sensitivity is incorrect and indefensible. But even more influential in the SCC determination is the upper bound (i.e., 95th percentile) of the ECS probability distribution. Apart from not even being consistent with the AR4, now, more than five years hence, the scientific literature tells a completely different story. And this is very significant and important difference because the high end of the ECS distribution has a large impact on the SCC determination—a fact frequently commented on by the IWG2010.”

Dr. Judith Curry has prepared a table of different values of the ECS that illustrates the relative impacts of the indefensible cherry picking of a value that suited the agenda of the IWG rather than a more recent value.

Curry Equilibrium Climate Sensitivity

Because the extreme values are a key driver of the ECS, the 95th percentile values are of most interest. Refer back to the Michaels testimony above to see that the IWG had lower values available to it for years but chose not to use them. There is another nuance to this table that is important to me personally as a meteorologist with over 40 years of experience with modeling and monitoring. The last two rows in this table are estimates based on monitoring and not modeling so, in my opinion, are more likely to be correct.

The SCC is the fundamental rationale of the NY carbon pricing program. When the time comes to decide whether to implement the carbon pricing initiative it is important for decision makers to be aware of the changes in the value of the program possible by tweaking two parameters in the calculation of the SCC. The uncertainties with the methodology and the three technical reasons support my recommendation to include the SCC values from the EPA RIA for the revised Clean Power Plan so a range of potential benefits is provided.

Pragmatic Environmentalist of New York Principle 9: Ridley’s Paradox

For pragmatic environmentalists Riley’s Paradox describes a fundamental concern relative to climate change policy: Economic damage from man-made ‘climate change’ is illusory whereas damage from man-made ‘policies’ to fight the said change is real.

I ran across this principle at Climate Scepticism where Paul Matthews posted a summary of former Australian Prime Minister Tony Abbott speech at the Global Warming Policy Foundation.  Prime Minister Abbott’s speech “Daring to Doubt” described climate science with a skeptical viewpoint then went on to talk about climate policy with an emphasis on Australia. He said:

In what might be described as Ridley’s paradox, after the distinguished British commentator: at least so far, it’s climate change policy that’s doing harm; climate change itself is probably doing good; or at least, more good than harm.

Matt Ridley is a British scientist, columnist, and author of several award winning books, including the Rational Optimist. I have admired his writings for a long time. He recently posted on this issue noting that climate policies are doing more harm than good and that is a moral issue. Please read his post because he explains the problem better than I can. He lists ten climate policies that are doing more harm than good.

  1. Ethanol subsidies
  2. Biodiesel programs
  3. Promotion of diesel cars
  4. Burning pellets derived from wood products
  5. Wind power
  6. Solar farms
  7. Only renewables policies
  8. Fuel poverty
  9. High energy costs
  10. The neglect of more serious environmental problems

Richard Tol also has written about this paradox. He notes that “Politically correct climate change orthodoxy has completely destroyed our ability to think rationally about the environment.”

Finally, I want to acknowledge Shub Niggurath for the definition I used of Riley’s Paradox.

 

My Comments on the RGGI September 2017 Stakeholder Meeting

When environmental rules and regulations are promulgated there are rules which include comment periods where interested parties can submit their suggestions about the proposals. This post describes the process, the comments submitted to the recent Regional Greenhouse Gas Initiative (RGGI) stakeholder meeting and includes the comments I submitted.

I have extracted my disclaimer from my comments for use here. I have been involved in the RGGI program process since its inception. In the final years before my retirement I analyzed air quality regulations that could affect electric generating company operations and RGGI was one of the regulations reviewed. The opinions expressed in these comments 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. I believe the majority of the stakeholder opinions expressed at meetings and in submitted comments are, in my opinion, very naïve relative to the actual burden implementing their preferred alternatives, overly optimistic about the potential value of continued RGGI reductions and ignore the potential for serious consequences if things don’t work out as planned.

Comment Process

Ideally the comment period enables stakeholders to suggest modifications to the rules or schedules that make the final rule better. Of course the definition of better depends on where you are coming from. Pragmatic environmentalists in industry generally comment on topics that they think will affect their ability to comply with the proposed rules or address issues related to compliance obligations, primarily related to reporting. Our comments depend on evidence so we are careful to provide evidence for our assertions.

I have never worked on the other side of the dynamic between regulators and the regulated community so I am not sure how responses to comments are handled. Generally agencies are required to address all comments submitted and if the responses are debatable the regulated community can litigate the rule to address that problem. It is not clear how regulators handle quality vs. quantity of comments. If there is one comment that makes a strong argument on a particular point and many comments that argue the opposite side of that point with weak technical or purely emotional arguments who wins? There is no doubt in mind however, that even in the most professional regulatory agency with the most educated and experienced staff, that ultimately most decisions are made by political appointees who can ignore the strongest technical arguments depending on the political agendas involved.

In this case the Stakeholder meeting presented the plan for the future of RGGI that includes tightening the emissions restrictions, extending the program beyond 2020, and tweaking some of the program elements. As of the date of this writing, October 19, 2017 there were 12 comments listed for the September 25, 2017 meeting in addition to mine. Eight comments from organizations and a combined into one comment total of 2,051 individual comments from members of the Sierra Club commended the states for their proposal to reduce the emissions cap after 2020. The NY Independent System Operator commented that the analysis used to justify the rule had not handled the New York electric system correctly and that should be corrected. The Environmental Energy Alliance of New York (EEANY) pointed out that substantive issues they had raised throughout the program review process had not been addressed so it was prudent to slow down the implementation schedule. The NJ Department of Environmental Protection submitted comments that seemed to be the issues RGGI needs to address before they would consider re-joining the program. Here is a summary of the comments:

  • Ceres
    • Commends the states for their proposal to extend and strengthen the program through 2030.
  • The City of New York
    • Supports the cap emission reduction and formation of ECR but notes that RGGI States must go further if they are to align with the goals of the Paris Climate Agreement.
  • Collaborative for RGGI Progress
    • Voices strong support for the states’ consensus draft program recommendations released August 23, 2017.
  • Dynegy
    • Voices strong support for the states’ consensus draft program recommendations released August 23, 2017.
  • EEANY
    • Reiterates prior comments that were not addressed
    • Recommends delaying implementation of the cap reductions until we see what happens when the effects of earlier revisions become effective
  • Joint Comments (4 Industry Organizations)
    • Overall, supports the proposed changes and the extension of the program through 2030. We believe that the base cap has been set at a reasonable level
    • Specific recommendations for tweaks for improvement
  • Joint Comments (35 Environmental Organizations)
    • Thanks for open, transparent and responsive process
    • Strongly supports reducing the emissions cap
    • Recommendations for further reductions and tweaks to program
  • Joint Comments (16 Environmental Justice Organizations)
    • Supports proposal
    • Recommends stronger caps and more restrictions
  • NJ Department of Environmental Protection
    • Requested specific information relative to NJ participation in RGGI
    • Offered some criticisms of the supporting documentation
  • NYISO
    • Requested corrections to NY electric system modeling for IPM analyses
  • Physicians for Social Responsibility (PSR)
    • As health professionals who recognize the adverse health impacts of climate change and the need to mitigate those impacts now, we support the governors’ decision to strengthen the Regional Greenhouse Gas Initiative (RGGI) by committing to further cut carbon pollution.
  • Sierra Club Members (2,051 Individuals)
    • These comments were form letters signed by Sierra Club members that thanked the States for protecting the climate, reducing pollution, creating jobs, and growing the economy by reducing the cap.

My recommendation is the same as EEANY. Because past reductions are not going to be as easy as in the past it would be prudent to delay further emission reduction requirements.

In my opinion, all RGGI policy decisions have been and were in this case made for political reasons. As such no amount of technical arguments are ever going to win the day. You might ask then why bother submitting comments. Frankly, the only reason I go through the motions because if the problems I have documented actually happen I want to be in a position to say don’t blame the affected sources because RGGI was told that this could happen and the comments were ignored.

My Comments

I am submitting these comments on the September 25, 2017 RGGI Program Review Meeting and the proposed revision to the emissions cap in light of the RGGI Investment Proceeds report that was issued after the meeting. Based on the CO2 reduction numbers claimed in the Proceeds report the revised emissions cap appears to be risky and threatens the credibility of the program. It would be prudent for RGGI to delay implementation of any cap reductions post-2020 to determine the feasibility of meeting additional reductions based on the actual rate of CO2 reductions produced by RGGI and other programs.

CO2 Reductions from RGGI Investments

Before I use results in the Investment of RGGI Proceeds in 2015 report I want to comment on a relevant issue with it. The Executive Summary notes that “the RGGI states have reduced power sector CO2 pollution over 45 percent since 2005”. There is no better example of the pervasive mis-direction in the reporting on the impact of RGGI in this document and the RGGI reports overall than this statement. The casual reader would certainly conclude that the RGGI program itself was responsible if not for the entire reduction at least a sizeable portion of the reduction. However, looking at CO2 reductions in the RGGI states that is not the case. In the first place, the program started in 2009 not 2005. As shown in Table 1, the reduction from the last year before RGGI (2009) was instituted was 31%, much less than the 45% claimed. (Note that my numbers don’t match the RGGI report which I believe is because I relied on the EPA Clean Air Markets Division database with the assumption that summing all the annual CO2 from the all programs that report CO2 was a good enough approximation. If RGGI only summed data from RGGI-affected units it could certainly account for the difference between numbers.)

However, it is even worse. CO2 emissions in 2015 were 41 million tons less than the 2006-2008 baseline so the investments that were projected to avoid the release of 20.5 million tons of CO2 could account for no more than 50% of the observed reduction. The 20.5 million decrease is only a 16.1% reduction from the 2006-2008 baseline. This is consistent with the white paper submitted to RGGI by the Environmental Energy Alliance of New York which showed that RGGI is only responsible for between 24% and 5% of the observed reduction.

Importantly, there is an implication to the RGGI investments “success” with carbon reductions relative to the proposed 30% reduction in the emissions cap. The proposed program revisions released last month for RGGI call for an annual post-2021 cap reduction of 2,275,000 tons per year. In the Proceeds Investment Report, Table 1 Benefits of 2015 RGGI Investments, it lists the annual benefits of 2015 investments and shows an annual CO2 reduction of 298,410 tons. As also shown in the white paper submitted to RGGI by the Environmental Energy Alliance of New York the affected electrical generation units have made most if not all of the cost effective reductions possible from their operations. As a result, future reductions will have to come from sources outside the affected units and RGGI has no track record providing any assurance that its investments will be sufficient to meet the targets proposed. The fact is that RGGI has not provided a roadmap for the 30% reductions that they have proposed so it is not clear how this will work.

I have personal serious doubts where the additional reductions will come from. There is a lot of hopeful reasoning if the presumption is that other state programs will provide the necessary energy changes needed to reduce CO2 emissions from the affected entities. Even though it has been said before, I will say it again: if a compliance entity has no allowances available to cover emissions their only compliance alternative is to stop running. If that happens then RGGI will have a whole lot of explaining to do in order to salvage any credibility as a template for a successful control program.

Potential Impact

RGGI has never quantified the potential impacts of their program on global warming. In order to address that shortcoming I have adapted data for RGGI emissions in Table 2 RGGI 30% Reduction Impact on Global Warming  from the analysis in Analysis of US and State-By-State Carbon Dioxide Emissions and Potential “Savings” In Future Global Temperature and Global Sea Level Rise. The original analysis of U.S. and state by state carbon dioxide 2010 emissions relative to global emissions quantifies the relative numbers and the potential “savings” in future global temperature and global sea level rise from a complete cessation of all CO2 emissions in the RGGI region as well as the proposed 30% reduction.

My analysis shows current growth rate in CO2 emissions from other countries of the world will quickly subsume any reductions in RGGI CO2 emissions. According to data from the U.S. Energy Information Administration (EIA) and based on trends in CO2 emissions growth over the past decade, global growth will completely replace an elimination of all 2010 CO2 emissions from RGGI states in 190 days. The proposed 30% reduction in the RGGI emissions cap will result in an additional reduction of 22.5 million tons but global growth will completely replace the expected reductions in 10 days.

Furthermore, using assumptions based on the Intergovernmental Panel on Climate Change (IPCC) Assessment Reports we can estimate the actual impact to global warming for a change to the cap. The proposed 30% reduction in the RGGI emissions cap will result in an additional reduction of 22.5 million tons which is projected to ultimately impact global temperature rise by a reduction, or a “savings,” of 0.00033°C by the year 2050 and 0.00069°C by the year 2100.

These predicted temperature savings for the 30% RGGI emission reduction have to be put in context to fully appreciate their insignificance. The National Oceanic & Atmospheric Administration’s Requirements and Standards for NWS Climate Observations states that: “The observer will round the entered data to whole units Fahrenheit”. The nearest whole degree Fahrenheit (0.55°C) is over 1600 times greater than the projected change in temperature so the impact will not be observed.

Another way to relate to the savings is to compare those temperatures differences to climatological temperature variation. Table 3 RGGI 30% Emission Reduction Temperature Savings  compares the projected temperature savings to the temperature climatology of Syracuse, NY. I chose Syracuse because I live there but using any location in the RGGI states would show similar numbers. On an annual basis the temperature range for the highest and lowest recorded temperatures in Syracuse was a 129 deg. F which is 214,000 times greater than the temperature difference that would result from the proposed 30% reduction in emissions. On a seasonal basis the ranges between the daily maximum, minimum and average are all listed and the lowest ratio is that the daily minimum temperature range over the year is 77,000 times greater than the temperature difference that would result from the proposed 30% reduction in emissions. There also is a range in temperature every day and the maximum, minimum, and average hourly maximum and minimum difference ranges are listed. The lowest ratio is for the minimum difference between the observed maximum and minimum temperatures and that is over 22,000 times greater than the temperature difference that would result from the proposed 30% reduction in emissions.

Unfortunately those numbers still don’t completely reflect the futility of claiming that the 30% RGGI emission reduction is anything other than a symbolic gesture. A more relatable context would be to consider them in relation to typical changes in temperature with elevation and latitude. Generally, temperature decreases three degrees Fahrenheit for every 1,000 foot increase in elevation above sea level. The temperature difference projected for the 30% reduction in RGGI emission is equivalent to a one inch drop in elevation. The general rule is that temperature changes three degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level. The temperature difference projected for the 30% reduction in RGGI emission is equivalent to going south 159 feet. Given that those changes are insignificant compared to everyone’s daily experience it is clear that no environmental impacts caused by global warming could possibly be affected with this emission reduction.

Summary

RGGI has been a success inasmuch as it has successfully demonstrated how a cap and auction program can be run, has contributed to the observed CO2 reductions and has provided worthwhile investments in energy efficiency, energy conservation, and ratepayer direct bill assistance. On the other hand, RGGI has no demonstrated success providing the magnitude of CO2 reductions necessary to meet the proposed post-2021 cap reduction of 2,275,000 tons per year. Therefore, it would be prudent for RGGI to delay implementation of any cap reductions after 2020 to determine the actual rate of CO2 reductions produced by other programs. As shown in my analysis of global warming impacts there is no pressing environmental impact rationale to implement reductions as proposed. The success and the credibility of the program itself is endangered by the reckless insistence on a further 30% reduction in emissions at this time.

Millennium Proposed Valley Lateral Pipeline Project

There is no better example of New York State’s utter disregard of pragmatic environmental policy than the Department of Environmental Conservation’s (DEC) denial of water quality permits for the construction of a 7.8 mile natural gas pipeline to the CPV Valley Energy Center which is under construction and expected to be completed in early 2018. On October 16, 2017 the DEC filed a formal challenge to the Federal Energy Regulatory Commission’s (FERC) decision that DEC waived its jurisdiction under the federal Clean Water Act for the Millennium Pipeline Company’s proposed Valley Lateral project.

Before proceeding a disclaimer. Before retirement from the electric generating industry, I was actively analyzing air quality regulations that could affect company operations. I am convinced that evidence-based environmental decision making is necessary to maintain New York’s electrical system infrastructure and that is the reason I maintain this blog. Sadly, motivated reasoning where the conclusions are based on emotions or preconceptions and the evidence used only reflects that belief while anything else is ignored appears to be the rationale for much of current New York environmental and energy policy. 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.

According to the DEC website for the project the Department of Environmental Conservation (DEC) has conditionally denied water quality permits for Millennium’s proposed Valley Lateral pipeline project. The conditional denial is based in part on the inadequacy of the environmental review conducted by the Federal Energy Regulatory Commission (FERC), which failed to account for downstream greenhouse gas emissions.” DEC goes on to say: “DEC subjects all applications for environmental permits to an extensive and transparent review process that encourages public input at every step‎, and DEC’s determination included consideration of nearly 6,000 public comments. DEC will continue to thoroughly evaluate all applications to ensure they do not adversely impact the environment.”

The DEC description of the project notes:

Construction of a new 7.8 mile, 16-inch diameter natural gas pipeline lateral extending from Millennium’s existing main line pipeline north to the new 650 megawatt natural gas powered Competitive Power Ventures (CPV) Valley Energy Center. The proposed pipeline lateral is located in the Towns of Wawayanda and Minisink in Orange County, New York. The project would provide approximately 130 million cubic feet per day of natural gas to the CPV Valley Energy Center.

The pipeline lateral would be installed via horizontal directional drill (HDD) below two Class C(t) streams (Rutgers Creek) and seven federally regulated streams (no impacts). Additionally, the pipeline lateral would be installed via open trench within three federally regulated streams resulting in a temporary disturbance to the bed and banks of the streams for a total of approximately 16 linear feet.

Three state regulated Freshwater Wetlands (MD-23, MD-26 and MD-29) would be crossed via trenchless methods (no impacts). A total of 1.35 acres of federally regulated wetlands would be temporarily impacted by the construction of the pipeline lateral and 0.34 acres of federally regulated wetlands would be permanently impacted by the operation of the pipeline lateral.

From the water quality standpoint the permanent wetland impact of the pipeline is equivalent to a plot of land 120 feet by 120 feet. That is not the reason used to deny the water permit.  Instead they claim the downstream impact of the natural gas emissions have to be considered. So what are those impacts?

DEC notes that the pipeline would provide approximately 130 million cubic feet per day of natural gas to the CPV Valley Energy Center where it will be burned to produce power. To be conservative assume that the pipeline provides 260 million cubic feet per day or 94,965 million cubic feet per year. Using EPA emission factors that would result in annual emissions of 5,169,853 metric tons of CO2 per year.

I assume that the downstream impact of interest is the predicted temperature impact on global warming. For the CPV Valley Energy Center that can be estimated by adapting estimates in Analysis of US and State-By-State Carbon Dioxide Emissions (For 2010) and Potential “Savings” in Future Global Temperature and Global Sea Level Rise from a Complete Cessation of All CO2 Emissions by Paul Knappenberger. These climate change calculations are based on Intergovermental Panel on Climate Change reports using the MAGICC climate model simulator (MAGICC: Model for the Assessment of Greenhouse-gas Induced Climate Change). MAGICC was developed by scientists at the National Center for Atmospheric Research under funding by the U.S. Environmental Protection Agency and other organizations. MAGICC is itself a collection of simple gas-cycle, climate, and ice-melt models that is designed to emulate the output of complex climate models. MAGICC produces projections of the global average temperature and sea level change under user configurable emissions scenarios and model parameters. There are many parameters that can be altered when running MAGICC, including the climate sensitivity (how much warming the model produces from a doubling of CO2 concentration) and the size of the effect produced by aerosols. In all cases, the MAGICC default settings were used (for example, a climate sensitivity of 3.0°C), which represent the middle-of-the-road estimates for these parameter values.

In order to calculate the temperature impact of the 5,169,853 metric tons emissions from CPV Valley Energy Center the parameters estimated when the US observed 2010 CO2 emissions were simply scaled by 167.1 million metric tons divided by 5,631.3 million metric tons as shown in Table 1 CPV Valley Energy Center Impact on Global Warming. The results indicate that the project will increase global warming 0.00008 Deg. C by 2050.

DEC claims to “thoroughly evaluate all applications to ensure they do not adversely impact the environment”. In order to determine the impact on the environment we should consider the predicted temperature impact relative to the environment.

The National Oceanic & Atmospheric Administration’s Requirements and Standards for NWS Climate Observations states that: “The observer will round the entered data to whole units Fahrenheit”. The nearest whole degree Fahrenheit (0.55°C) is over 7,000 times greater than the projected change in temperature so the impact will not be observed by the NOAA monitoring system.

Another way to relate to the savings is to compare those temperatures differences to climatological variation. Table 2 CPV Valley Energy Center Temperature Impact Relative to Middletown NY Climate compares the projected temperature impacts to the average temperature climatology of Middletown, NY near where the project is located. The annual temperature range for the maximum daily average high and the minimum daily low in Middletown is 65.8 F degrees which is 863,000 times greater than the temperature difference that would result from the potential emissions. The annual temperature range for the average daily high and the average daily low in Middletown is 19.7 F degrees which is 258,000 times greater than the temperature difference that would result from the potential emissions. There is a range in temperature every day and the maximum, minimum, and average hourly maximum and minimum difference ranges are listed. The lowest ratio is for the minimum difference between the observed maximum and minimum temperatures and that is over 178,000 times greater than the temperature difference that would result from the potential emissions.

Unfortunately those numbers still don’t completely reflect the absurdity of claiming that this facility will have an adverse impact on the environment due to downstream impacts of its emissions. A more relatable context would be to consider them in relation to typical changes in temperature with elevation and latitude. Generally, temperature decreases three degrees Fahrenheit for every 1,000 foot increase in elevation above sea level. The temperature increase projected for the potential emissions is equivalent to a 3/8” drop in elevation. The general rule is that temperature changes three degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level. The temperature increase projected for the potential emissions is equivalent to going south 40 feet.

Clearly the technical evidence is that these changes are insignificant so no environmental impacts associated with global warming could possibly be affected with these emissions. Any rational pragmatic environmental policy would weigh the benefits of this project against these insignificant impacts and approve the permits without delay.

Investment of RGGI Proceeds in 2015

This is a post on the latest Regional Greenhouse Gas Initiative (RGGI) report: Investment of RGGI Proceeds in 2015. It is another in a series of posts on RGGI that discusses how RGGI has fared so far (see posts labelled RGGI in the menu). Although the press release, RGGI Report: Investments Generating Consumer Benefits, describes the benefits of the program in glowing terms there are some unsettling numbers buried in the report.

I have been involved in the RGGI program process since its inception. Before retirement from a non-regulated generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance. After years dealing with RGGI I worry that whether due to boredom or frustration, that there is very little dissent to the program. It may be because, contrary to EPA and State agency rulemakings, RGGI does not respond to critical comments and rebut concerns raised by stakeholders. After years of making comments that disappear into a void, industry does not seem to think there is value to making comments. 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.

Summary of the Report Results

According to the Executive Summary in this report:

Proceeds from the Regional Greenhouse Gas Initiative (RGGI) have powered a major investment in the energy future of the New England and Mid-Atlantic states. This report reviews the benefits of programs funded in 2015 by RGGI investments, which have reduced harmful carbon dioxide (CO2) pollution while spurring local economic growth and job creation. The lifetime effects of these RGGI investments are projected to save 28 million MMBtu of fossil fuel energy and 9 million MWh of electricity, avoiding the release of 5.3 million short tons of carbon pollution.

As a whole, the RGGI states have reduced power sector CO2 pollution over 45 percent since 2005, while the region’s per-capita GDP has continued to grow. RGGI-funded programs also save consumers money and help support businesses. RGGI investments in 2015 are estimated to return $2.31 billion in lifetime energy bill savings to more than 161,000 households and 6,000 businesses which participated in programs funded by RGGI investments, and to 1.5 million households and over 37,000 businesses which received direct bill assistance.

The report describes how the RGGI investments were used 2015, a brief summary of cumulative investments, and then provides specific information for each state including an example of the programs.

Critique

The first step evaluating the claims of the RGGI states is to convert the pretty graphics to numbers. Chart 4 Cumulative RGGI Investments by Category is an example of the graphical data provided. In the table, All-Time RGGI Investments by Category %, I extracted the numbers shown for each analogous State graphic. In the State information sections the amount of money invested, received and diverted to the general fund for each state is listed. In the table, All-Time RGGI Investments by Category $Millions, I listed those numbers then multiplied them by the State category percentages to get total category amounts.

When you extract the numbers a less complimentary picture of the RGGI proceeds investments emerges. For starters, Chart 4 RGGI Investments by Category does not include the embarrassing raids of RGGI funds by New York and New Hampshire. In reality, the correct percentages are shown as the last row in the All-Time RGGI Investments by Category $Millions table. Similarly, the individual state category investments do not include the General Fund raids which would have shown that 10% of the New York “investments” went to political expediency.

There are some financial issues raised when the amounts are available for each state. Note the difference between the RGGI monies received and investments made and the column labelled “investments received %” which is simply investments divided by received. There is a huge range between the states. Vermont is the most efficient turning the money received into investments but six of the nine states all managed to invest at least 80% by the end of 2015. Delaware, Rhode Island and New York did much worse. It is probably no coincidence that the Administrative cost percentages for Delaware, Rhode Island and New York were among the highest four state percentages.

Administrative costs in general and the tithe to RGGI total over $100 million.   Coupled with the general fund raids there is clearly a cautionary tale for carbon tax advocates who suggest that returning those taxes revenues to the public will minimize impacts. In my opinion, whenever there is a large pot of money available there will be politicians abusing their power to the disadvantage of the public.

The cost effectiveness of these investments is not presented in the report. The report notes that the lifetime effects of the 2015 RGGI investments are projected to save 28 million MMBtu of fossil fuel energy and 9 million MWh of electricity, avoiding the release of 5.3 million short tons of carbon pollution. In Chart 2 there is a note that states that the RGGI states invested $410,158,329 in 2015. The lifetime effects cost $15 per MMBtu, $46 per MWh of electricity and $77 per ton of carbon. I am unfamiliar with the benchmark costs per MMBtu and MWh for comparison with the RGGI effectiveness. However, the common justification for carbon reduction costs is the social cost of carbon. At a 3% discount rate, EPA says that the 2015 social cost of carbon was $36. RGGI investments are reducing carbon at twice the rate claimed to value the climate impact of rulemakings so their investments are not cost effective in this regard.

There is one other aspect of this report that needs to be addressed. The Executive Summary notes that “the RGGI states have reduced power sector CO2 pollution over 45 percent since 2005”. There is no better example of mis-direction in the reporting on the impact of RGGI in this document than this statement. The casual reader would certainly conclude that the RGGI program itself was responsible if not for the entire reduction at least a sizeable portion of the reduction. However, looking at CO2 reductions in the RGGI states that is not the case. In the first place, the program started in 2009. As shown in the EPA CAMD Annual CO2 Trend Data table the reduction from the last year before RGGI was instituted to 2015 was 31%, much less than the 45% claimed. (Note that my numbers don’t match the RGGI report which I believe is because I relied on the EPA Clean Air Markets Division database with the assumption that summing all the annual CO2 from the all programs that report CO2 was a good enough approximation. If RGGI only summed data from RGGI-affected units it could certainly account for the difference between numbers.)

However, it is even worse. The 20.5 million decrease is only a 16.1% reduction from the 2006-2008 baseline. This is consistent with my previous post on CO2 reductions due to RGGI which showed that RGGI is only responsible for between 24% and 5% of the observed reduction.

There is one final implication to the RGGI investments “success” with carbon reductions. The proposed program revisions released last month for RGGI call for an annual post-2021 cap reduction of 2,275,000 tons per year. In the Proceeds Investment Report Table 1: Benefits of 2015 RGGI Investments Program the annual benefits of 2015 investments lists an annual reduction of 298,410 tons. As shown in a white paper submitted to RGGI by the Environmental Energy Alliance of New York the affected electrical generation units have made most if not all of the cost effective reductions possible from their operations. As a result, future reductions will have to come from other investments but RGGI has no track record providing any assurance that RGGI investments will be sufficient to meet the targets proposed. For the record if a compliance entity has no allowances available to cover emissions their only compliance alternative is not run. If that happens then RGGI states will have a whole lot of explaining to do.