Trust in meteorology has saved lives. Is the same possible for climate science?

This article was published at Watts Up With That on October 19, 2021

In a special to the Washington Post Oliver Uberti opines that “Trust in meteorology has saved lives. The same is possible for climate science”.  The former senior design editor for the National Geographic and co-author of three critically acclaimed books of maps and graphics does an excellent job tracing the history of weather forecasting and mapping.  Unfortunately he leaps to the conclusion that because meteorological forecasting has worked well and we now “have access to ample climate data and data visualization that gives us the knowledge to take bold actions”.

Uberti writes:

“The long history of weather forecasting and weather mapping shows that having access to good data can help us make better choices in our own lives. Trust in meteorology has made our communities, commutes and commerce safer — and the same is possible for climate science.”

I recommend reading most of the article.  He traces the history of weather observations and mapping from 1856 when the first director of the Smithsonian Institution, Joseph Henry, started posting the nation’s weather on a map at its headquarters.  Eventually he managed to persuade telegraph companies to transmit weather reports each day and eventually he managed to have 500 observers reporting.  However, the Civil War crippled the network.  Increase A. Lapham, a self-taught naturalist and scientist proposed a storm-warning service that was established under the U.S. Army Signal Office in 1870.  Even though the impetus was for a warning system, it was many years before the system actually made storm warning forecasts.  Uberti explains that eventually the importance of storm forecasting was realized, warnings made meaningful safety contributions, and combining science with good communications and visuals “helped the public better understand the weather shaping their lives and this enabled them to take action”.

Then Uberti goes off the rails:

“The 10 hottest years on record have occurred since Katrina inundated New Orleans in 2005. And as sea surface temperatures have risen, so have the number of tropical cyclones, as well as their size, force and saturation. In fact, many of the world’s costliest storms in terms of property damage have occurred since Katrina.”

“Two hundred years ago, a 10-day forecast would have seemed preposterous. Now we can predict if we’ll need an umbrella tomorrow or a snowplow next week. Imagine if we planned careers, bought homes, built infrastructure and passed policy based on 50-year forecasts as routinely as we plan our weeks by five-day ones.”

“Unlike our predecessors of the 19th or even 20th centuries, we have access to ample climate data and data visualization that give us the knowledge to take bold actions. What we do with that knowledge is a matter of political will. It may be too late to stop the coming storm, but we still have time to board our windows.”

It is amazing to me that authors like Uberti don’t see the obvious difference between the trust the public has in weather forecasts and misgivings about climate forecasts.  Weather forecasts have verified their skill over years of observations and can prove improvements over time.  Andy May’s recent article documenting that the Old Farmer’s Almanac has a better forecast record, for 230 years, than the Intergovernmental Panel on Climate Change (IPCC) has for 30 years suggests that there is little reason the general public should trust climate forecasts.  The post includes a couple of figures plotting IPPC climate model projections with observations that clearly disprove any notion of model skill. 

Sorry, the suggestion that passing policy based on 50-year climate science forecasts is somehow supported by the success of weather forecast models is mis-guided at best.

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Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

Climate Leadership & Community Protection Act Integration Analysis: New Findings

At the October 1, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) described findings from the integration analysis.  These findings underscore the difficulties faced to meet the CLCPA targets.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

The Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline and supply 70% or the electrical energy come from renewable resources by 2030 and by 2040 provide all electricity from zero-emissions sources.  Meeting these targets will require a transition of the entire New York energy system.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  The Council and the advisory panels are composed of political appointees chosen more for their advocacy and politics than their expertise in the energy sector.  In order to address the lack of expertise and assemble a comprehensive strategy New York State Energy Research and Development Authority (NYSERDA) and their consultants are providing technical support by developing an integration analysis.

The integration analysis has developed a reference case and four scenarios that include specific strategies, emission estimates, and costs for Climate Action Council comment and discussion:

      • Reference Case
        • Currently implemented policies
      • Scenario 1: Advisory Panel Recommendations
        • Aggregate impacts of recommendations from Advisory Panels
        • Scenarios that meet or exceed GHG emission limits, achieve carbon neutrality by midcentury
      • Scenario 2: Strategic Use of Low-Carbon Fuels
        • Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications
      • Scenario 3: Accelerated Transition Away from Combustion
        • Low-to-no bioenergy and hydrogen combustion; Accelerated electrification of buildings and transportation
      • Scenario 4: Beyond 85% Reduction
        • Accelerated electrification limited low-carbon fuels; Additional VMT reductions; Additional innovation in methane abatement; Avoids direct air capture of CO2

According to the presentation in order to meet the targets, there are foundational themes across the scenarios based on findings from Advisory Panels and supporting analysis:

      • Zero emission power sector by 2040
      • Enhancement and expansion of transit & vehicle miles traveled reduction
      • More rapid and widespread end-use electrification & efficiency
      • Higher methane mitigation in agriculture and waste
      • End-use electric load flexibility reflective of high customer engagement and advanced techs

The schedule for the remainder of the year is ambitious.  The integration analysis will be incorporated into the draft scoping plan by the end of October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

New Findings

I extracted the bullet points describing the new findings of the integration analysis from the October 1, 2021 Climate Action Council meeting presentation.  My reaction to these findings is shown in italics below.

  • Achievement of emissions reductions to meet state law requires action in all sectors, especially considering New York State’s novel emissions accounting

Novel emissions reporting refers to the emphasis on greenhouse gases other than CO2, particularly, methane and nitrous oxides.  Novel is another way of saying no other jurisdiction in the world has prepared an inventory of emissions with such an overt and flawed emphasis on natural gas.

      • Every sector will see high levels of transformation over the next decade and beyond, requiring critical investments in New York’s economy
  • Energy efficiency and end-use electrification will be essential parts of any Pathway that hits NYS Emissions Limits
      • In all scenarios modeled, zero emission vehicles and heat pumps become the majority of new purchases by the late 2020s, and fossil-emitting cars and appliances are no longer sold after 2035
      • 1 -2 million efficient homes electrified with heat pumps by 2030
          • In 2017 there were 7,302,710 occupied housing units in NYS
          • 2% or 820,554 used electricity for space heating
          • The fraction of heat pumps used is unknown but has to be small
          • To reach 1.5 million heat pump homes requires about 200,000 conversions per year
      • Approximately 3 million zero-emission vehicles (predominantly battery electric) by 2030
          • 1 million vehicle registrations on file in 2018 so 2030 is 27% EV
          • On 9/2/2021 there were 81,858 ZEVs on the road in NY, 0.9%
          • Over the last 12 months 2.15% of the new vehicles registered were electric vehicles and the greatest month was 4.36%
  • Unprecedented rate of adoption of novel and potentially disruptive technologies and measures

Disruptive technologies “significantly alter the way consumers, industries, or businesses operate”.  “To be considered disruptive, technology must be easily accessed by a majority of the population. Revolutionary inventions are often not disruptive because they’re too expensive for the common consumer. In many cases, it’s not until the technology is refined enough to become affordable that it’s considered disruptive to the market. A disruptive technology is one that enters the mainstream and changes the way most people think or behave.

Disadvantages of disruptive technologies:

          • “New technology is typically untested and unrefined during its early stages and development can continue for years.”
          • “Nearly all innovations go through a period of problem-solving.”
          • “It can take time for a disruptive technology to find its place in the marketplace.”

It is incredibly risky to be counting on novel and disruptive technologies to meet the CLCPA targets.

  • Consumer decision-making plays a large role, especially important for the purchase of new passenger vehicles and heating systems for homes and businesses through the next decade

The climate act implementation echo chamber has not addressed what will happen when there is an extended outage following an ice storm.  Many folks have a contingency plan for that kind of an event but see no reasonable alternatives when everything is electrified.

  • Substantially reduce vehicle miles traveled while increasing transportation access
    • Expansion of transit service structured around community needs
    • Smart growth inclusive of equitable transit-oriented development
    • Transportation demand management

I do not believe that the majority of New Yorkers are aware that the CLCPA will mandate these limitations on personal mobility.  The climate act implementation echo chamber has not explained how this will not have massive impacts to rural areas and the rural poor.

  • Wind, water, and sunlight power the majority of New York’s economy in 2050 in all Pathways
    • Even with aggressively managed load, electric consumption doubles and peak nearly doubles by 2050, and NYS becomes a winter peaking system by 2035.

Although the presentation mentions that the reliability standards are included in the scenarios it is not clear to me that is the case because there is so little documentation available.  Furthermore, I think it is likely that there will be new reliability rules that certainly have not been included.

  • Offshore wind on the order of 20 GW, solar on the order of 60 GW, and 4-and 8-hour battery storage on the order of 20 GW by 2050

These are extraordinary numbers.  The largest integrated solar-powered battery will be at the Florida Power & Light Manatee Solar Energy Center rated at 409 MW, 900 MWh.  Note that the energy storage facility only provides two hours of storage so over 100 equivalent facilities will have to be built.

  • Firm, zero-emission resources, such as green hydrogen or long-duration storage, will play an important role to ensure a reliable electricity system beyond 2040

Long-duration storage does not exist today and green hydrogen has not been deployed at utility scale.  Moreover, as the hydrogen is produced it will have to be stored and transported to where it will be used which is no easy feat.

  • Low-carbon fuels such as bioenergy or hydrogen may play a critical role in helping to decarbonize sectors that are challenging to electrify
    • By 2030, initial market adoption of green hydrogen in the following applications: medium and heavy-duty vehicles, high-temperature industrial (sic).

For a technology not yet commercially available expecting any significant market adoption in this time frame is a stretch.

  • Additional promising end-use applications include district heating and non-road transportation such as aviation and rail.

In theory these fuels might work for these applications but the technology has not been proven.

  • Required transition to low-GWP refrigerants and enhanced refrigerant management by 2050

If these refrigerants and enhanced management were cost-effective,then they would be used now.

  • Large-scale carbon sequestration opportunities include lands and forests and negative emissions technologies
    • Protecting and growing New York’s forests is required for carbon neutrality

I get the impression but have not confirmed that one of the control strategies is to convert home heating with wood to electric.  The concept that people do that because they cannot afford alternatives and the probable increase in costs associated with this law suggests that more rather than less people will want to heat with wood.  It is not clear to me how the State would regulate a land owner’s use of wood for home heating.

  • Negative emissions technologies (e.g., direct air capture of CO2) may be required if the State cannot exceed 85% direct emissions reductions

This is an absurd statement because it presumes that the New York contribution to the total greenhouse gas levels in the atmosphere can be measured to the point where direct air capture could have an effect.  

  • Strategic land-use planning will be essential to balance needs
  • Necessary methane emissions mitigation in waste and agriculture will require transformative solutions
    • Diversion of organic waste, capture of fugitive methane emissions are key in waste sector

Easy to say but extremely difficult to implement in practice.

  • Alternative manure management and animal feeding practices are key in agriculture

If these practices were cost-effective farmers would be doing them today.  Apparently they are not using them so who pays for farmers to use them?

 Additional innovation will be required in areas such as carbon sequestration solutions, long-duration storage, flexible electric loads, low-GWP refrigerants, and animal feeding, in concert with Federal action (e.g. Earthshots)

Requiring “additional innovation” to ensure that the lights are on, homes are kept warm and people will be able to charge their mandated electric vehicles is extraordinarily risky.  If the risks associated with the effects of climate change that could be changed by New York emissions were compared to the risks of this policy causing a blackout, then I have no doubts that the integration analysis strategies would be rejected out of hand.

 For what it is worth, the Earthshot example refers to the Department of Energy’s “Energy Earthshots” that will “accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade”.  Even if they accomplish a breakthrough the CLCPA schedule is too aggressive to take advantage of it.

  • Largest three remaining sources of emissions in 2050: Landfills, aviation, and animal feeding

No comment.

Conclusion

Of particular concern is that the integration analysis acknowledges that disruptive technologies will be required to meet the CLCPA targets.  I explain that these technologies are typically untested and unrefined during early stages and development can continue for years.  These innovations go through a period of problem-solving.  Given that the electric system has a long history of revisions following blackouts to address reliability problems as they arose it is unrealistic to expect that similar problems will not arise in the future. 

In order to meet the CLCPA legal schedule there has been insufficient time to prepare the documentation necessary for stakeholders to evaluate the proposed strategies.  However, given the absolute need to try to avoid catastrophic problems the integration analysis scenarios have to be fully documented.  Climate Action Council meetings have included multiple member statements arguing that the law requires some of the more unrealistic proposals incorporated into the strategies.  The ultimate question for the Climate Act is what happens when stakeholders expose the reliability risks of those strategies.  Will the Hochul administration cave to the special interests or listen to those responsible for keeping the lights on.

Climate Leadership & Community Protection Act First Impression of Estimated Costs and Benefits

At the October 14, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) presented the first estimates of costs and benefits.  Not surprisingly they conjure up a way to claim that the benefits out weighed the costs.  This will be my first post on those claims.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

I will update this post when the presentation slide deck (available 10/15/21) and meeting recording are posted. 

The Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline by 2030.  In 2030 70% or the electrical energy is supposed to come from renewable resources and by 2040 all electricity is supposed to come from zero-emissions sources.  The Council is composed of political appointees chosen more for their direct involvement in the CLCPA transition than their expertise in the energy sector so the New York State Energy Research and Development Authority (NYSERDA) is providing technical support by developing an integration analysis.

The October 14, 2021 Climate Action Council meeting included the following topics:

  • Overview of scenarios and recap of sectoral results
  • Costs and Benefits Analysis
  • Electric System Sensitivities
  • Air Quality and Health Effects
  • Update on Approach for Potential Carbon Pricing Analysis

There is fodder for multiple posts in this material but most will have to wait until another day.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  NYSERDA and their consultants determined that those recommendations did not meet the targets and prepared an integration analysis to provide alternatives.  The following scenario overview lists three scenarios that meet or exceed the limits.  (For this post I will concentrate on Scenario 2: Strategic Use of Low-Carbon Fuels.)  The integration analysis will be incorporated into the draft scoping plan in October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

October 1, 2021 Meeting Presentation

Societal Benefits

The focus of this post will be on the first mention of cost and benefit data at the October 14, 2021 Climate Action Council meeting.  As expected, they made up a way to claim that the benefits out-weigh the costs.  Readers should keep in mind that the costs are real.  Completely re-building the entire New York energy sector will cost enormous sums of money and, at first glance, estimates of several hundred billion for the complete transition are laughably low for the all-in costs.  On the other hand, estimates of benefits are heavily dependent upon value judgements and analysis assumptions to the point that there are such a wide range of possible outcomes that claiming a single value is fantasy.

According to the presentation the integration analysis approach will include three components as shown in the following slide captures.   The integration analysis will evaluate societal costs and benefits of greenhouse gas (GHG) mitigation for the different scenarios relative to a reference scenario.   The value of avoided GHG emissions will be calculated based on guidance provided by the Department of Environmental Conservation (DEC). The third component is an analysis of health co-benefits.  In the remainder of this post, I will focus on the alleged benefits.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting
Screen capture of slide presented at October 14, 2021 Climate Action Council meeting
Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

According to the presentation the cost of inaction exceeds the cost of action by more than $80 billion.  For the Strategic Use of Low Carbon Fuels scenario the estimated costs are $340 billion and the benefits total $420 billion.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

The benefits breakdown in the Strategic Use of Low Carbon Fuels scenario into two categories.  In the first there are $160 billion in benefits due to improvements in air quality, increased active transportation, and energy efficiency interventions in low- and moderate- income homes.  Reducing GHG emissions avoid social costs due to climate change to the tune of $260 billion.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

Value of Avoided Carbon

I described problems with the DEC Value of Avoided Carbon Guidance in a couple of posts earlier this year.  In my first post I noted that the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal.  I believe that the guidance approach is wrong because it applies the social cost multiple times for each year of an emission reduction.  In the second post I described how I  submitted comments on this topic to DEC and NYSERDA in February and followed up in June.  The response “We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level.”  I will just summarize my arguments and the effect on the estimated benefits here.

In section §75-0113, Value of Carbon the CLCPA states that the “social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions” and that “As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero.”  The Social Cost of Carbon (SCC) is the present-day value of projected future net damages from emitting a ton of CO2 today. 

In my comments to DEC, I explained that it is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. . The social cost calculation that is the basis of their carbon valuation sums projected benefits for every year subsequent to the year the reductions are made out to the year 2300.  Clearly, using cumulative values for this parameter is incorrect because it cumulatively counts those benefits repeatedly.  I contacted social cost of carbon expert Dr. Richard Tol about the use of lifetime savings and he stated that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”.  Note that Dr. Tol is using the social cost of carbon nomenclature rather than value of carbon label. 

The integration analysis claims reducing GHG emissions will provided societal benefits of avoided economic damages of $260 billion.  The correct value is much less.   DEC promulgated the 1990 baseline GHG emission inventory consistent with the CLCPA last year. According to §496.4 Statewide Greenhouse Gas Emission Limits (a) For the purposes of this Part, the estimated level of statewide greenhouse gas emissions in 1990 is 409.78 million metric tons of carbon dioxide equivalent, using a GWP20 as provided in Section 496.5 of this Part.  The DEC Value of Avoided Carbon Guidance recommends a social cost of $121 in 2020 and $172 in 2050.  If New York had magically eliminated all of the 409.78 million tons of GHG in 2020 the societal benefit of those reductions would have been $49.6 billion making the integration analysis 5.24 times too high.  If all the reductions occurred in 2050 the societal benefit would be $70.5 billion making the integration analysis 3.7 times too high.

Public Health Impacts

The health benefits of the strategic use of low carbon fuels scenarios total $160 billion.  While the health effects analysis considered multiple air pollutants and health benefits from energy efficiency the primary pollutant of concern is inhalable particulates or PM2.5.  I did a post on claims of inhalable particulates impacts in New York City last year.  The New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report is often referenced and provides a typical and consistent health benefit estimate from inhalable particulates.  The DOHMOH report concludes: “Each year, PM2.5 pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.”  These conclusions are for average air pollution levels in New York City as a whole over the period 2005-2007.

The DOHMOH report specified four scenarios for comparisons (DOHMOH Figure 4) and calculated health events that it attributed to citywide PM2.5 (DOHMOH Table 5).  Based on their results the report notes that:

Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits. Achieving the PlaNYC goal of “cleanest air of any big city” would result in even more substantial public health benefits.

Based on years of developing and using models I prefer observed results any time as opposed to model projections.  In this regard it is important to note that the NYS DEC air quality monitoring system has operated a PM2.5 monitor at the Botanical Garden in New York city since 1999 which provides inhalable particulate trends for New York City.  I compared the data from that site for the same period as this analysis relative to the most recent data available (Data from Figure 4. Baseline annual average PM2.5 levels in New York City). The Botanical Garden site had an annual average PM2.5 level of 13 µg/m3 for the same period as the report’s 13.9 µg/m3 “current conditions” city-wide average (my estimate based on their graph).  The important thing to note is that the latest available average (2018-2020) for a comparable three-year average at the Botanical Garden is 7.4 µg/m3 which represents a 43% decrease.  That is substantially lower than the PlaNYC goal of “cleanest air of any big city” scenario at an estimated city-wide average of 10.9 µg/m3

Until such time that the CLCPA Scoping Plan bases its inhalable particulate health benefits on the observed health outcome benefits observed from the reductions that have occurred, then I do not accept the health benefits suggested in the Integration Analysis.  If an analysis were done using actual data, I believe that the results would most likely show a much smaller benefit.  Note that the reduction in PM2.5 annual average concentrations in the Strategic Use of Low Carbon Fuels scenario predicts at most a reduction in PM 2.5 of 0.35 µg/m3.  The observed reduction in New York City since 2005-2007 is 5.6 µg/m3

Energy Efficiency

In the effort to prove that the costs of the New York transition to the CLCPA goals is out-weighed by benefits the integration analysis comes up with energy efficiency benefits.  I am not going to discuss this claim in detail so I provide the methodology slide below.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

The following slide lists the health-related measures and I am leery of the claims.  They expect to reduce asthma-related incidents by increasing weatherization presumably to keep polluted ambient air out.  It is my understanding that asthma rates have increased even as pollution rates have gone down so this measure may have the perverse effect of increasing whatever is causing the observed asthma incidents.  I have no idea how this strategy can reduce trip or fall injuries.  Health benefits from reduced hot and cold thermal stress are claimed.  Note that increased costs of energy in England have forced lower-income residents to lower their thermostats thus increasing thermal stress from cold.  This is a likely outcome in New York.

Screen capture of slide presented at October 14, 2021 Climate Action Council meeting

Conclusion

I have no doubts that when I evaluate their costs for the transition that I will find markedly higher costs.  Even if estimated costs end up being reasonable, the incorrect valuation of the societal benefits of carbon reductions drops the benefits to no more than $70.5 billion. Coupled with their values for health effects benefits that reduces total benefits to $230.5 billion as opposed to costs of $340 billion. 

Moreover, the costs will be real but the benefits are something else again.  The social cost of carbon is the greater alleged benefit.  Because that represents the societal benefits of reducing a ton of carbon today totaled out to 2300 and the impacts of climate change are more expensive closer to 2300 that means that most of those alleged benefits will not accrue to this generation of New York residents, their children, their grandchildren, or even their great grandchildren.  In addition, I have major reservations with the alleged health benefits.

The bottom line is that CLCPA is not cost effective relative to societal benefits.

CLCPA “Winging It” is a Catastrophe Waiting to Happen

At the September 13, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  I agree that this is an important consideration and recently wrote that the European experience reflects not only high energy costs but there are troubling signs that reliability issues can occur even during periods when the electric system is not stressed due to high demand.  This post calls reader’s attention to Minister of Parliament Steve Baker’s recent article on the United Kingdom’s similar plans to reach net zero emissions.   

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Steve Baker is a Conservative MP and former Brexit Minister. He is a trustee of the Global Warming Policy Foundation (GWPF).  I wanted to include a description of the GWPF in this section but recent changes have made that difficult.  If you do an internet search for the GWPF, you will get a string of results all branding them as the “United Kingdom’s most high profile climate denier group” but won’t be able to find their own link without searching.   If you get to gwpf.com then you are redirected to Net Zero Watch.  GWPF has set up Net Zero Watch to “provide serious analysis of naïve and un-costed decarbonisation policies.”  They plan to “highlight the serious economic, societal and geopolitical impacts of poorly-considered policies, both domestically and internationally”.

Net Zero Watch has been setup to “highlight and discuss the serious implications of expensive and poorly considered climate change policies”.  A recent energy crisis in Europe foreshadows New York’s future under the CLCPA:

With our domestic shale gas resources sitting untapped under an absurd government ban, gas prices are going through the roof. Net Zero Watch will challenge the wild claims of green activists and policy advisers about this venerable and benign technology, which has brought US gas prices down to a small fraction of those here.  As this year’s weather has shown, our decision to phase out fossil fuels and nuclear power and to rely more and more on wind farms for our electricity supply has had dangerous consequences. We will campaign to put affordability and security of supply back at the centre of the energy debate, and we will expose the risky wishful thinking behind many claims about energy storage.

Baker’s description of the United Kingdom net-zero plan is entirely consistent with my impression of the CLCPA.  The following section quotes Steve Baker’s commentary in italics with my indented and unitalicized comments.  I don’t have many comments because one only has to substitute New York for UK and Albany for Westminster for the most part.

“Winging It” is a Catastrophe Waiting to Happen

The UK’s plans to decarbonise the economy are a classic example of the ancient political strategy of “winging it”. Hard though it is to credit that idea, it’s true; the “experts” in Westminster have been basing your future and mine on a plan that relies, to a very great extent, on a collective crossing of the fingers.

 The CLCPA experts in Albany rely on bureaucrats at the state agencies that have to tailor their results to meet the political agendas of their appointed directors to sustain their careers.

Governments of one shade or another, Whitehall bureaucrats, and their advisers in the Climate Change Committee have been working on such plans for well over a decade now, and it’s fair to say that they still have little or no idea how Net Zero can be achieved, beyond a vague idea that we should electrify everything and have lots of energy from windfarms.

 The description of the scenarios to meet the CLCPA targets at the October 1, 2021 meeting of the Climate Action Council is entirely consistent with this description.

 That’s no more than a starting point, of course. There are enormous practical difficulties (and eye-watering costs) to be dealt with, but such nitty-gritty issues seem of little interest to the experts in Westminster. “Things will become cheaper…” they say “….we’ll invent something”.

 Expert handwaving of this kind has been enough to convince the media and most politicians, but as the legendary physicist Richard Feynman once pointed out, Nature cannot be fooled, and it looks very much as Nature is going to lay her cards on the table this winter.

 One of the key problems is that we don’t have any way to store electricity on a large scale for when the wind isn’t blowing. That can be a few weeks in a normal year, or months in a bad one. The problem has always been there, and we have had no firm answer from the “experts”. We don’t have enough suitable sites for pumped hydro; batteries and hydrogen are far too expensive. As was pointed out in a letter to one of the national newspapers last week, enough batteries to see us through a wind lull lasting just ten days would cost £150,000 per household at current prices.

 There is no reason to believe that New York’s costs to maintain current reliability standards will differ much from the £150,000 per household or $204,000 per household.

 The Climate Change Committee says that we can get electricity through interconnectors from other countries when the wind doesn’t blow here. This is something of a “magic solution” for them, because they can simply claim that we’ll build as much interconnector capacity as we need. However, it again ignores the practical difficulties, such as the fact that if the wind isn’t blowing here, it probably isn’t blowing in most of western Europe either, so assuming (as the “experts” in Westminster do) that everyone follows us down the decarbonisation path, we are all going to get in a bidding war for the few megawatts of power that are left. There is also a national security problem with interconnectors, as was recently brought sharply into focus by French threats to cut the UK off if we didn’t play ball over fishing rights.

 To this point, the CLCPA scenarios avoid the use of imported power and, for the most part, we don’t have to worry about international security issues.  Note, however, that a key component for New York City is a transmission interconnection for hydropower  from Quebec.

 The CCC also says we can get a bit of power from gas-fired power stations equipped with carbon capture and storage (CCS). However, the practical problems are again fairly stark; nobody has yet made a success of CCS – a series of pilot projects have tested the waters on the easier ground of coal-fired power stations, and each has been closed as an economic failure; the power they produce is simply too expensive. And nobody has yet got the technology to work at all for gas-fired power stations.

 New York’s plans include CCS for concrete manufacturing but so far have downplayed its use for power generation.  All of the concerns listed are relevant and don’t note that a suitable location for sequestration is needed.  Incredibly there are members of the Climate Action Council that want to prohibit all forms of combustion which would preclude the use of CCS altogether.

 The other problem with planning for gas and CCS to deliver us from the perils of intermittency is that it appears unlikely we are going to have any cheap gas to feed them with – successive governments, egged on by the CCC, the renewables industry, and the green movement have told us we must “keep fossil fuels in the ground”.

 This was seen in part as a way to encourage the second part of the decarbonisation strategy, namely for people to “invent something”. In other words, if we have no gas and no way to balance the grid, well, someone will come up with some way to fix the problem. So we first made the electricity grid unwelcoming for gas-fired power stations, then we neutered the nascent shale gas industry with absurd regulations, and then we banned it completely.

 This is entirely consistent with New York’s CLCPA implementation.

 Which brings us to where we are today, with the whole country crossing its fingers and praying that someone will “invent something”, or at least find us a way to make it through the winter without the lights going out.

 For twenty years, the vested interests have had their say, and public relations have taken precedence over engineering and economics. But, to return to Professor Feynman, Mother Nature really cannot be fooled, and when she reveals her hand, the results are likely to be horrible.

 Is catastrophe coming? I fear so, unless ministers get a grip and liberate the private sector to go for gas, right now.

 New York’s problems are not so imminent largely because Pennsylvania went ahead with the natural gas fracking and now has an abundance of natural gas to sell to New York.  Nonetheless, National Grid has warned its customers in Central New York that natural gas bills could go up 31% because of increased demand and a global spike in prices.  I cannot help but wonder if New York had developed its natural gas resources if we would be seeing a similar price increase.

 Conclusion

The slow motion train wreck that is the future of New York energy under the CLCPA will only continue to a similar crisis unless it is repealed for all of the reasons shown in MP Steve Baker’s commentary.  To date “vested interests have had their say, and public relations have taken precedence over engineering and economics” but at some point, reality has to be addressed.  The fact is that today’s wind, solar and energy storage technology is not up to the role conceived by the authors of the CLCPA.

RGGI Third Program Review Listening Session 5 October 2021

The Regional Greenhouse Gas Initiative (RGGI) is a carbon dioxide control program in the Northeastern United States.  One aspect of the program is a program review that is a “comprehensive, periodic review of their CO2 budget trading programs, to consider successes, impacts, and design elements”.  This article describes the first listening session of the third RGGI program review.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. 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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions. It is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont, and Virginia to cap and reduce CO2 emissions from the power sector.  According to a RGGI website:

“The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.” 

Proponents tout RGGI as a successful program because participating states have “cut carbon pollution from their power plants by more than half, improved public health by cutting dangerous air pollutants like soot and smog, invested more than $3 billion into their energy economies, and created tens of thousands of new job-years”.  Others have pointed out that RGGI was not the driving factor for the observed emission reductions.  My work supports that conclusion and points out that the cost-effectiveness of the investments from this carbon tax reduce CO2 emissions at a cost of $858 per ton which is far greater than the social cost of carbon metric.  In other words, RGGI investments not a cost-effective way to reduce CO2 emissions.

Third Program Review Listening Session 5 October 2021

The slides for the listening session and the meeting recording for the listening session give a good overview of what is planned.  Briefly the RGGI states are looking for input on the allowance cap, trajectory for changing the cap, allowance bank, compliance mechanisms and requirements, offsets, and “comment on how states can further address environmental justice and other equity concerns, including through program design and/or the use of RGGI auction proceeds to support underserved and/or otherwise affected communities.”

I posted an article that described my initial comments on the program review.  My comments recommend making no changes.  In the next few years, the RGGI allowance market will change to the unprecedented emissions trading situation in which the majority of the RGGI allowances are held by entities who purchased allowances for investment rather than compliance purposes.  No one knows how the market will react and the compliance mechanisms are working well as is so there is no need to change anything at this time.  I showed that RGGI investments only were directly responsible for less than 5% of the total observed reductions since RGGI began in 2009 the rest of the observed reductions occurred due to other factors, primarily fuel switching. Based on that observation, it appears to me that the goal of RGGI should be to balance the cap with emissions so that the allowance bank is only used for year-to-year variations in weather-related excess emissions.  Over time it may become necessary to adjust the emission reduction trajectory but that should be based on observations and not model projections.

The 5 October 2021 listening session consisted of three parts.  Presenters from RGGI and the RGGI states described the program and goals of the third program review in the first part.  They allocated time for questions and answers about the process and goals.  Finally, they offered stakeholders the opportunity to present oral comments.  The remainder of this post addresses those comments.

Ten people presented appropriate comments.  A couple of other people asked questions that were out of scope for the purpose of the meeting and I did not include their comments in this summary.  I classified the commenters into five categories.  The first category is “Little Green”.  There were two of these grass roots advocacy organizations which are usually non-profits, have small staff, address limited local and regional issues, and have not been around for a long time.  There were three commenters in the second category, “Green Analysis”.  These are consultants that have technical staff available to analyze environmental issues and policies.  The third category, “Green Legal”, had two commenters.  These are organizations that have lawyers who address environmental legal issues.  The fourth organization category is “Big Green”.  Both the National Resources Defense Council and the Environmental Defense Fund made comments.  These are large organizations that have advocates, scientists and lawyers, have been around for a long time and have large revenues and endowments.  Finally, there is a category for organizations that commented on RGGI solely because they are interested in the money available.  Only one commenter fit this description.

All of the commenters explicitly or implicitly claimed that RGGI has been a success.  Most of the commenters managed to request that future emissions reductions be “equitable” and that investments from auction proceeds consider disadvantaged communities.  Phelps Turner from the Conservation Law Foundation went so far as to suggest that 70% of the proceeds should be invested in disadvantaged communities.

Some commenters only addressed a single issue.  Paul R. from a land trust in Rhode Island argued that RGGI funds should be allocated to organizations like his so that they can set-aside land for carbon sequestration.  Laura H. from the Partnership for Policy Integrity wants the exclusion for biomass rescinded because the emissions from other pollutants than CO2 are high from these sources.  Kai S from the Green Energy Consumers Alliance wants revisions to the voluntary renewable energy credit market.  Nate B. from the Southern Environmental Law Center argued that vertically integrated utilities should be treated differently than non-regulated generating companies in the auction process.

Six of the commenters said that the emission caps should be tightened to reduce zero emissions by a date certain.  For example, Drew Stilson, from the Environmental Defense Fund said that the RGGI emissions cap should be updated to be in line with “what the science says is necessary to avoid the worst impacts of climate change”.  He said that emissions from the electricity sector must be reduced by  “at least 80% by 2030” because it is critical in “achieving the Biden Administration’s commitment to a 50% reduction across the economy by 2030”.  My impression is that most believe that RGGI state CO2 emissions should be zero by 2035.

Zero Emissions Trajectory

None of the commenters who advocated for a zero emissions cap by 2035 to satisfy a political target without any regulatory authority have any responsibilities for keeping the lights on. Easy for them to say and no personal consequences if their aspirational goals fail.  It appears that the emotional need to meet this target because their selected science says it is necessary over rides the common-sense question whether such a target is feasible. 

This section looks at an example zero-emissions cap by 2035.  Based on the third program review timeline I don’t think a revised cap could be implemented before 2024 which is appropriate because that is the start of a new compliance period. 

In my previous analysis I argued that continued fuel switching could produce zero-emissions from the more carbon intensive sources by 2030 so I calculated a linear reduction to zero out those emissions by 2030 from all but natural gas and “other fuel” sources.  For the zero emissions trajectory for the remaining sources by 2035, I calculated a similar trajectory of reduced heat input from those fuels and estimated an emissions trajectory to zero by 2035.  If RGGI were to make its emissions caps consistent with those trajectories then the total allocations from 2024 to 2035 cap would have to equal the cumulative emissions in the fuel source type trajectories over that period minus the allowance bank at the end of 2023. A revised cap that reduces the allowance bank and the allowance allocations is shown in the revised cap column of Table 1, Eleven-State RGGI Projected Emissions and Allowance Margin for Zero-Emissions By 2035 Scenario.  

Feasibility of Zero-Emissions by 2035

In order to eliminate natural gas-powered generation, a total of 118,815,096 MMBtu of replacement energy must be found to displace its use every year between 2024 and 2035.  Using the average of the last three years of EPA Clean Air Markets Division ratio data between heat input (MMBtu) and gross load (MWh) the natural gas displacement heat input is equivalent to 15,000,000 MWh.  The average of the last three years energy output at the now retired Indian Point unit 3 was 8,594,967 or 57% of the displaced natural gas energy output.  In 2020 New York had 1,985 MW of installed onshore wind energy that had a capacity factor of 25.2% and at that rate 6,780 MW (3.4 times) additional wind capacity would be needed to match the natural gas output.  For new onshore wind with a capacity factor of 35% 4,881 MW per year of new generation would have to be built.  Offshore wind with a capacity factor of 50% would only need to develop 3,417 MW but 8,543 MW of solar with a capacity factor of 20% would need 8,543 MW developed. 

In addition, the generation from natural gas and nuclear is dispatchable so comparing the energy output between them is apples to apples.  However, because wind or solar is not dispatchable a direct energy comparison is not appropriate which means that additional resource development and energy storage would also have to be included.  A recent presentation by the New York State Reliability Council described how the New York electric system is operated to maintain reliability and some of the challenges presented when renewable energy sources are increased significantly.  In my article on the presentation, I noted that the New York reserve margin will have to increase to over 100% relative to the current reserve margin of about 20%.  In other words, in order to ensure that current reliability standards are maintained the amounts listed in the previous paragraph would have to be doubled.

Conclusion

In my initial comments to RGGI on the third program review I made the point that the most important planning consideration to keep in mind is that CO2 control is different than sulfur dioxide, nitrogen oxides and particulate matter because there are no cost-effective retrofit controls available for existing facilities.  The data show that fuel switching has been the primary reason for the observed emission reductions in the RGGI states.  Once the facility has changed to a lower emitting fuel the only options at a power plant are to become more efficient and burn less fuel or stop operating all together.  While it is easy for the commenters to say that would be a good thing the reality is that the real impacts of a blackout caused by unavailable generating resources would be much greater than the alleged impacts of global warming.  I concluded that if it ever comes to the point that allowances are unavailable to operate that could threaten reliability, so it is imperative that RGGI never tighten the cap so low that affected sources are unable to operate due to unavailable allowances. 

With respect to the comments demanding that a zero-emissions trajectory by a certain date it is clear that they are ignoring the performance of RGGI to date.  In my initial comments I showed that the RGGI investments to date are only directly responsible for less than 5% of the total observed reductions since RGGI began in 2009.  Also note that the cumulative annual RGGI investments are $2,795,539,789 and that means that the cost per ton reduced is $857.74.    If the RGGI states have to rely on RGGI investments to make the annual 7,143,044 ton reduction needed, that cost per ton rate would mean an annual cost of $6.1 billion.

As the RGGI states embark on another program review process I hope that they will ignore the calls for emission caps consistent with an aspirational emissions reductions target.  It is also important that they consider the actual results of the program to date.  The fact is that any emissions trading approach for CO2 has to acknowledge that there are limited options for cost-effective reductions and that most of the observed RGGI state reductions have not been due to the RGGI program.  Because of the limited options available and relative ineffectiveness of RGGI investments it is absurd to establish the future emissions caps based on zero emissions by 2035.  That could only lead to reliability issues when affected sources run out of allowances to operate but are still needed to run to keep the lights on.

Reliability Goal of a Renewable-Dependent Electricity System

In early September 2021 I wrote an article, “Reliability Challenges in Meeting New York’s Climate Act Requirements”, that described a presentation made by the New York State Reliability Council (NYSRC) to the New York Climate Action Council.  In this post I describe a recent paper that analyzes synoptic-scale extreme reductions in wind and solar power energy resources that I think raises an important reliability question: when New York relies on fragile intermittent wind and solar energy resources is the current New York reliability goal to prevent a loss of load event due to resource adequacy of no more than once per ten years still appropriate.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

In my reliability challenge article, I explained that there is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low.  Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous.  Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be increase substantially above current levels to satisfy anticipated load and the intermittent nature of wind and solar resources.  The NYSRC presentation concludes that the state of New York appears to be headed down a transition path which will require reliance on technologies that do not currently exist in less than ten years.

Wind and Solar Droughts

Dr. Patrick Brown’s blog post describes his recent paper co-authored with David J. Farnham and Ken Caldeira entitled “Meteorology and climatology of historical weekly wind and solar power resource droughts over western North America in ERA5” (Brown et al., 2021).  His post explains that as wind and solar become more indispensable for providing electricity it is important that we understand the intensity, frequency, and duration of droughts of their availability.  In Brown et al., 2021 they use a meteorological database that covers 71 years from 1950 to 2020.  They compared estimated weekly solar and wind availability against cooling and heating degree days as a proxy for electrical load over that entire period. 

The following plot of the weekly values is of special interest.  The plot explanation states:

All weekly values from 1950 to 2020 (average over the western North America domain, Fig. 1) for power supplied by wind and solar resources (x and y axes respectively) and a proxy for power demanded via cooling degree days (color of dots). The mean seasonal cycle in wind and solar power is shown by the black loop (52 black dots for each week of the year). Drought weeks are indicated with black edge colors with wind droughts represented as circles, solar droughts represented as squares and compound wind and solar droughts represented as diamonds.

Of particular concern is the lower left quadrant which represents weeks where both wind and solar resources are lower than the annual mean of long-term availability.  Note that this quadrant is “mostly astronomical autumn. The mean wind & solar power given a wind + solar drought label shows that during a drought you can only expect around 40% of the solar resource and 65% of the wind resource.

There is an animation showing the degree to which there is persistence in time.  In the video each week is sequentially plotted since 1979 over a plot of the seasonal cycle.  As you watch the video keep in mind that you are watching the seasonal progression of plots.  While the majority of weeks with both wind and solar droughts are in autumn there are periods at the start of each year that appear to me to be among the most intense.  That is consistent with New York analyses that define the ultimate problem

that must be resolved to ensure reliability: firm capacity is needed to meet a multi-day period of low solar and wind resource availability during the winter. 

In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included a slide titled Electricity Supply – Firm Capacity that states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits.  Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.

Brown et al., 2021 is a promising approach for evaluating the long-term frequency of wind and solar droughts.  However, there are some limitations.  Obviously, the work has to be done for a New York centric domain.  In addition, because previous New York analyses by Energy + Environmental Economics  and The Analysis Group both identified problems on a multi-day basis it would be more appropriate to evaluate New York’s droughts on a daily basis. I strongly recommend that New York sponsor this analysis to determine the frequency and duration of renewable resource droughts. 

Because wind and solar are naturally intermittent the amount of energy storage needed to balance output must be determined.  The Brown et al., 2021 technique can also be used to identify periods that should be evaluated in more detail to determine the intensity of the droughts so that energy storage requirements can be determined.  This is important not only for grid planning but also for distributed energy resources (DER).  In theory DER can “generate smaller amounts of clean electricity closer to end-users, to increase energy efficiency, reduce carbon pollution, improve grid resiliency, and potentially curtail the need for costly transmission investments”.  However, unless they incorporate sufficient energy storage these resources won’t work when the system is stressed the most, so they may not be the panacea that advocates claim.

Reliability Planning

New York’s electric system is de-regulated so reliability planning is provided by the New York Independent System Operator, various state agencies and the NYSRC.  The NYSRC presentation describes the NYSRC and the Installed Reserve Margin (IRM) parameter.  The IRM is defined as the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   Load shedding occurs when the demand for electricity exceeds supply and grid operators have to turn power off for groups of customers in order to prevent the whole system from collapsing. 

To this point, reliability planning has been primarily focused on an electric system powered by conventional dispatchable generating resources. In that context resource obtainability is not particularly concerned with long-term availability of the resource because the resources are not intermittent.  That changes when the system becomes dependent upon wind and solar because there are short-term and long-term availability concerns.  It is in this context that the results from Brown et al., 2021 climatology becomes important and raises the question whether planning based on a ten-year metric is still appropriate in the future.  Using this approach, we can determine the frequency and duration of the expected worst case over ten years consistent with current IRM planning.  However, because we can consider a longer period, we can also consider the frequency and duration of droughts over the whole 70 years and get expected worst cases over other time periods.  If there is a marked difference over say the 30-year time period, it may be appropriate to expand the IRM planning period in order to prevent the probability of shedding load due to more severe drought.

Black Swan Events

To this point in this article, I have only addressed normal weather variability effects. During the preparation of this post, I came to believe that there is another reliability concern related to renewable resource adequacy that has to be addressed.  What happens to the electric system when unprecedented extreme weather cripples the relatively fragile renewable generating and transmission system?  These statistical outliers are described as a “black swan event”.

A Black Swan event is an event in human history that was unprecedented and unexpected at the point in time it occurred. However, after evaluating the surrounding context, domain experts (and in some cases even laymen) can usually conclude: “it was bound to happen”. Even though some parameters may differ (such as the event’s time, location, or specific type), it is likely that similar incidences have had similar effects in the past.

In this context the conclusion that “it was bound to happen” has to be discussed.  At an Our Energy Policy (OEP) panel discussion on New York State’s emerging offshore wind market, someone asked an off-shore wind industry expert whether wind turbines in New York would be able to withstand a Category 5 storm.  Clint Plummer the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded: “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said.

In the October 1, 2021 Climate Action Council meeting presentation Carl Mas described the initial results of the integration analysis that will be used to develop the plan to implement changes to New York’s energy system to meet the CLCPA targets.  Four scenarios have been developed with different renewable resource, load reduction and sequestration strategies.  The new findings indicate that 20 GW of offshore wind resources will be necessary.  Assuming that New York builds the latest generation offshore wind turbine, e.g. the GE Haliade-X 12 MW turbine, that equates to over 1,600 turbines with 220 m or 722 foot rotors. 

However, hurricanes likely exceeding the threshold described by Ørsted expert Plummer have occurred in the area New York plans to build its offshore wind facilities.  In 1635 the “Great Colonial” Hurricane hit New York and New England and the “Great Storm of 1693” devastated Long Island. There were other hurricanes that made landfall in the Tri-State area – 1788 (left the Battery in ruins), 1821, 1893 (the second hurricane that year, different from the one that hit Halifax, Nova Scotia), 1944 (“Great Atlantic” hurricane), 1954 (Carol), and 1991 (Bob). The 1938 “Long Island Express” made landfall in Long Island as a Category 3 hurricane with sustained winds of 125 mph and wind gusts up to 150 mph bringing waves surging to 35 feet.  Given that part of the rationale for the CLCPA is that extreme weather events such as hurricanes are becoming more frequent and severe there should be no question that a contingency plan is necessary for the time that a hurricane inevitably affects, if not destroys, the New York offshore wind resource.  Moreover, should that not be a part of the reliability planning process?

Unfortunately, that is not the only extreme weather event that can have extreme consequences on a more fragile wind and solar electricity network.  I am particularly worried about ice storms.  On a local level it is not clear how the public will be able to survive a multi-day power outage caused by an ice storm when the CLCPA mandates electric heat and electric vehicles but the bigger reliability concern is that fact that ice storms can take out transmission lines.  For example, consider, the January 1998 North American ice storm:

The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern QuebecNew Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months. It led to 34 fatalities, a shutdown of activities in large cities like Montreal and Ottawa, and an unprecedented effort in reconstruction of the power grid. The ice storm led to the largest deployment of Canadian military personnel since the Korean War, with over 16,000 Canadian Forces personnel deployed, 12,000 in Quebec and 4,000 in Ontario at the height of the crisis.

New York Governor Kathy Hochul recently announced “two major green energy infrastructure projects to power New York City with wind, solar and hydropower projects from upstate New York and Canada”.  The press release claims that the combined project will deliver 18 million megawatt-hours of upstate and Canadian renewable energy per year.  Clean Power New York plans on over 20 wind and solar generation projects – all located in New York State – and a new 174-mile, underground transmission line. Champlain Hudson Power Express is a 338-mile underground power line from Quebec hydroelectric facilities to New York City.  The problem is that not all the associated infrastructure in these projects is underground and immune from ice storms.

Photo from 1TAC Survival Blog

Conclusion

The requirements for New York reliability planning will have to change for a future grid that relies on intermittent and diffuse wind and solar.  Current planning for the electric system is based on decades-long experience with a system powered primarily by sources that are dispatchable and includes sources that have on-site storage.  The potential for lack of source availability over days, weeks, and even months is not a serious concern today because the New York system has been diverse, redundant, and resilient to the vagaries of weather.

The CLCPA requirement for a zero-emissions electric system that relies on wind and solar energy resources changes the reliability planning requirements.  Previous analysis has highlighted the need to address multi-day wind lulls in the winter as a particular problem.  Brown et al., 2021 have developed a technique that can be used to determine the climatological frequency and duration of those periods of low wind and solar resource availability that clearly should be included in New York reliability planning.  Their analysis technique can also be used to identify the worst-case periods of wind and solar droughts so that more detailed resource availability analyses can estimate how much energy storage is needed not only for the electric grid but also the distributed energy resources proposed for the CLCPA.  This analysis is needed to prevent the kind of Texas February 2021 disaster from happening in New York.

The existing New York system has evolved over years of trial-and-error experience to the point where it is relatively resilient to extreme weather events.  While there have been exceptions, the possibility of widespread, weeks-long outages is extremely low.  However, because wind and solar resources are more fragile to wind and ice crippling damage than existing generating sources, the likelihood of the conditions that cause that level of damage should be determined.  Brown et al., 2021 can determine the occurrence of events over a 71-year period.  If, for example, their analysis suggests that the return period of a crippling event is one in thirty years, then should New York reliability planning incorporate a longer time horizon for its planning?

At this time, the off-shore wind strategy calls for 20 GW of development.  The ramifications of a Category 4 or greater hurricane destroying or significantly damaging those facilities should be at least be considered.  Repairing them will take months if not years and the ramifications if insufficient resources are available are immense. If nothing else the statements claiming that the future wind and solar dependent electric system will be more resilient should be toned down.

RGGI Third Program Review

The Regional Greenhouse Gas Initiative (RGGI) is a carbon dioxide control program in the Northeastern United States.  One aspect of the program is a program review that is a “comprehensive, periodic review of their CO2 budget trading programs, to consider successes, impacts, and design elements”.  This post describes my comments at the start of the third program review public participation process.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. 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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions. It is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont, and Virginia to cap and reduce CO2 emissions from the power sector.  According to a RGGI website:

“The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.” 

Proponents tout RGGI as a successful program because participating states have “cut carbon pollution from their power plants by more than half, improved public health by cutting dangerous air pollutants like soot and smog, invested more than $3 billion into their energy economies, and created tens of thousands of new job-years”.  Others have pointed out that RGGI was not the driving factor for the observed emission reductions.  My work supports that conclusion and points out that the cost-effectiveness of the investments from this carbon tax reduce CO2 emissions at a cost of $858 per ton which is far greater than the social cost of carbon metric.  In other words, this is not a cost-effective way to reduce CO2 emissions.

Third Program Review

According to the program review link on the RGGI website:

The RGGI states completed the First Program Review in February 2013 and completed the Second Program Review in December 2017, resulting in the 2017 Model Rule. Now the states have initiated the Third Program Review to consider further updates to their programs.

On February 2, 2021, the RGGI states released a statement announcing the plan for the Third Program Review, and in Summer 2021 the states released a preliminary timeline for conducting the Third Program Review. Note that this timeline is subject to change and may be revised over time.

To support the Third Program Review, the states will:

      • Conduct technical analyses, including electricity sector modeling, to inform decision-making related to core Program Review topics, such as the regional CO2emission cap.
      • Solicit input from communities, affected groups, and the general public on the Program Review process and timeline, core topics and objectives, modeling assumptions and results, and other policy and design considerations.
      • Convene independent learning sessions with experts and other interested parties on key design elements.

Public participation is a key component of a successful Program Review. The RGGI states will conduct public engagement throughout Program Review, including periodic public meetings and accompanying open comment periods, to share updates and solicit public feedback.

RGGI has released a list of issues to be considered in its Topics for Public Discussion.  The RGGI states are seeking comments on the future size and reduction trajectory of the allowance caps and the allowance bank.  Comporting with the current fad they are also considering environmental justice and equity considerations.  The RGGI program includes auction mechanisms and they have asked for comments on them.  They also asked for comments on the compliance mechanism and the offset program.

In brief, my comments recommend making no changes.  In the next few years, the RGGI allowance market will change to the unprecedented emissions trading situation in which the majority of the RGGI allowances are held by entities who purchased allowances for investment rather than compliance purposes.  No one knows how the market will react and the compliance mechanisms are working well as is so there is no need to change anything at this time.  The purpose of this post is to describe why I believe changes to the allowance cap and reduction trajectory are unnecessary.

I have prepared a simple analysis that projects the margin between allowances available and emissions (Table 1) for a first cut estimate of the RGGI allowance market and compliance requirements.  I downloaded CO2 mass, heat input, and primary fuel use data from the EPA Clean Air Markets Division database from 2009 to 2020 for Acid Rain Program units rather than RGGI program units so that I could include data from New Jersey and Virginia. 

While Table 1 lists totals for five categories of fuel use: natural gas, coal, residual oil, diesel oil, and other fuels, it is instructive to look at a breakdown of the fuels over time.  Table 2 lists the CO2 mass, heat input and calculated CO2 rate (lbs/hr) by fuel category for the combined nine states that have been in RGGI since 2009, New Jersey and Virginia.  The final row lists the percentage change between the first three years of RGGI and the latest three years.  In nine-state RGGI CO2 mass is down 39%, heat input is down 28% and the CO2 rate is down 16%.  However, the fact that the CO2 rates for New Jersey and Virginia are down more than the RGGI states indicates that the economics of fuel switching to natural gas is the primary reason that CO2 emissions have decreased as observed in the RGGI region. 

Table 1 lists the allowance cap and adjusted cap from 2009 to 2030 in the first three data columns.  The observed CO2 mass and heat input totals for the five fuel categories are in the last columns.  Starting in 2021, the estimated total allowances available expected at the end of each year are listed.  The 2021 value is based on the latest Potomac Economics  report on the secondary market report.  From a compliance standpoint the key parameter is the margin between the allowances available and the emissions.  For each year subsequent to 2021 the allowances available equals the previous year allowances minus that year’s emissions plus the allowances from the adjusted cap through 2025 and unadjusted cap through 2030.

Based on the observation that fuel switching is the primary CO2 reduction methodology to date, the emission projection in the table forces coal, residual oil and diesel oil to go to zero by 2030.  The projected emissions are summed and the margin (difference between allowances available and emissions) is calculated.  Using these assumptions, the allowance bank and the margin continue to decrease suggesting that there will be no major upheavals in compliance strategies or allowance prices.  Of course, projecting future emissions is fraught with difficulties and uncertainties but this approach is probably conservative and actual reductions will likely be greater. 

It is also appropriate to review the emission reduction results of RGGI relative the Social Cost of Carbon (SCC) cost-effectiveness parameter.  I believe that the only reductions from RGGI that can be traced to the program are the reductions that result from direct investments of the RGGI auction proceeds. Information necessary to evaluate the performance of the RGGI investments is provided in the RGGI annual Investments of Proceeds updates.  In order to determine reduction efficiency, I had to sum the values in the previous reports because the reports only report lifetime benefits.  In order to account for future emission reductions against historical levels and to compare values with the SCC parameter, the annual reduction parameter must be used.  Table 3, Accumulated Annual RGGI Benefits, lists the sum of the annual avoided CO2 emissions generated by the RGGI investments from previous reports.  The total of the annual reductions is 2,259,203 tons while the difference between the baseline of 2006 to 2008 compared to 2019 emissions is 72,908,206 tons.  Therefore, the RGGI investments are only directly responsible for less than 5% of the total observed reductions since RGGI began in 2009.  Also note that the cumulative annual RGGI investments are $2,795,539,789 and that means that the cost per ton reduced is $857.74.

Based on comments in previous program reviews there will undoubtedly be calls to make the allowance cap “binding” that is to say force emission reductions to meet a particular emission reduction trajectory.  While the projections above do not reduce emissions as much as the arbitrary 3% reduction target from the previous program review, there are potential consequences if a more stringent reduction is mandated. 

The most important consideration to keep in mind is that CO2 control is different than sulfur dioxide, nitrogen oxides and particulate matter because there are no cost-effective controls available for existing facilities.  As the data show, fuel switching is the primary reason for the observed emission reductions but once the facility has changed to a lower emitting fuel the only options at a power plant is to become more efficient and burn less fuel or stop operating all together.  Fuel costs are a major factor affecting the price of generation so keeping that price as low as possible to improve competitiveness has always been a priority objective.  Consequently, it is unlikely that this could be a source of many future reductions. If it ever comes to the point that allowances are unavailable to operate that could threaten reliability, so it is imperative that RGGI never tighten the cap so low that affected sources are unable to operate due to unavailable allowances.

Theory suggests that as the market gets tighter that the allowance price will rise.  If the allowance price exceeds the Cost Containment Reserve trigger price, then allowances equal to 10% of the cap will be released to the market.  Because that is greater than the 3% reduction target, that suggests that discouraging a tight market supports greater emission reductions.

Conclusion

As the RGGI states embark on another program review process I hope that they will consider the actual results of the program to date.  RGGI has demonstrated that a cap-and-auction emissions trading program can be set up and work well.  However, the fact is that any emissions trading approach for CO2 has to acknowledge that there are limited options for cost-effective reductions.  I believe that political considerations have diluted the effectiveness of RGGI investments for emission reductions so that the investments are not cost effective relative to the social cost of carbon value of reductions. 

I believe that the goal of RGGI should be to balance the allowance cap with observed emissions so that the allowance bank is only used for year-to-year variations in weather-related excess emissions.  Over time as RGGI investments fund zero-emission energy sources it may become necessary to adjust the emission reduction trajectory but that should be based on observations and not model projections.  If this recommended approach is chosen then the RGGI program can continue to operate without threatening reliability and continue to produce revenues for the RGGI states.

New York City’s Plan to Combat Extreme Weather

This post was published at Watts Up With That on September 30, 2021

On September 27, 2021 New York City Mayor Bill de Blasio releasedThe New Normal: Combatting Storm-Related Extreme Weather in New York City,” billed as a “landmark report that provides New York City with a new blueprint to prepare for and respond to extreme weather”. I wholeheartedly support many of the initiatives proposed in the document but I disagree with the report’s arguments suggesting that absent climate change, initiatives to increase resiliency would not be appropriate.  Furthermore, given the enormous sums of money needed to address these issues I question whether it is appropriate to continue to spend any money on emissions reductions to ameliorate the alleged effects of climate change.

The report starts off claiming the devastation associated with the remnants of Hurricane Ida on September 1, 2021 was unprecedented: “it was a frightening lesson in our new reality: one in which even so-called “remnants” of storms, traveling from thousands of miles away, can be as ferocious and dangerous as those aimed directly at our city”.  The report goes on to say: “Increasingly, these extreme weather events are the new normal: part of an undeniable climate crisis that stretches across our entire nation, from droughts in the Southwest to raging wildfires on the West Coast. Climate change isn’t a far-off threat. It is here, it is real, and it is taking lives.”

New York governments have been claiming that most every recent extreme weather event is evidence of climate change for quite a while.  For example, before the most recent Climate Act implementation meeting I wrote a post predicting that Hurricane Ida impacts would be highlighted at the meeting and, surprising no one, that is exactly what happened at the meeting.  I have documented other instances where New Yorkers have confused climate change impacts with weather events here.

In my prediction post I noted that on August 22, 2021 tropical depression Henri made landfall in Rhode Island.  Although it had weakened from a hurricane and skirted New York, it dumped heavy rains from New Jersey to New England.   The region had a wet summer so the ground was already saturated.  As a result, the main impact was flooding.  Hurricane Ida struck the Louisiana coast on August 29, 2021.  I followed the forecasts of the remnants of Ida as it slogged north and the east out to sea in the New York City area.  Every forecaster was warning that heavy rains were likely in the New York City area and coupled with already saturated grounds that flooding was likely. 

Cliff Mass described the weather as it hit the area and noted that New York’s Central Park had a record of 3.15 inches in an hour.  He explained that hurricane remnants, known as extratropical cyclones, combine strong upward motions with large amounts of tropical moisture.  This combination causes heavy rains and flooding.  Moreover, Paul Homewood evaluated climate data and showed that that worse precipitation has been observed in the past

Sadly, there were big impacts associated with the storm.  The New York City report states that “For the first time in history, the National Weather Service (NWS) declared a flash flood emergency in New York City. The storm shattered the record for the most single-hour rainfall in our city, set only two weeks earlier by another extreme storm, Hurricane Henri. It flooded streets, subways, and homes. Most tragically, Ida took the lives of 13 New Yorkers.”

Dr. Cliff Mass defines the Golden Rule of Climate Extremes as: The more extreme a climate or weather record is, the greater the contribution of natural variability.  For example, he did an extensive analysis of this summer’s great Northwest heat wave and found that “ global warming only contributed a small about (1-2F) of the 30-40F heatwave and that proposed global warming amplification mechanisms (e.g., droughts, enhanced ridging/high pressure) cannot explain the severe heat event.”  Although he did not do a similar analysis of the New York City flooding, the analyses described above suggest a similar conclusion here.  Note, however, his description of the weather event made the point that we could and should improve forecasting and communications for this type of event because the deaths were preventable.

In this regard, the New York City report is encouraging.  The press release explains that the following new strategies are outlined in the report:

  • Educate, train, and acclimate New Yorkers to this new reality
  • Increase planning for the worst-case scenario in every instance
  • Accelerate upgrades to storm modeling, tracking, and alert systems
  • Broaden protection for inland communities, not only our coastlines
  • Protect basement and cellar occupants
  • Prioritize investments in low-income neighborhoods, immigrant communities, and communities of color
  • Re-imagine our sewage and drainage system, and rapidly increase green infrastructure and cloudburst solutions
  • Call on support from the state and federal government in further depending our reach

I will look at these strategies in more detail below.

Educating New Yorkers to be more weatherwise is a necessary first step in the public warning process.  In my opinion, many city folks are so insulated from the real world, including the weather, that they don’t bother to follow weather forecasts.  For the most part, that only creates inconveniences.  However, there are extreme weather events that can affect safety and they have to be aware of the consequences.  Given the importance of this requirement I will not quibble that those events have always happened and, even if the magical solutions to mitigate climate change are enacted, severe weather events will continue happen.

The planning for worst-case scenarios basically consists of setting up a “new senior position at City Hall, the Extreme Weather Coordinator”.  Hopefully they will work closely with the National Weather Service experts in the area of severe weather communications.  If the warnings are not credible then they will be ignored.

I am sure Dr. Mass would endorse the plan to “build state-of-the-art storm modeling, a new tiered alert system tailored to at-risk areas, and a modern tracking system that will monitor dangerous weather throughout the tri-state area and beyond”.   I agree that this is necessary and would be the first to support diverting some of the money poured into climate change research into a better warning system for weather events associated with the “new normal”.  This certainly is a “no regrets” option.

Three of the strategies are related.  Inland communities and basement occupants are threatened mostly because the sewage and drainage system is inadequate.  The report notes that “Completely recalibrating our sewers for storms like Ida would require a decades-long, potentially $100-billion investment dependent on federal funding”. However, it would reduce the severity of inland flooding, help prevent basement flooding, and reduce the health impacts associated with sewage overflows.

It seems that all environmental infrastructure projects proposed today have to include environmental justice commitments.  I doubt that anyone would object to requirements that mandate equitable investments.  However, given the amount of money needed to address all the resiliency problems it would be inappropriate to try to over-compensate low-income neighborhoods for past injustices.

Clearly it is beyond the capability of the city to fund everything that could be done.  Not surprisingly, the final strategy is to get more money from “our partners at the State and Federal level”.   In my opinion New York City is missing the obvious solution.

Even if greenhouse gas emissions affect global warming as alleged, there are problems with New York City’s support of greenhouse gas emission reduction mitigation projects.  In the first place, New York emissions reductions cannot possibly measurably affect global warming.  Paul Knappenberger’s Analysis of US and State-By-State Carbon Dioxide Emissions and Potential “Savings” In Future Global Temperature and Global Sea Level Rise used the Model for the Assessment of Greenhouse-gas Induced Climate Change which projects changes based in expected global warming based on admittedly old Intergovernmental Panel on Climate Change estimates.  I simply pro-rated his estimates of United States impacts by the ratio of New York greenhouse gas emissions divided by United States emissions to determine the effects of a complete cessation of all New York State’s emissions.  I found that there would be a reduction, or a “savings,” of between 0.0097°C and 0.0081°C by the year 2100.  To give you an idea of how small these temperature changes are consider changes with elevation and latitude.  Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000-foot increase in elevation above sea level.  The projected temperature difference for all the greenhouse gases is the same as a 39-inch change.  The general rule is that temperature changes three (3) degrees Fahrenheit for every 300-mile change in latitude at sea level.  The projected temperature change is the same as a change in latitude of less than a mile. Given these small changes I believe that there could not possibly be an effect on extreme weather events from New York emission reductions.

In addition, New York’s potential emission reductions should be considered relative to the rest of the world.  According to the China Electricity Council, about 29.9 gigawatts of new coal power capacity was added in 2019 and a further 46 GW of coal-fired power plants are under construction.  If you assume that the new coal plants are super-critical units with an efficiency of 44% and have a capacity factor of 80%, eliminating all New York’s greenhouse gas emissions will be replaced by the added 2019 Chinese capacity in less than two years.

I think that the New York City New Normal report outlines useful strategies to address the problems of extreme weather.  I disagree that there is any “new” normal but the fact is that extreme weather always has happened and will always happen whatever mankind tries to do, makes planning a system to address these events a no regrets solution.  The biggest impediment to implementation is the enormous funding needed and I believe it is obvious that taking the money presently being thrown away on greenhouse gas emission reduction projects would be better served funding these strategies.  New York emissions cannot possibly be reduced enough to affect global warming and the alleged new normals of extreme weather even if there is a link between the two.  Given that it is a moral imperative that everyone should have access to abundant, reliable energy that can only be provided affordably with fossil fuels means that emission increases elsewhere are going to be greater than any possible New York emission reductions.  Finally, New York’s emphasis on wind and solar zero emissions resources for future emission reductions depends on technology that does not exist.  As a result, catastrophic blackouts with impacts equivalent to the extreme weather events are likely as a result of the mitigation efforts of New York.  It would be logical and safer to use emission reduction funds for the proposed strategies.

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Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

The Climate Leadership & Community Protection Act’s Fundamental Flaw

The authors of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council biased implementation of the law to vilify methane and nitrous oxides because they have the potential to warm the atmosphere more than an equivalent amount of  carbon dioxide.  This post explains why that rationale is incorrect and makes the CLCPA fundamentally flawed.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Last year I published an article, Climate Leadership and Community Protection Act Methane Obsession that described how the irrational New York obsession against natural gas has resulted in a requirement in the CLCPA to develop an emissions inventory using a 20-year time horizon because methane has a greater potential to increase global warming.  As a result of this requirement and another mandate to include upstream emissions too, the baseline 1990 greenhouse gas emissions inventory nearly doubled.  I pointed out in that article that as a result of this approach, the implementation will have to focus on immediately reducing natural gas use despite its many advantages and crucial support to energy supplies.

My previous article noted that the methane obsession in the CLCPA law and its implementation strongly relies on the research of Professor Robert Howarth of Cornell University.  According to the Cornell Chronicle Howarth played a “key role” in drafting the law and now as a member of the Climate Action Council will “identify and make recommendations on regulatory measures and other state actions that will ensure the attainment of the statewide greenhouse gas emissions limits”.  Howarth is the David R. Atkinson Professor of Ecology and Environmental Biology at Cornell and his biography notes “My training was in oceanography, and much of my research still focuses on coastal marine ecosystems”.  Cornell Alumnus David Atkinson provided funds to establish and make permanent Cornell’s Center for Sustainability because he “realized that climate change is probably the biggest issue facing humanity”.  A recent paper of Howarth’s on methane emissions inventories was funded by the Park Foundation that has a long history of anti-natural gas fracking activism.  I make these points because it is clear that his funding sources support certain outcomes so supporting research is at the very least encouraged.  Moreover, nothing in his background suggests expertise in atmospheric radiation related to a thorough understanding of nuances associated with global warming theory.  If a dentist receiving money from the tobacco industry were to publish research that said smoking has health benefits, then his motives would be questioned and his claims scrutinized in great detail.  Despite an analogous background and other research contradicting his analyses Howarth’s research is unquestioned in the implementation process.

As mentioned previously, one of the mandates specified in the CLCPA is that the global warming potential (GWP) had to be calculated over a 20-year time horizon.  The Inter-governmental Panel on Climate Change describing time horizons and the GWP notes:

“The GWP has become the default metric for transferring emissions of different gases to a common scale; often called ‘CO2 equivalent emis­sions’ (e.g., Shine, 2009). It has usually been integrated over 20, 100 or 500 years consistent with Houghton et al. (1990). Note, however that Houghton et al. presented these time horizons as ‘candidates for discussion [that] should not be considered as having any special sig­nificance’. The GWP for a time horizon of 100 years was later adopted as a metric to implement the multi-gas approach embedded in the United Nations Framework Convention on Climate Change (UNFCCC) and made operational in the 1997 Kyoto Protocol. The choice of time horizon has a strong effect on the GWP values — and thus also on the calculated contributions of CO2 equivalent emissions by component, sector or nation. There is no scientific argument for selecting 100 years compared with other choices (Fuglestvedt et al., 2003; Shine, 2009). The choice of time horizon is a value judgement because it depends on the relative weight assigned to effects at different times.”

Reference: Myhre, G., D. Shindell, F.-M. Bréon, W. Collins, J. Fuglestvedt, J. Huang, D. Koch, J.-F. Lamarque, D. Lee, B. Mendoza, T. Nakajima, A. Robock, G. Stephens, T. Takemura and H. Zhang, 2013: Anthropogenic and Natural Radiative Forc­ing. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.


Howarth and others argued that it was necessary for the CLCPA to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 GWP over a 20-year period.  Because of these high potentials they assumed that meant that the effect of methane on expected warming would be significant.

Earth’s Thermal Radiation

I was prompted to write this post because of Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases”.  In my previous post on New York’s methane obsession, I noted that a report entitled “Methane and Climate” by the same two authors had concluded that “Proposals to place harsh restrictions on methane emissions because of warming fears are not justified by facts.”  However, Andy May’s analysis describes the greenhouse effect and the potential impact of methane so well that it also needs to be considered in the context of the CLCPA. The greenhouse effect is the basic rationale for the alleged existential threat of climate change because additional anthropogenic greenhouse gases, in the absence of any other processes, must warm the atmosphere.  Although this is a non-controversial scientific fact, the reality is that there are so many processes, conditions, caveats, and unknowns that it is impossible to precisely estimate how much warming can be expected with added greenhouse gas emissions.  May explains the basics and some of the complexities in his recent article and references his previous article on the greenhouse effect for even more discussion of the fundamental effect.

Thermodynamics in general and atmospheric thermodynamics have always given me a headache and I agree with May’s argument that no one really understands all the component complexities of it.  Fortunately, Wijngaarden and Happer (W&H) have evaluated the likely influence of greenhouse gases (CO2, H2O, CH4, N2O, and O3. using the HITRAN line-by-line molecular transmission and absorption database maintained at Harvard University to give us a better understanding of the atmospheric processes and effects of these gases. May writes:

HITRAN stands for high-resolution transmission molecular absorption. The database compiles spectroscopic parameters that computer programmers can use to model the transmission and emission of light in the atmosphere. W&H use the database to model a hypothetical mid-latitude temperature and GHG atmospheric profile to derive a representative climate sensitivity to doubling the gases. 

In layman’s terms this analysis considers the distribution and characteristics of greenhouse gases in the atmosphere to determine how much the climate could warm due to this process in isolation.

Verbatim Andy May Summary and Conclusions  (the following section is directly quoted)

“In summary, W&H have provided us with a detailed and accurate emissions model that shows only modest warming (2.2 to 2.3°C), inclusive of likely water vapor feedback, but not counting the feedback due to cloudiness changes. Both the magnitude and sign of net cloud feedback to surface warming are unknown. Lindzen has shown it is likely negative (cooling) in the tropics, but outside the tropics no one knows.”

“The water vapor feedback to surface warming is also very unclear, Ferenc Miskolczi (2014) has written:”

‘As long as the Earth has unlimited water supply (in the oceans) with its three phases permanently present in the atmosphere and two phases on the ground surface, the stability of the planetary climate will be controlled by the equations [see paper, page 19]. These two equations, together with the Clausius-Clapeyron equation, will regulate the transfer of the latent heat through the boundary layer in such a way that the net amount maintains the planetary radiative balance.’

“Miskolczi, and others have found that total water vapor in the atmosphere has gone down in the past 70 years, although this is questioned. The work by W&M on radiation emissions suggests that future warming due to GHGs will be modest. Speculation about the warming feedback due to clouds and changes in total water vapor is just that, speculation.”

“The results of the study are summarized in Table 2.”

Table 2. Modeled parameters for each GHG in the W&H study. The current flux at 11 km and 86 km for each GHG are shown, then the values if they are doubled, and removed from the atmosphere, and finally the percentage change in forcing (W/m2) if the current concentration is doubled. Only CO2, H2O and O3 change significantly when doubled.

“Table 2 shows that the main GHGs are CO2, H2O and O3, doubling the methane or N2O concentration changes the outgoing forcing by less than one percent. Due to the properties of water vapor, its atmospheric concentration is very unlikely to double, but if it did, it would only increase the forcing by eight percent at 11 km. Doubling CO2 only increases the forcing by four percent at 11 km.”

“The combined current 11 km and 86 km forcing values in the table are not the sum of the individual values due to overlap. It is very clear from this table that all GHGs are saturated and adding to the current concentrations will make very little difference. Doubling CO2 will cause the stratosphere to cool about 10°C, but the changes in surface temperatures from this model are all less than 2.3°C, as shown in Table 1. This is much less than the preferred IPCC AR6 value of 3°C (IPCC, 2021, pp. TS-57). Considering that the current net effect of clouds is cooling and it seems likely that total water vapor in the atmosphere is decreasing or staying flat, these results suggest we have little to worry about regarding increasing GHGs.”

CLCPA Implications

One of the bigger problems implementing the CLCPA is developing strategies to reduce methane (CH4 and nitrous oxide (N2O) especially because of the unprecedented focus on those pollutants.  While there aren’t as many sources of either one or as much emitted by either one relative to CO2, the capability to control them is difficult.  So difficult that the apparent strategy is to ban their use.  With respect to methane that means eventually banning the use of natural gas for home heating, cooking and hot water despite its inherent advantages.  Similarly, the largest source of nitrous oxides emissions is from nitrogen fertilizer so reducing those emissions has unintended consequences.

The reason that methane and nitrous oxides are included in the CLCPA and used to justify changing the emissions calculation methodology to emphasize their importance is that the global warming potential for both pollutants are much higher than the warming potential of carbon dioxide.  If it can warm more then it most be more important according to this rationale.  The CLCPA emissions inventory is calculated differently than just about every other jurisdiction for this reason.

The Wijngaarden and Happer paper destroys this rationale.  Ultimately the CLCPA rationale is to mitigate global warming by reducing the emissions that have the potential to enhance the greenhouse effect itself.  Two characteristics of greenhouse gases determine the effect: the global warming potential and the concentration of the gases in the atmosphere.  Because the atmospheric concentrations of methane and nitrous oxides are so small doubling concentrations change the “outgoing forcing by less than one percent”.  In other words, doubling emissions or cutting emissions in half of methane and nitrous oxides will have no measurable effect on global warming itself. 

The Climate Action Council claims to “follow the science” but it is evident that the CLCPA science actually selectively follows the narrative supporting the agenda to electrify everything using unreliable and expensive renewable energy.  No where is this more evident in the use of the 20-year global warming potential emissions inventory that makes natural gas untenable.  If the state actually implements these restrictions, then people will freeze to death in the dark either slowly because they cannot afford the energy costs or quickly when there is an ice storm that knocks out power for days.  All because of flawed CLCPA reasoning best shown by the following analogy.  Methane is 86 times more powerful than carbon dioxide so it is necessary to frame the emissions inventory to address methane uses the same reasoning as a claim that because an ant can lift 86 times its own weight it is more powerful than a man who cannot lift as high a percentage of its weight.

Climate Leadership & Community Protection Act Lessons from Europe

At the September 13, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  I agree that this is an important consideration but I expect that the evaluation will consider the control measures themselves in isolation and ignore the ramifications observed of those measures.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to complete a draft scoping plan by the end of 2021, take comments next year, revise the scoping plan, have the next state energy plan incorporate the scoping plan strategies, and then have state agencies develop the many regulations necessary.  A key component of the process will be the integration analysis. At the September 13, 2021 Climate Action Council meeting , it was noted that the Integration plan provides support for the scoping plan but it is not the same as the scoping plan as a whole.  “It is designed to assess the greenhouse gas reductions, benefits and costs of portfolios of measures state-wide so the implications of various policy recommendations can be understood.”  The report will be prepared by Energy & Environmental Economics (E3) under the guidance of the New York State Energy Research & Development Authority (NYSERDA).  It “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The scoping plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

Carl Mas from NYSERDA led the discussion of the integration scenario planning process.  During his presentation he summarized feedback from the Climate Action Council.  At 1:43:40 in the video of the meeting he described the measures/policies first bullet, that notes that they will examine carbon reduction measures being pursued by “other states, regions, localities, and nations”.  He said that measures in other states and regions, “including Europe”, will be evaluated.  The purpose of this post is to point out that in addition to the measures themselves the observed outcomes should also be addressed.

Great Britain and Germany Electrical System Status

Great Britain and other European jurisdictions have similar greenhouse gas reduction policies in place.  In June 2019 Great Britain became the “first major economy to bring all greenhouse gas emissions to net zero by 2050”.  Germany has its Energiewende (energy transition) which will expand renewable energy resources and phase the electric sector out of fossil fuels to “reduce the energy sector’s emissions by 61 or 62 percent by 2030 compared to 1990”.  Implementation of both policies is further along than the New York CLCPA and the ramifications are becoming evident.

In September 2021 electricity prices reached record levels in the European and United Kingdom power markets.  The day-ahead electricity prices are triple of those a year ago.  Paul Homewood at the Not a Lot of People Know That blog writes:

The immediate trigger has been low wind speeds across much of Europe in the last few weeks, meaning reduced outputs of wind power. This has led to a shortage of power on the grid, and a consequent spiking of prices. This sort of thing occasionally happens in winter when demand is high, but is unheard of in summer months, indicating that something is going badly wrong.

European and United Kingdom Electricity Prices

https://www.catalyst-commercial.co.uk/works/september-2021-energy-market-brief/

I believe that the current problem can be traced to an increasing lack of diversity of electrical generation sources in the European and United Kingdom electrical systems.  In order to provide reliable electricity, electric operators must balance load with generation dispatching generating sources to meet load variations.  Dispatchability is a key attribute of the generators needed for reliable electricity.  Fossil-fired, nuclear, and hydro generating stations are the primary sources of dispatchable energy today.  Europe has been phasing out coal and nuclear generation so the percentage of dispatchable generation is decreasing.  In order to keep prices down the more types of dispatchable power that are available the better so that any upset in one source can be balanced by power from the other sources.  Nuclear and hydro generation has low fuel costs so those sources run as much as possible so the loss of coal capacity means that prices are strongly influenced by the availability and cost of natural gas. 

In addition, solar and wind resources have zero fuel costs so they run whenever the sun shining and the wind is blowing.  This results in less income for the dispatchable resources and is a factor in the loss of coal generation capacity shown in following graph.  This price structure also affects existing natural gas generation and makes the construction of new natural gas capacity a poor investment so new plants are not being built. The result is a long-term loss of dispatchable generation availability.  

Europe has reached the point where renewable resource availability can trigger price issues.  Recently there was a two-week wind lull at the same time there was a Europe-wide gas shortage.  As a result of the system needing sources that can only survive by charging very high prices for the short periods when their energy is needed, the electricity price spiked and  German electricity prices hit a new record high

Also note that short-term variations in solar resources caused German electric grid operators to disconnect several industrial companies from the grid to maintain the system:

The generation of electricity in Germany on this Saturday was downright chaotic. During the day, the solar systems generated a lot of electricity due to the almost optimal solar radiation. Between 1 p.m. and 2 p.m., the solar power reached a peak output of more than 30,000 megawatts. In the evening, the power generation of the solar systems collapsed drastically. Between 7 p.m. and 8 p.m., they delivered around 3,000 megawatts, just 10% of the output from the afternoon. However, the demand for electricity in the evening was almost unchanged at a good 50,000 megawatts. The network operators therefore had to call up all available reserves. But the output of the pumped storage power plants and the lignite power plants run up to their maximum load was not enough to compensate for the deficit between electricity demand and electricity generation. The still missing amount of electricity could not be compensated by importing electricity from abroad. Therefore, shortly before 8 p.m., loads were shed from larger, energy-intensive industrial plants, such as aluminum and copper smelters

Advocates for renewable energy often under-estimate the importance of reliable electricity to society.  Obviously, higher energy prices affect consumers but they also impact industrial activities and can force them to curtail operations.  As a result of the spike in prices, British fertilizer plants shut down, CO2 produced by the fertilizer plants became unavailable, and now there is the threat of food shortages because “The gas is critical to the production and transport of a range of products, from meat to bread, beer and fizzy drinks”.  The soaring energy prices have affected the viability of gas suppliers and taxpayers in Great Britain may have to bail them out.

The European crisis also underscores issues with imports.  The United Kingdom has become increasingly dependent on electricity imports from France and Ireland.  Issues with the undersea transmission line from France have reduced the amount that can be imported.  Ireland froze exports to the United Kingdom when they needed all the output from their wind farms for their own needs.  Worse, is the reliance of Europe on Russian exports of natural gas which could easily become a source of political blackmail.  The bottom line is that relying on imports introduces complications which can come back and cause problems.

Conclusion

The Climate Action Council reminded the analysts developing the CLCPA integration analysis that the law mandates review of actions being pursued by “other states, regions, localities, and nations”.  In the presentation Carl Mas summarized the planned response to feedback from the Climate Action Council.  His presentation said they would examine carbon reduction measures being pursued by other states and regions, “including Europe”.  I suspect that the response to this mandate will focus on the measures themselves and overlook the inconvenient fact that cost and reliability issues are occurring with greenhouse gas emission reduction targets similar to the CLCPA.

Based on the current trajectory of the CLCPA implementation process I believe the same things happening in Europe today will happen in New York.  The majority of the Climate Action Council members have insufficient technical background to fully appreciate the magnitude of the challenge converting the existing electrical system to one dependent upon intermittent renewable energy resources.  For example, while the claim that solar generating capacity may be cheaper than natural gas fired power plants may be true the problem is that the claim only covers part of the cost of providing reliable electricity to homes and businesses.  When the total costs necessary to provide electricity when and where needed is added the cost is much higher as reflected by the long-term trend in European electricity prices.  Over dependence upon intermittent resources reliant on the vagaries of weather also affect shorter term price as shown by the September price spikes.  It also appears that increased energy use during cold weather this winter could be a problem in Europe unless it is mild due to the surging gas and electricity prices.  The European experience also shows that there are significant ramifications to high energy costs that should be addressed by the CLCPA.

The European experience reflects not only high energy costs but there are troubling signs that reliability issues can occur even during periods when the electric system is not stressed due to high demand.  Germany had to shut down power to major industrial facilities without warning in August because of solar variability.  The fact that the September wind lull during a period generally considered low load demand caused grid operators to call on rarely used coal generators suggests that continued retirements of the dispatchable resources at the same time more wind facilities are added will eventually cause insurmountable problems because when a high-pressure system causes calm winds it does so over a very large area so all the wind facilities in an area as small as Great Britain will all lose power at the same time.  Someday the over-reliance on wind energy and loss of dispatchable resources will cause a grid crisis in Great Britain and New York will fare no differently if the state goes down the same path.

The CLCPA attempt to reduce greenhouse gas emissions ignores the observed risks and impacts of a transition to an electrical system reliant on renewable energy in a quixotic quest to reduce the impacts of the imaginary existential threat of climate change.  This cannot end well unless the state accepts the lessons from Europe and radically revises the schedule and targets of the CLCPA until a feasible plan to address the problems identified is developed.

Finally, given the importance of what is happening in Europe I recommend an article on the same topic at Manhattan Contrarian.