Climate Act Integration Analysis Inhalable Particulate Health Benefits

Recent presentations on the integration analysis strategies to meet the  Climate Leadership and Community Protection Act (Climate Act) targets are providing insight into the impacts on personal choice and costs necessary to meet the so-called “net-zero” goals.  There is a lot of information in the presentations and it takes effort to unpack what they are saying, why they are saying it and how they came to their recommendations.  This post looks at one aspect of the alleged benefits of the Climate Act and its implications for the public.

I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it 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.


Implementation for the Climate Act implementation began soon after the law became effective in January 2020.  The law established the Climate Action Council whose charge was to develop a scoping plan to meet the targets.  The Council was supported by seven advisory panels who between late summer 2020 and spring 2021 developed strategies for the required emission reductions.  Over the summer they were turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan in October so that the scoping plan can be finalized by the Climate Action Council by the end of the year.  Next year the public and other stakeholders will get to comment on the scoping plan

In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented.  The analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with four scenarios that incorporate different emission reduction strategies.  The results presentation described specific recommended strategies and provided the first inkling of the costs and alleged benefits.  I am convinced that most New Yorkers have no idea what is included in the state’s plan to do “something” about climate change.  This article addresses the primary driver of the health benefits – inhalable particulates or PM2.5.

Claimed Inhalable ParticulateHealth Benefits

The integration analysis included health co-benefits analysis to estimate and quantify health benefits of mitigation scenarios relative to a reference case.  They did a county level analysis using EPA’s CO Benefits Risk Assessment (COBRA) Health Impacts Screening and Mapping Tool customized with detailed inputs specific to NYS and the pathways scenarios analyzed.  The model projects ambient air quality based on SO2, VOC, NOX , and direct PM2.5 emissions and the ensuing changes in annual PM2.5 concentrations from 2020 to 2050.  The results include 12 different health outcomes, such as premature mortality, heart attacks, hospitalizations, asthma exacerbation and emergency room visits, and lost workdays.

I cannot over-emphasize the point that modeling inhalable particulates air quality is a challenge.  In addition to direct PM2.5 emissions from a wide range of sources these particles also form as a byproduct of reactions in the atmosphere.  As a result, a large area that includes upwind sources has to be analyzed and that means transport becomes complicated.   As a result of these complexities and a lack of verification studies I am suspicious of the results.

The presentation on October 14, 2021 (meeting recording at 3:00:00) claimed that:

      • Decarbonization of New York can result in a substantial health benefit from improved air quality, on the order of $50 –$120 billion from 2020 to 2050 (based on reduced mortality and other health outcomes).
      • Benefits would be experienced throughout the state and downwind of the state in
      • neighboring states.
      • Benefits of reduced fossil fuel combustion are higher in urban areas due to both higher emissions and larger impacted population.
      • Benefits of reduced wood combustion are higher in upstate areas
      • Annual benefits grow over time as pollution rates decrease.

The presentation also claimed that air quality improvements can avoid:

      • Tens of thousands premature deaths
      • Thousands of non-fatal heart attacks
      • Thousands of other hospitalizations
      • Thousands of asthma-related emergency room visits
      • Hundreds of thousands lost workdays

The integration analysis modeling monetizes the air quality improvements over the period 2020 to 2050 to come up with the $50 –$120 billion claimed health benefits.  The components of the benefits are described in the following slide (meeting recording at 3:06:43).  It shows that the two largest sources of benefits are coming from “benefits of all other reduced combustion (downstate)” and “benefits of reduced wood combustion (upstate)”.  The integration analysis develops strategies to meet the targets but it does not specify how regulations will be written to implement them.  In order to realize those benefits upstate home heating with wood has to be replaced by electrification and energy efficiency effectively banning wood heating.  Policy options could include a wood burning prohibition mandate or they could assume that their electrification and energy efficiency solutions are so wonderful that everyone will willingly convert.  Authors could also believe that the efficiency of wood-burning furnaces could be improved so much that the impacts will be reduced.  In practice, however, getting any combustion source “tuned” to minimize emissions is an operator challenge and I think it is unlikely that owners will take the time and effort to master that skill.

New York Inhalable Particulate Trends

Over the past 30 years there has been a remarkable decline in SO2, VOC, NOX, and direct PM2.5 emissions and the observed annual average inhalable particulate concentrations at seven locations across the state have declined in response as shown below.  Inhalable particulate monitoring started in the late 1990’s but since 2000 the annual averages have dropped between 30% and 60%.  These reductions are mostly due to decreased SO2 and NOX emissions caused by the Acid Rain Program and ozone reduction programs.

New York State PM2.5 Trends

Inhalable Particulate Emissions and Benefits Projections

The integration analysis presentation (meeting recording at 3:08:26) includes the following slide that describes where the emissions are coming from that provide the alleged benefits.  The key point here is that the modeling projects that roughly three quarters of the expected inhalable particulate emissions in 2025 come from commercial and residential wood burning and industrial wood burning is another big chunk. According to Carl Mas “It is not that we are burning a lot of wood, it is that it is very dirty when it is burned”.

Not surprisingly, the projected health benefits by sector analysis comes to the conclusion that if there was no wood combustion there would be benefits.  This provides the benefit justification to offset the costs for the electrification, home energy efficiency, and wood stove energy efficiency strategies.

Inhalable Particulate Air Quality Projections

The integration analysis presentation (meeting recording at 3:17:42) presents the PM2.5 air quality projections that drive the benefits analysis.  Carl Mas claims that we are getting “deep” reductions of inhalable particulates across the whole state but the highest annual average value is no greater than 0.35 µg/m3. That is a pretty small concentration that I suspect, but could not document, is near the precision of the monitoring system.

It is also informative to compare the predicted decrease in inhalable particulate concentration resulting from the Climate Act strategies to the observed decrease from 2000 to 2020.  As shown in the following figure where I inserted the observed decreases from the seven PM2.5 ambient monitoring stations used before, all but one of the monitoring sites observed a PM2.5 decrease a factor of ten greater than the largest predicted reduction.  On average, the observed reduction between 2000 and 2020 was fifteen times greater than the predicted future decrease.


The EPA’s relationship between inhalable particulates and health benefits, as exemplified by the COBRA model, has been used as the primary benefit-cost rationale for many air quality regulations.  At this time New York state is in compliance with the inhalable particulate national ambient air quality standard which is the legally enforceable mechanism to protect human health.  These projections claim that there is no threshold for health impacts and that there is a linear relationship between health impacts and ambient concentrations.  For example, in September, 2011 US EPA Administrator Lisa Jackson testified to Congress that fine particles kill hundreds of thousands of people in America every year, a claim based on EPA epidemiology and extrapolated projections.  However, Enstrom tested the validity of this relationship and found no effect of fine particulates.  Nonetheless, these results have been used for years to justify regulations and legislation and from the basis of these Climate Act benefits.

In order to convince me that the relationship used to predict these benefits is correct I need to see verification of the health benefits with a reduction in inhalable particulate concentrations.  In order to  do the verification correctly, the EPA Environmental Benefits Mapping and Analysis Program should be used.  That model uses similar health outcome predictions to COBRA but uses observed air quality changes as its input.  The linear model used to project the health benefits should show proportional impacts to the integration analysis projections.  If that relationship is correct then there should be observable reductions (on the order of 15 times great than the integration analysis predictions) in all the health outcomes used.


I do not accept the linear no-threshold model for air pollution health analysis mostly because the National Ambient Air Quality Standards are based on a threshold approach.  Consider this example as an illustration of my cynicism.  No one questions the fact that prolonged exposure to wood smoke can cause health problems.  I have no doubt that there are health studies that have conclusively shown that at high pollution levels people have contracted cancer.  For the sake of argument, assume that the health studies have found that wood smoke at a continuous dose of 100 ppm for one year causes cancer.  The linear no-threshold model can extrapolate that dose response down to 0.00019 ppm per minute.  Using that extrapolation relationship, if 5,256 people sitting around campfires were exposed to the 100-ppm dose for one minute then linear no-threshold models claim one of them will get cancer from that dose.  Anyone who has sat around a campfire probably has been downwind of the smoke and received a dose of wood smoke.  It does not matter what the actual health impact dose response rate is, if you extrapolate that down to the dose of people sitting around a campfire and multiply that by all the people sitting around campfires the linear no-threshold model predicts an impact.

Comparison of the observed reductions of inhalable particulate ambient concentrations since 2000 and the projected decreases expected due to the climate act suggests that NYSERDA could validate their health impact benefit claims.  They claim benefits by preventing tens of thousands premature deaths, thousands of non-fatal heart attacks, thousands of other hospitalizations, thousands of asthma-related emergency room visits, and hundreds of thousands lost workdays.  Using their linear relationship and an order of magnitude larger observed reduction of inhalable particulates then the relationship should show up.  I find it hard to believe that the reduction in inhalable particulates has actually prevented millions of lost workdays.

Finally, note that the integration analysis only presents strategy recommendation.  At the end of 2022 the scoping plan will be finalized and the next year NY agencies will have to develop implementing regulations.  In this example, will they actually prohibit wood burning to ensure that the greenhouse gas emission targets and the projected health benefits are realized?  Maybe they will just assume that their electrification and home heating energy efficiency programs will be so popular that everyone will convert willingly. I don’t think that will work given that many of the people that I know who use wood for heating, get the fuel from their own woodlots.  Electric options have to be significantly more expensive for them.  Finally note that they might believe that wood stove energy efficiency programs will improve performance and reduce inhalable particulate emissions.  I don’t think that is a realistic hope because maintaining efficiency is too difficult for typical home owners.

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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