The New York State Department of Environmental Conservation (DEC) has proposed Amendments to Part 490, Projected Sea Level Rise andComments that are due on April 29. This post describes my comments on the proposed amendment and requests that New Yorkers who reading this before April 29 submit comments. Don’t worry, I will give language.
The proposed amendments revise the projections of future sea-level rise required by New York regulations. It is flawed because the methodology estimates an unrealistically high projected sea-level for the Community Risk and Resiliency Act flood risk management applications that will use the projections. Unless more realistic estimates are used permitting applications in areas near tidal zones will be required to incorporate flood levels that will not be expected in the lifetime of the project. That would be a hidden cost for the net-zero transition of the Climate Leadership & Community Protection Act (Climate Act).
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The summary of the Part 490 proposed amendments states that: “The goal of the proposed amendments is to provide up-to-date science-based projections of future sea level rise.” This is another example of the many ways that the Climate Act is intruding on many aspects of society. The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation but implementation is behind schedule. The proposed amendments to the sea-level projections are a hidden aspect of the Climate Act that has significant potential impacts.
Part 490 Projected Sea-Level Rise
The Regulatory Impact Statement (RIS) for this proceeding describes the regulation’s statutory authority and legislative objectives, the proposed changes, needs and benefits, and costs. It explains:
On September 22, 2014, the Community Risk and Resiliency Act, Chapter 355 of the Laws of 2014 (CRRA), was signed into law. CRRA, among other things, established Environmental Conservation Law (ECL) § 3-0319. ECL § 3-0319 requires the Department of Environmental Conservation (Department) to adopt regulations establishing science-based sea level rise projections for New York State and to update them no less than every five years. The Department established a new Part 490 of Title 6 of New York Codes, Rules, and Regulations (6 NYCRR), “Projected Sea-level Rise” (Part 490) in February 2017 and is updating the regulation through the current rulemaking.
The proposed amendments are an update of the 2017 sea-level rise projections. While I am not absolutely sure I believe the reason that this amendment was delayed was because the primary reference, New York Research & Development Authority New York State Climate Impacts Assessment, was not available within the five-year period. Even so, the documents for the Assessment are all marked “Interim Version for Public Release” which calls into question their use for a policy document.
The goal of the proposed amendments is to provide up-to-date science-based projections of future sea level rise. Part 490 does not create a mandate on local governments. Part 490 does not impose any compliance obligations on any entity.
While technically and legally correct, the excuse not to include costs and the argument that there are no compliance obligations or mandates on local governments has significant ramifications. The fact is that there are compliance obligations that are affected by the Part 490 rulemaking. DEC selectively chose to emphasize analyses that support the “high-end storyline” without regard to how the sea-level rise projections will be used. There are relevant, plausibility, timing, and cost implications that I believe should be added to the Regulatory Impact Statement.
As originally enacted, the CRRA required applicants for permits or funding in a number of specified programs to demonstrate that future physical climate risk due to sea-level rise, storm surge and flooding had been considered in project design, and that DEC consider incorporating these factors into certain facility-siting regulations. The CLCPA amended the CRRA to include all permits subject to the Uniform Procedures Act. The CLCPA also expanded the scope of the CRRA to require consideration of all climate hazards, not only sea-level rise, storm surge and flooding, in these permit programs.
In my comments I argued that that while Part 490 may not directly create a mandate on local governments, all permits must consider the sea-level rise climate hazard which is essentially a mandate affecting all governmental agencies.
Part 490 Proposed Amendments
The RIS description of the proposed sea-level rise projection amendments with my annotated comments follows:
Table 4. Updated projections of sea level rise for three tidal regions of New York State, based on the Department’s proposed methodology. Projections are in inches, relative to a 1995-2014 baseline, and are based on a combination of the SSP2-4.5, SSP5-8.5-medium-confidence and SSP5-8.5-low-confidence projections, with the addition of a RIM scenario.
Part 490 is intended to give permitting authorities information on the full range of potential sea-level rise. In reality the CRRA design considerations that use the sea-level rise projections focus on the highest values. New York State Flood Risk Management Guidance for Implementation of the Community Risk and Resiliency Act states that “Applicants and programs are also encouraged to consider the following during project siting, design and review” states:
Applicants for projects involving new or replacement critical infrastructure should consider the full range of projected flooding, including the highest adopted projections of sea-level rise, during the expected service life of the project. Where adherence to the highest guideline is not feasible, due to practicality, costs, risk tolerance, and/or environmental effects, applicants should carefully describe and justify designs not adhering to the most restrictive guideline.
Note the requirement to use “the highest adopted projections of sea-level rise” includes the caveat to consider the “expected service life of the project”. That is missing piece in the RIS. The RIS emphasizes the point that the Intergovernmental Panel on Climate Change (IPCC) has not indicated the relative probabilities that any of the illustrative scenarios included in the latest assessment report (AR6) will occur. However, CRRA infrastructure applications need to consider the likelihood of sea-level rise levels to determine practicality, costs, risk tolerance, and/or environmental effects. The RIS argues that focusing on the most probable outcome has risks and warns of much higher potential sea-levels.
Furthermore, Hinkel et al. (2015) warn that sea level rise projections based on process-based models, such as those used by IPCC, are primarily intended for the purpose of understanding earth system physics and are not appropriate for risk-based decision making as they do not fully incorporate the effects of accelerated ice melt. They warn that projections based on the IPCC AR5 projections of mean global sea level rise of 11 to 39 inches by 2100 may not be adequate for risk management due to the intolerably high residual risk associated with rapid ice melting Parris et al. (2012) also cautioned that focusing only on the most probable outcome could lead to vulnerability or maladaptation.
The reference to “intolerably high residual high residual risk associated with rapid ice melting” ignores the expected service life of the project consideration. The RIS explains that the decision makers need to understand the full range of potential risk but does not acknowledge that their presentation of results discourages the use of anything but the high projections. The result is that development near the tidal shoreline is planning for extremely high projected sea-level rise. A New York City project to increase a park to handle 8 to 10 feet of sea-level rise is include in “a $1.45 billion flood protection project that backers say befits the nation’s largest city, a massive project that will include the construction of a 2.4-mile system of walls and gates along the East River”. That is only a fraction of the harbor front in the City so it makes sense to use more reasonable estimates of sea-level rise given the need to protect the entire harbor of New York, but it is easier for DEC to just recommend the biggest number to “be safe”.
Decision makers, including residents and local leaders, should understand the full range of potential risk. Communities and stakeholders in New York State that have been presented with the ClimAID projections have tended to adopt and plan for high levels of sea level rise rather than more moderate levels. These stakeholders have placed a high degree of importance on ensuring the viability of proposed infrastructure investments and the social and economic fabric of their communities from even unlikely eventualities.
The “science-based” regulation and the guidance did a disservice to New Yorkers because the risk management approach did not adequately address tradeoffs between costs and likelihood of “unlikely eventualities”. The sea-level rise projections rely on cherry-picked studies and ignoring any work that does not fit the extreme scenario used and that is not “science”. Unlikely things that just might happen in the distant future are not “eventualities”. All the extreme sea-level rise projections use the implausible high emissions scenario embodied in Representative Concentration Pathway (RCP) or Shared Socio-economic Pathways (SSP) RCP/SSP8.5. There is overwhelming evidence that the coal use, population growth, and neglect to consider any decarbonization policy assumptions in those scenarios are inconsistent with observed reality. The National Oceanic Atmospheric Administration (NOAA) Geophysical Fluid Dynamics Laboratory (GFDL) description of their globcal climate modeling approach that states “SSP5-8.5 is a very high greenhouse gas emissions scenario – and unlikely to happen – where carbon dioxide emissions triple by 2075″ and does not use it for their recommended projections.
Notwithstanding the arguments in the following paragraph from the RIS trying to justify its use, the fact is that using these projections are inappropriate to use in this context. I do not dispute that the potential for rapid ice melt exists that would cause a spike in sea levels. However, I maintain that is improper to use in this context because it is a low probability event but that in the time frame of CRRA infrastructure projects it is a much lower possibility. The argument that Part 490 guidance must address sea level rise that will “likely occur at some point” without consideration of the use of the projections is inappropriate. The State simply cannot afford the ramifications of the insistence to remove risk entirely.
Finally, as explained above, sea level rise will continue for many centuries as the earth system comes into equilibrium over many centuries or even millennia. Thus, the question for decision makers is not if a critical sea level will be reached, but when. Strauss (2013) calculated that historic emissions have already committed the globe to a mean sea level rise of 6.2 feet. Levermann et al. (2013) estimated that the current international target of 2°C warming will result in an eventual mean global sea level rise of more than 15 feet after 2000 years. Thus, a full range of projections in Part 490 that includes higher values is appropriate to allow for consideration of a level of sea level rise that will likely occur at some point, even if the timing of such occurrence is uncertain. The Department acknowledges that current GHG emissions policies would result in actual emissions lower than projected by SSP5-8.5. Thus, the inclusion of higher projections of sea level rise, especially those based on SSP5-8.5, could lead to consideration of conditions that are unlikely to occur, at least in the more immediate future. Unfortunately, current literature does not provide a basis for assessment of the emissions levels at which ice shelf and marine ice cliff instability, important factors in sea level rise in high emissions scenarios, such as SSP5-8.5, become significant.
This paragraph characterizes my concern that the purpose of the sea-level rise projections was not considered enough. Preparing for the next 2000 years for a city that was founded only 400 years ago is silly.
This gap in the literature, however, does not relieve decision makers from the responsibility to at least consider the potential consequences of future events about which scientific uncertainty remains. Adoption of several levels of projections allows for consideration of risk tolerance in decision making. The high or RIM projections might be used for long-term projects for which there is low risk tolerance, for example, while lower projections may be appropriate for consideration in situations in which risk tolerance is high. Inclusion of low-confidence, but plausible, projections provide benchmarks against which long-term decisions, e.g., those regarding critical infrastructure and land-use change, can be evaluated for high-consequence events. If Part 490 did not include higher projections of sea level rise, decision makers would not be able to even consider the possibility of such levels occurring. The Department proposes, therefore, to adhere to the recommendation of Stammer et al. (2019) to include “high-end storylines,” that reflect physical processes about which high uncertainty exists, i.e., the RIM scenario, with probabilistic projections.
The last paragraph in this section clearly describes the misguided DEC approach. There is no question that decision-making when there is high scientific uncertainty is difficult. From a risk management perspective all factors must be considered. In this instance, the recommendation to use the higher sea-level rise projections for long-term projects does not consider CRRA infrastructure life expectancies which are shorter than the time frame of the high-risk impacts. Furthermore, it can be argued that the “low” confidence sea-level rise estimates are “no” confidence events because they rely on SSP-8.5 which is implausible. I do not believe that a “high-end storyline” approach is appropriate for regulatory guidance.
Summary of My Comments
My detailed comments describe the observed sea-level rise at the Battery monitoring station in New York City, the methodology used to project sea-level rise, and compare the sea-level rise projections and observations (table below). The following table compares the projected sea-levels using the observed from 1850 to present and 1984 to present with the projections of sea-level rise. Importantly the observed sea-level rise is less than the 50th percentile, “medium confidence” Part 490 sea-level projections. In other words, the observations indicate that the medium confidence projections are conservative estimates of sea-level rise. I also found that comparing the acceleration of sea-level rise necessary to comport with the projected rates with the observations indicates that there is no sign that the “high-end storyline” projections are realistic.
Compare 2024 proposed sea level rise projections (inches of rise relative to 1995-2014 baseline) to sea-level rise projected using observed trends since 1850 and 2014 at the Battery Monitoring Station
The RIS argues that observed sea-level rise projections are not appropriate to use for future estimates because they do not account for projected global warming. To address this concern the Energy and Environmental Alliance of New York proposed a “pledge and review” alternative approach in 2016. My comments argue that this is a better approach. Given the uncertainties of modeling both global warming and the associated sea-level rise along with the model over-estimates of warming it is prudent to assume that the sea-level trend observed over the last 150 years will continue until the observations indicate otherwise.
There is a section in my comments that describes how the sea-level rise projections are intended to be used for flood risk management. The RIS does not consider that flood risk management must incorporate probability of occurrence. The Part 490 sea-level rise projections do not because of the emphasis on the “high-end storyline”. Even though the RIS appropriately describes all the scenarios and how the data were collected and used, the RIS risk analysis is flawed because it does not weigh potential results against benefits and consequences. The comments describe a more appropriate risk management approach.
Summary of Recommendations
The sea-level rise projections in the proposed amendment need to be reconsidered. The over-arching problem is that the low-likelihood, high-impact storyline that incorporates the rapid ice melt scenario is dependent upon the RCP/SSP 8.5 high emissions scenario and does not account for the near-term applicability of the sea-level projections for CRRA applications. Even the RIS acknowledges that “current GHG emissions policies would result in actual emissions lower than projected by SSP5-8.5.” Because the high greenhouse gas emissions are a necessary condition for the rapid ice melt low-likelihood, high impact scenario, that emissions scenario should not be used for sea-level rise recommendations. Furthermore, the timing of the rapid ice melt scenario is extremely unlikely to occur in the time frame of infrastructure projects in the New York State Flood Risk Management Guidance for Implementation of the Community Risk and Resiliency Act guidance that refers to Part 490 sea-level rise.
The RIS claims that because Part 490 “will not impose any costs on any entity because the regulation consists only of sea level rise projections and does not impose any standards or compliance obligations” that no costs are associated with Part 490. However, the pertinent cost issue is the difference between the recommended alternative and the alternatives described in the RIS. The “high-end storyline” approach has an impact on costs and the failure of the RIS to address them is a disservice to the citizens who will have to foot the bill. The RIS should be modified to compare costs with the alternatives included.
Any projection that uses the RCP/SSP 8.5 high emissions scenario overestimates sea-level rise values. Given the acknowledged uncertainties with sea-level projections and the over-predictions of global warming with current global climate models, the pledge and review approach should be used to determine if accelerated sea-level rise consistent with the “high-end storyline” projections are observed. The sea-level projections consistent with SSP2-4.5 should be used because these sea level rise projections are associated with the most likely conservative estimates of potential emissions and the numbers are consistent with observed sea-level rise. If future observations indicate that this scenario is no longer conservative then the projections can be modified accordingly.
How To Provide Written Comments
I encourage my New York readers to submit written comments by the 5:00 PM April 29, 2024 deadline. I have prepared a detailed explanation of the process at this link. The link also includes a condensed comment that addresses the key points described above.
Copy the comment text in the link into the body of your email.
Submit it
If you are inexperienced with the DEC rulemaking process let me explain what happens next. If you are lucky, you will get an acknowledgement that your comment was received. DEC staff are required to read the public comments and the rulemaking requires a response to comment document. At some point there will be a document that includes a response to each comment and recommendation. It would be especially useful if you have a specific example of a concern related to the projections to include that in your comments. If you prepare your own comments, then they will have to respond to that separately, but all the comments submitted using my recommendation will be consolidated. Reading comments and writing a response does not mean DEC will change anything in their proposed rulemaking.
I have submitted comments for countless proceedings over the last 40 years. Sadly, over the years DEC has become more and more politically driven to the point now that all rulemaking policy decisions are ultimately decided by the Administration regardless of the science. To increase the chance that any of the comments and recommendations will actually be implemented, I suggest sending a copy to your legislators. Like most of the Climate Act implementation components very few people know what is happening and the ramifications of the actions. If the legislators start asking the Administration questions about the use of implausible scenarios that will make development near the shorelines more expensive, there may be a political response towards consideration of tradeoffs. Absent that the only solace is the record will show that the State was warned that their policies were ill-advised when the proposed sea-level recommendations fall far below the observed rise.
The rule-making process includes a perfunctory public hearing. The Part 490 hearing was held on April 22. The hearing officer described the rule making process and Mark Lowery from DEC went through the following slide. That was all over in ten minutes. Two people signed up to give comments. I signed up but could not talk because of a persistent cough. The other person’s comments were totally unrelated. She wanted to thank DEC for setting up raptor nesting boxes. For the record all comments are considered equally so nothing was lost. In fact, I showed up for a hearing one time and a friend from DEC who was working on the proceeding basically said the hearings were a waste of time and that they preferred the written comments.
Conclusion
Given the poor turnout for the public hearing, there does not appear to be much interest in this rulemaking. I doubt that these comments and recommendations will have any effect on the rulemaking because there is too much institutional inertia. The record for some rulemakings makes a big deal about the number of comments that support their position. If the negative comments outweigh those supporting the proposal, then it will be interesting to see how the documentation spins that. In order to find out please, submit a comment. Thanks.
A recent Associated Press story noted that “For the 10th consecutive month, Earth in March set a new monthly record for global heat — with both air temperatures and the world’s oceans hitting an all-time high for the month, the European Union climate agency Copernicus said.” It went on to state that “Climate scientists attribute most of the record heat to human-caused climate change from carbon dioxide and methane emissions produced by the burning of coal, oil and natural gas.” This post provides evidence that human-caused climate change was not the primary cause for the records.
The rationale used for New York’s Climate Leadership & Community Protection Act (Climate Act) that reducing GHG emissions will affect climate is of special interest to me. However, I question whether we know enough about natural climate variability to legitimately make that claim. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Observed Climate Variability
The video Climate the Movie: The Cold Truth includes a very good description of historical temperatures and CO2 trends. It provides examples why claims that today’s observations indicate unprecedented heat in earth’s history are wrong. In geologic time scales temperatures today are not at all unusual and because we are in an ice age all previous non-ice age geologic epochs were warmer. Over the last 2,000 years there also have been periods of warmer temperatures. The video goes on to compare CO2 trends over those periods to show that there is no link.
In a recent post I addressed the basic tenet of anthropogenic global warming catastrophists, like the authors of the Climate Act, that the correlation between CO2 and global warming evident since 1976 proves that CO2 is the control knob for climate. Andy May prepared an Annotated Bibliography for Climate the Movie that includes a section titled “From 1945 to 1976 the world cooled”. It includes the following plot of global temperatures and carbon dioxide. Climate Act proponents believe that increasing temperatures since the end of the Little Ice Age are caused by increases in CO2. This graph does not support that claim. From 1850 to 1910 temperatures trend slightly down and CO2 trends slightly up. From 1910 to 1944 there is little change in the CO2 trend but the temperature trends up markedly. CO2 emissions don’t start to rise significantly until the end of World War II in 1945 but from 1944 to 1976 the global temperature trends down. For the remaining two periods shown in the graph temperature and CO2 correlate well.
The caption highlights the key point. There is good correlation between CO2 concentrations in the atmosphere after 1980 but the correlation is poor before that. I believe this shows that natural climate variation caused the 1910 to 1944 warming. I do not believe that anyone has proven that the same natural climate drivers are not affecting the recent warming.
The National Oceanic and Atmospheric Administration (NOAA) recently posted a comment that contradicts the existential threat narrative and supports those who argue natural climate variability is the main driver of climate change. It states that “The amount of CO2 in the atmosphere today is comparable to around 4.3 million years ago, when sea level was about 75 ft higher than today, the average temp was 7 degrees F higher than in pre-industrial times, & large forests occupied areas of the Arctic that are now tundra.” Climate the Movie shows that going back further in time that CO2 levels were much higher than today. It is not clear to me why there is supposed to be an existential threat to society when temperature and CO2 concentrations were higher in the past and the ecosystems survived.
Recent Warming
The claims for recent global temperature records reference NASA satellite data. This data set only goes back to 1979 but it provides the greatest representative coverage of the globe because it does not depend on randomly spaced surface measuring stations. In the following graph note the large spike in recent months.
Note that the spikiness in these measurements is not reflected in the atmospheric concentrations of CO2 measurements. According to NOAA’s CO2 measurements:
The global surface concentration of CO2, averaged across all 12 months of 2023, was 419.3 parts per million (ppm), an increase of 2.8 ppm during the year. This was the 12th consecutive year CO2 increased by more than 2 ppm, extending the highest sustained rate of CO2 increases during the 65-year monitoring record. Three consecutive years of CO2 growth of 2 ppm or more had not been seen in NOAA’s monitoring records prior to 2014. Atmospheric CO2 is now more than 50% higher than pre-industrial levels.
If CO2 really is the control knob, then why is there so much inter-annual variation in temperature at the same time there is so little variation in the CO2 trend? The only possible explanation activists have is that there are some natural variation processes. Picking and choosing CO2 as the cause of the increasing trend while simultaneously acknowledging that there also are natural processes affecting the observed temperatures does not seem to be a particularly strong position to me.
Most Recent Warming
The Associated Press article claimed that “Climate scientists attribute most of the record heat to human-caused climate change from carbon dioxide and methane emissions produced by the burning of coal, oil and natural gas.” The reality is that not all climate scientists support the claim that most of the record-breaking heat was caused by anthropogenic greenhouse gases.
Javier Vinós described the recent warming explaining that this spike in temperatures marked the warmest period recorded by instruments and that the recent change was exceptional. He found that “the temperature increase from the previous record was the largest in 153 years, at +0.17°C. This level of increase from previous records is remarkable, even for a year that has been recorded as the warmest on record.” If there had been a spike in GHG emissions that preceded this warming spike, then I would be more supportive of the CO2 is the control knob theory. It turns out that there was no spike in human emissions but there was a natural spike. The Tonga-Hunga underwater volcanic eruption blasted unprecedented amounts of water vapor into high levels of the atmosphere. Water vapor is more effective than CO2 as a greenhouse gas so this could be part of the reason for the recent warming spike.
There is another natural phenomenon likely responsible for some of the warming. Surface water temperatures in the Pacific Ocean oscillate between warm (El Niño) and cold phases (La Niña ) of the El Niño-Southern Oscillation or “ENSO”. The winter of 2023 occurred during an El Niño when the ocean releases heat into the atmosphere and has been associated with marked increases in global temperatures. However, the 2023 El Niño was a weak year so its contribution to the observed warming was minimal.
In an article entitled “State of the climate – summer 2023“, Judith Curry examined the top of the atmosphere radiation balance. As of June 2023, her analysis suggests that the water vapor increase in long-wave radiation warming from the Tonga-Hunga underwater volcanic eruption was offset by the short-wave aerosol particle cooling. She gave other reasons for the observed warming records:
The exceptionally warm global temperature in 2023 is part of a trend of warming since 2015 that is associated primarily with greater absorption of solar radiation in the earth-atmosphere system. This increase in absorbed solar radiation is driven by a slow decline in springtime snow extent, but primary by a reduction in reflection from the atmosphere driven by reduced cloudiness and to a lesser extent a reduction in atmospheric aerosol. Any increase in the greenhouse effect from increasing CO2 (which impacts the longwave radiation budget) is lost in the noise.
She lists three reasons for the warming. The slow decline in springtime snow extent has been linked to the warming trend as we come out of the Little Ice Age. Clouds affect global temperatures. Within the atmosphere more low clouds reduce temperatures by reflecting more sunlight but increased high clouds increase temperatures. Particles or aerosols also scatter light and can affect temperatures by blocking sunlight. She attributes the observed warming to the reduction in reflection from the atmosphere driven by reduced low-level cloudiness and to a lesser extent a reduction in atmospheric aerosol particles. Low-level cloudiness trends are not well understood and are not included in climate models. The aerosol changes are attributed to changes in the sulfur content of ship fuel. Most importantly, she points out that increasing CO2 effects are “lost in the noise” which directly contradicts the Associated Press article.
Conclusion
The rationale for the multi-billion Climate Act net-zero transition is the alleged link between climate change and greenhouse gas emissions. Undoubtedly the emissions increases have some greenhouse effect on global temperatures, but the effects of natural climate variability not only must have been responsible for all of the historical variations in global temperatures but also appear to be the primary driver even during the most recent period when carbon dioxide emissions and global temperatures are well-correlated. The rationale for the Climate Act transition is weak at best.
As part of the Department of Public Service Proceeding 15-E-0302 a technical conference was held on December 11 and 12, 2023 entitled Zero Emissions by 2040. A zero-emissions electric system is a key part of New York’s Climate Leadership & Community Protection Act (Climate Act) and all credible projections for the generating resources needed for the zero emissions Climate Act target have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability. Previously I published an article describing the slide presentation by Zachary Smith from the New York Independent System Operator (NYISO) describing DEFR. The video of the meeting is available now and this article describes the first session of the meeting – Gap Characterization.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. DEFR is a particularly challenging problem. When political fantasies meet reality, reality always wins.
Gap Characterization
The Department of Public Service (DPS) convened a two-day technical conference on December 11, 2023. The conference focused on characterization of the potential “gap” discussed in the May 14, 2023 Proceeding 15-E-0302 Order and technologies that could shrink or fill that gap.
The first session (video) of the conference was titled Characterizing the potential “gap”. It addressed resource adequacy, transmission security, and grid stability arising from shuttering fossil fuel-fired resources and increased loads due to the Climate Act electrification strategies. It was moderated by Schuyler Matteson from DPS. There were four panelists and I have included links to the location in the video with their introductions:
Deidre Altobell, Chief Transmission Planning Engineer Consolidated Edison. She represented the concerns of the New York City electric system provider. New York City has unique issues within the New York State electric power market that are a particular challenge for a transition to a system dependent upon renewables.
Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell. Professor Anderson provided an independent check on the work of other electric system planning analysts because her group has modeled resources necessary for the New York electric system transition.
Zach Smith, VP System Resource Planning, New York Independent System Operator (NYISO). NYISO is “responsible for operating wholesale power markets that trade electricity, capacity, transmission congestion contracts, and related products, in addition to administering auctions for the sale of capacity.” As part of those responsibilities NYISO has done extensive modeling resource projections of the net-zero transition.
Kevin Steinberger, Director, Energy and Environmental Economics (E3). As part of the New York Climate Act transition plan an Integration Analysis was performed that included an assessment of the electric system net-zero transition resources. E3 provided the quantitative analysis for that effort.
The description for the meeting described the items for discussion:
Existence of a “gap,” based on physical and planning requirements of the grid.
Resource adequacy, transmission security, and grid stability components of the potential resource-reliability gap that is expected to emerge in New York as fossil-fired generation resources are shut down pursuant to CLCPA requirements.
How models used by NYISO, the Climate Action Council, and others identify this “gap” and estimate its size and timing.
Information to seek/develop through additional studies conducted as part of the Coordinated Grid Planning Process and/or ongoing NYISO Reliability Needs Assessment.
This article only discusses one of the sessions in the Technical Conference. The DPS website provides information on the other sessions and links to the videos of the discussions. There is plenty of fodder for additional posts, but I also have a long list of obligations and other topics to cover so I am not going to address anything else here.
Gap Characterization Session
After the introductions the moderator asked a series of questions. This section lists the questions with a link to that location in the video. I highlight some of my concerns and points made by the panelists
The first questions was: “How do we know if there is a gap?” Professor Anderson described an analysis her group did. They made projections for expected loads and potential resources then used 22 years of hourly historical data to model the system. Without considering cost constraints they assessed system vulnerabilities to evaluate periods where there was insufficient generation to meet projected loads. Even with optimistic projections they found there will be periods during the coldest and hottest periods where there will be insufficient generation from wind, solar, and energy storage resources. Steinberger also responded that their modeling consistently showed the need for a new resource that is firm, dispatchable, and has no emissions that can power the system for days without significant recharge from wind and solar resources. He stressed the importance of considering actual historical meteorological conditions because renewable energy production is dependent on weather conditions.
Zachary Smith gave an overview summary presentation of the DEFR issue that was the focus of an earlier post of mine. In his first slide (shown below) he gave an overview of the generating resource outlook to make the point that a large amount of new generating resources needs to be developed. The estimates shown are from the 2021-2040 System & Resource Outlook and represent two plausible load projections. He noted that there are “a lot of attributes that fossil fuel resources provide today that wind, solar, and energy storage simply cannot provide”. He also made the point that the DEFR replacements do not have to be a single technology but could be several technologies that in aggregate can replace the fossil generation.
The ultimate problem for reliability in an electric system that depends on wind and solar is illustrated in the following slide from Smith’s presentation. It highlights a 7-day wind lull when the wind, solar, and energy storage are insufficient to meet demand. The replacement resources must be able to ramp up quickly, stay online for a long period, and provide ancillary services to support the transmission system. The sum of the grey area under the curve during that period is the amount of energy (MWh) that must be provided by DEFR sources based on an analysis of historical weather data. If there are insufficient resources during a wind lull, then the load cannot be met. The consequences of that situation would be catastrophic.
To meet this need for dispatchable resources Smith explained that dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York:
As resources shift from fossil generators to zero emission resources, essential grid services, such as operating reserves, ramping, regulation, voltage support, and black start, must be available to provide New Yorkers with a reliable and predictable electric system that consumers require.
DEFRs will be required to provide both energy and capacity over long durations, as well as the reliability attributes of retiring synchronous generation. The attributes do not need to be encapsulated in a singular technology, but in aggregate the system needs a sufficient collection of these services to be reliable.
The NYISO must toe the political correctness line, so Smith downplays the enormity of the challenge to bring DEFR online in the timeframe necessary to meet the arbitrary Climate Act schedule. I have no such restrictions so I will note that I think that anyone who thinks that this can be done is crazy. Smith lists the attributes needed by DEFR in his presentation. In the following I offer my comments on his list of attributes.
Smith’s first attribute for DEFR is that it must have “dependable fuel sources that are carbon free and allow these resources to be brought online when required”. Clearly intermittent wind and solar do not meet this fundamental requirement.
The second DEFR attribute is that it must be “non-energy limited and capable of providing energy for multiple hours and days regardless of weather, storage, or fuel constraints”. This is a particular concern of mine. Wind and solar resources correlate in time and space. In other words, when the wind is light at one wind farm in New York it is very likely that all the wind farms in the state are experiencing light winds. The seven-day wind lull example in the dispatchable resources needed figure illustrates the problem. If there are insufficient resources during that wind lull, then the load cannot be met. My concern is that I think we do not know what the worst case low renewable resource availability period is. Until there has been more analysis done then I believe that planning to prevent reliability issues is inadequate.
The NYISO operators balance generation with load constantly. Smith describes several attributes necessary for this requirement. DEFR must be able to “to follow instructions to increase or decrease output on a minute-to-minute basis”. There must be “flexibility to be dispatched through a wide operating range with a low minimum output”. Finally, DEFR must be “fast ramping to inject or reduce the energy based on changes to net load which may be driven by changes to load or intermittent generation output”.
In addition to the attributes needed when units are operating, there are startup attributes. DEFR must be “quick start to come online within 15 minutes” and capable of “multiple starts so resources can be brought online or switched off multiple times through the day as required based on changes to the generation profile and load”. Smith explains that a range or DEFR generation will likely be required. Not every DEFR must be capable of every attribute for matching load but sufficient amounts each attribute for the system requirement will be required.
In addition to the generating requirements that cannot be supplied by wind and solar, there are ancillary support services for the transmission system. Smith describes three transmission support DEFR attributes:
Inertial Response and frequency control to maintain power system stability and arrest frequency decline post-fault;
Dynamic Reactive Control to support grid voltage; and
High Short Circuit Current contribution to ensure appropriate fault detection and clearance.
Smith’s presentation lists the attributes of twelve sample technologies in the following slide. This represents the NYISO opinion of the capability of different technologies to meet the attributes necessary to maintain a reliable system. In the future grid the insistence that all fossil fired units must be shut down means that numerous technologies that meet some of the necessary attributes will be required. The added complexity of these technologies does not increase resiliency because wind, solar, battery and demand response are all energy limited. Ancillary support services will be a major consideration because wind, solar and battery do not provide those services. Just from this overview, it is clear that affordability and reliability will be challenges.
Attributes of Sample DEFR Technologies
The moderator asked for Altobell’s reaction relative to the situation in New York City. She noted that Con Ed agrees with NYISO analyses and that their work has shown similar results. She made the point that there is a minimum amount of generation that must be on-line in New York City to provide reactive support. She explained that the location of that generation is important. Importantly, she noted that we cannot let any more fossil retire until replacement services are provided.
Altobell also described some of the reliability standards that they are required to address. For example, the reliability standard N-1-1 addresses the loss of the two largest components on the system and the ability to recover from the loss of those two components. This criterion is considered on a daily and on a long-term basis. Currently the system relies on quick start units to get the system back to normal after the loss of large components but the peaking turbines that have historically been used for this are being retired which complicates compliance with the requirement.
In another example of a hidden cost of the net-zero transition Altobell explained that the New York City transmission system needs to be modified to eliminate load pockets. Historically Con Ed has relied on generating resources that were located to serve those load pockets. To replace those resources, the load pockets have to be eliminated to open up the system. This is complicated by the fact that there isn’t much room available for infrastructure like substations.
I was interested in her comments on inverter-based resources relative to a dispatchable resources. She noted that 1,000 MW of offshore wind is equivalent to 100 MW of dispatchable resources in transmission security analyses. That means to replace the 2,000 MW of dispatchable Indian Point power that the State shut down, 20,000 MW of offshore wind must be deployed. Note that the Climate Act mandates 9,000 MW of offshore wind which is far less than what is needed to simply replace Indian Point.
The next question from the moderator addressed the quantity of resources necessary to address the gap. Specifically, he asked can wind, solar, short-duration solar, and improvements to the transmission system eliminate the gap. Professor Anderson explained that her team’s work found that adding more of each technology is not going to solve the gap problem. It is not just that we need more, we need it in the right places.
The moderator reflected the consensus of the panelists when he noted the New York gaps cannot be solved using existing technology because of the physical characteristics of the grid and the location of load in the state. He followed up by asking Steinburg when the gap will show up, how quickly do we need to react, and what is the magnitude of the resources necessary to respond. Steinburg said the work his group did for the Integration Analysis showed that the timing of the gap problem depends on the rate of electrification and retirements of existing fossil resources. The problem will be worse in the winter once the load peak shifts to account for electric heating and electric vehicles. Smith noted that the NYISO expects that New York will be a winter peaking system in the ”early to mid- 2030’s”.
Schyler Matteson, the moderator, pointed out that before the DEFR resources can be deployed a long period of planning, permitting, construction, and inter-connection is required. He stated that this could be on the order of seven years. He followed up with a question to Smith about how planning for the system reserve margins and the local transmission security issues most prevalent in New York City will affect the process to develop DEFR to replace existing fossil. Smith emphasized the point that this is a challenge that will require extensive collaboration between agencies. In order to address the retirement issues NYISO has instituted a quarterly “short-term assessment of reliability” process. While this reactively addresses generator deactivation notices, NYISO is also trying to consider longer-term issues. In particular, the Department of Environmental Conservation has a rule promulgated to retire old peaking combustion turbines. In that process, NYISO temporarily extended the retirement dates until reliability solutions could be deployed. Smith emphasized that a similar process needs to be incorporated as part of the Climate Act net-zero transition. Smith went on to point out that some of the DEFR required is not yet commercially available so there is even more lead time than required to simply deploy the resources. Altobell explained that there is another consideration – outage scheduling. The existing system still has to operate and the outages when changes can be made without threatening reliability are getting smaller and smaller.
The moderator gave his summary of the panel discussion and asked for comments. He said a gap “definitely exists”, that gap is flexible based on the future load characteristics, the generation mix, load profiles, and transmission constraints. The gap is starting to show up around 2035 and is definitely an issue by 2040. DEFR needs to be commercially available during the deployment planning period. Three different analyses showed that on the order of 20 to 30 GW of capacity is needed. Gaps of four maybe five days occur as much as every few years. Smith pointed out that future planning also has to address extreme events and the need for resilience.
The session ended by discussing a question raised in the chat. The question raised was how do we characterize what the maximum DEFR need is? Smith replied that more analysis is needed. He mentioned that the New York State Reliability Council is charged with addressing this issue. It is necessary to define the worst-case conditions and then decide how to design the system to deal with it. Altobell supported his comments and pointed out that the Reliability Council has an Extreme Weather Working Group that is looking at gap characteristics. They are also addressing the reliability rules that will be needed when the projected amounts of inverter-based resources (wind, solar, and energy storage) are deployed.
Discussion
At the Climate Action Council meeting to vote on the approval of the Scoping Plan Dr. Robert Howarth summarized his statement supporting his vote to approve the Scoping Plan. His statement notes that:
I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.
The position that “it could be done completely with technologies available at that time” had an out-sized influence on the Climate Action Council decision to approve the Scoping Plan. After all, if there are no technological barriers then it is simply a matter of political will.
This session is proof that this belief is wrong. The work of Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell; Zach Smith, VP System Resource Planning, New York Independent System Operator; and Kevin Steinberger, Director, Energy and Environmental Economics all found that a new resource that has all the attributes of fossil-fired peaking units but without any emissions is needed. Ultimately, the failure of the Hochul Administration to step and point out that the Integration Analysis that formed the basis of the Scoping Plan pointed out the need for this resource will have serious implications.
I have two worries. The first concern is that there are resource candidate technologies that are not commercially available. There is a long road between theory and lab prototype tests and having a technology available that can be deployed to maintain reliability. It is likely that many of the candidate technologies will fail this test. Secondly, even if the technologies are viable there are issues related to deployment time and costs. The Climate Act net-zero transition includes an ambitious schedule and there are affordability concerns. Neither issue can be addressed at this time.
A more immediate concern is the push to retire existing fossil-fired resources as soon as possible. This panel discussion showed that the belief that wind, solar, and energy storage are resources that can just be plugged into the New York City electric system to replace peaking power plants is dangerous. Those existing facilities provide much more than electric energy and wind, solar, and energy storage don’t provide those other necessary services. The session made the point that location matters and that there are spatial limitations in the City that could very well preclude development of alternative technology with different footprint requirements. Eventually, someone is going to have to stand up and tell the vocal environmental justice advocates that their demands to shut down peaking power plants cannot be met.
Conclusion
It is not clear where the Department of Public Service is going to go with issues raised at this technical conference. So far, the transition plan narrative has been based on the misplaced belief that no new technologies are needed. This gave the crony capitalists selling the wind, solar, and energy storage resources the opportunity to make the plan all about building as much as possible as fast as possible. Is there any chance that these technical issues will cause a change in direction?
For the first two months of 2024 the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) have been working on the New York Cap-and-Invest (NYCI) Program stakeholder engagement process. As part of the stakeholder engagement process there was a webinar describing the Preliminary Scenario Analyses. One thing that caught my attention was the claim that health benefits could be as much as $15.7 billion in 2035 because of NYCI implementation.
Two recent blog posts described a literature article about the development of the Linear No Threshold (LNT) model for cancer risk that is the basis of the NYCI health benefits claim. This post describes the Journal of Occupational and Environmental Hygiene paper by Edward Calabrese “Cancer risk assessment, its wretched history and what it means for public health” and the NYCI health benefits claims.
I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned. NYSERDA and DEC are attempting to promulgate rules for NYCI so that the program starts in 2025 and the regulatory package will claim significant health impacts that I think are unjustified.
The story about to unfold in this commentary will be disturbing but perhaps not too surprising now in contemporary society. You will be taken on a path of discovery that explores the history of cancer risk assessment for radiation and chemical carcinogens. This commentary is about a history of errors made by scientific leaders that have long remained hidden and uncorrected. The evidence shows that major biases led to deliberate misrepresentations (i.e., blatant dishonesties) of the scientific record by the very people society was supposed to trust, including multiple Nobel Prize winners. Equally troubling have been the dishonest actions of organizations, such as major advisory bodies, including the US NAS and the journal Science that have repeatedly succumbed to violations of the public trust. As disappointing and upsetting as such statements are, it is hard to believe that this historical record could get even more corrupt, but it does. It has become known that major US scientists conducting important mutation and cancer studies hid data and deliberately withheld results from the public and scientific community. Why? Because the findings didn’t fit their preconceived beliefs and would not enhance opportunities to obtain more funding for themselves and their programs. Yes, the destructive self-interest of the research community, especially governmental and university scientists, in this case, presents a prominent but long hidden dimension that unfolds in a complex journey of discovery.
Society is faced with questions over who can be trusted in today’s world: government, scientists, prestigious advisory groups, like the United States National Academy of Sciences (US NAS), and major journals like Science, Nature, The Lancet, and others. These have historically all been the entities that society has trusted for decades. The historical record presented here, therefore, involves powerful and high-profile individuals and groups that manipulated the public for personal gain and is presented in the following eight-part expose.
If you are interested, then I encourage you to read the rest of the SEPP newsletter and the article itself but the implications are not immediately obvious without background. Originally, I thought I would use this post as the basis for describing the background of problems identified in the Calabrese paper. However, Francis Menton wrote a post doing just what I was planning to do.
Menton notes that:
Calabrese’s article is long (18 two-column single-space pages) and goes into detail of the names involved, the particular pieces of evidence suppressed along the way, the manipulation of members of committees to get to desired outcomes, and so forth. It has a lengthy bibliography, including references to multiple prior articles of his own where he has been piecing together and building the story of the LNT fraud for years. If you are interested in this subject, I highly recommend this article.
Menton argues that this approach is a candidate for the greatest scientific fraud of all time. He writes:
This fraud goes by the common acronym of “LNT,” which stands for the “linear no threshold” hypothesis of causation of diseases, particularly cancer, from environmental factors. The LNT hypothesis is the basis for huge swaths of enormously costly regulation, probably the large majority of environmental regulatory cost outside the sphere of “climate.” In a March 7 article in the Journal of Occupational and Environmental Hygiene, a guy named Edward Calabrese makes the case that the LNT hypothesis has been advanced by means of intentional fraud since its inception nearly 100 years ago. The title of the article is “Cancer risk assessment, its wretched history and what it means for public health.”
He describes the basis of the approach:
The LNT hypothesis theorizes that if a chemical or phenomenon (e.g., radiation) is established as dangerous at some dosage, no matter how high, then it must also be dangerous at small dosages, no matter how tiny. That conclusion follows if the relation of dose to danger is linear, with no threshold below which the danger goes away. A tiny dose may have a tiny danger, but as long as the dose/danger relationship is linear without threshold, then there is no safe dose.
This approach was originally developed to address cancer risk from nuclear radiation exposure, but the principle is now applied in other ways.
Calabrese’s article provides a thorough history of the origins of the LNT hypothesis, and how it was advanced and promoted by the suppression of definitive contrary evidence. By the 1970s the LNT hypothesis had the backing of the National Academy of Sciences and had been adopted by the EPA as the basis for regulating hazardous chemicals and radiation. The EPA continues to use the LNT approach in its regulatory efforts today, even as evidence accumulates that it is wrong and has been based on fraud from the outset. And thus, the LNT hypothesis is the fundamental reason why nuclear power plants are so expensive and difficult to build; why no long-term solution for storage of spent nuclear fuel can be found; why EPA constantly proposes new regulations lowering allowable levels of emissions of chemical substances like mercury or PCBs; why pesticides and herbicides like glyphosate become the subject of multi-billion dollar liability disasters; and so forth.
Menton goes on to explain:
The LNT hypothesis may at first seem intuitively likely to be true. For example, it is established that large doses of radiation can induce mutations that can lead to cancer. So why then couldn’t a single item of radiation, like one alpha particle or a single gamma ray, induce the mutation that initiates the disease? But Calabrese points out that the LNT hypothesis presumes that mutations are rare, and that the body has no capacity to repair ongoing mutations. What research has revealed is that, far from being rare, mutations are extremely common; and the body has a large capacity to repair them. Thus, a small external source of mutations, like background or low-dose radiation, is easily dealt with, and if anything helps to stimulate and exercise the body’s natural repair system. Only when an external force causes very extensive mutations exceeding the body’s capacity to repair — i.e., when some threshold is crossed — does the external force increase the risk of cancer or other disease. From Calabrese, page 16:
[T]he most dominating cause of evolution is our metabolism which induces millions of mutations per day in each cell, with 99.99999% being repaired each day. If our repair systems were not so exceptionally good, life would not exist. Our metabolism produces about 200 million times more genetic damage events per cell per day than that induced by background radiation. There is no contest between the two. What this means is that our body is our biggest enemy; it also means that it is also our best friend. The body’s great repair mechanisms evolved not to prevent and repair damage from background radiation but to fix the damage that our metabolism induces each day. Thus, the body’s repair systems are designed by nature to protect our bodies against ourselves, with background radiation being a very tiny and insignificant factor.
Sadly, this approach is widely used and now provides “justification” for many environmental regulations. Proponents calculate a relationship between health effects at two high levels then extrapolate the dose response curve to ridiculously low levels. Even though there is a tiny effect multiplying the impact over a large population provides scary projections for things like asthma exacerbation. Menton explains why it has become so pervasive.
So how did the LNT hypothesis gain such enormous sway, and become the basis for extensive and destructive government decision-making for decades? Calabrese points out that, by contrast to the threshold hypothesis, the LNT hypothesis has the potential to induce great fear in the public, and thus to stimulate large opportunities for funding and career advancement:
[T]he experts got the radiation and chemical mutation idea wrong from the start but they convinced many that they were correct and created debilitating fear in the population at the same time. We also learned that one of the reasons that these great scientists created such fears was to advance their careers and to get a constant flow of government grant monies.
In the next section I will show how NYSERDA and DEC have used this approach for NYCI. Menton provides a good segue to that section:
Meanwhile, our government and its “experts” merrily go forth regulating on the basis of the LNT hypothesis, and imposing enormous costs on society for no benefit. From Calabrese’s Conclusion:
[The scientists who promoted the LNT hypothesis] were driven by ideological and self-serving professional biases that would lead to both falsifications of the research record and suppression of key scientific findings, all to establish the LNT model for hereditary and cancer risk assessment, replacing the threshold dose-response model. This troubling history has now been revealed in a long series of peer-reviewed publications by the author and summarized in a broad conversational manner in this Commentary. This troubling history remained hidden from regulatory agencies around the globe since its inception. These groups simply and uncritically accepted a flawed and corrupt history, assuming that it was accurate and reliable. Yet this path of historical ignorance led the US EPA, and other national regulatory agencies, to accept a dishonest foundation upon which to base and frame cancer risk assessment, terribly failing in their public service mission.
New York Cap and Invest Health Impacts
The purpose of this article is to show the basis for the projected health effects of NYCI. At the January 26, 2024 webinar the methodology for the health effects was described. In brief, fuel consumption changes by sector projected by their modeling were used to estimate changes in emissions. The changes in emissions reduce ambient air quality levels and this leads to the alleged health benefit improvements. Because the emissions estimates cannot be broken down into detail the air quality impacts also are broad estimates. EPA’s CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool uses the LNT approach to estimate health impacts, primarily for improvements in inhalable particulate matter that is 2.5 microns or smaller.
The projected health impacts description claims that there are substantial benefits.
The NYCI Preliminary Analysis Data Annex spreadsheet includes supplementary health effects data for the webinar presentation and a table that estimates impacts on air quality and health. The following table excerpts some of the health benefits projections. Frankly, I think that all these improvements are well within normal variation so the whole exercise has little value. Note that I expected that each of the benefits would be linearly proportional to the change in concentrations but applying the ratio of 2025 to 2030 improved concentrations to the health benefits did not match exactly. In all cases the assumed proportional benefit was less than the benefits shown.
Despite the lack of an exact linear match, I believe the results are close enough to use them to project health benefits between the inhalable particulate concentrations in 2000 relative to 2022. The Department of Environmental Conservation runs a network of inhalable particulate monitoring stations across the state and summarizes the results in its Ambient Air Quality Reports. I extracted the annual average concentrations for seven widely ranged sites with the longest records. All the stations show significant improvements in the inhalable concentrations over the period of record. I calculated the average of these sites in 2000 11.4 micro grams per cubic meter and 2022 6.0 micro grams per cubic meter for a statewide improvement of 5.4.
New York State Annual Average Inhalable Particulate Air Quality (micro grams per cubic meter) Trend
The following table compares the observed improvement in air quality and projects health benefit improvements proportional to the change in inhalable particulates. If there has been an observed reduction of over one million emergency room visits for asthma between 2000 and 2022 then I will believe the NYCI health benefit projections. I have never seen anyone verify this health benefit model which should be easy to do. I expect that the results would be inconvenient, and proponents of this methodology know this so it has never been done.
Conclusion
In every instance I have checked the Hochul Administration has overstated the benefits and understated the costs of the net-zero transition. New York’s cap-and-invest projected health benefits are a vivid example of how NYSERDA manipulates the narrative to claim benefits that far exceed any reasonable interpretation. I think Menton’s conclusion is an appropriate: “As of today, there is no evident retreat by EPA or other U.S. regulatory agencies from the LNT model. Fear sells, and they have no ability or incentive to self-correct.”
Paul Driessen explains why “the materials, costs and survivability for wind turbines on massive floating platforms defy reality”. I also learned more about floating turbines and wind turbines in general from the comments on this article.
I have an interest in offshore wind because the resource is a key part of New York’s Climate Leadership & Community Protection Act (Climate Act) net-zero transition plan. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Can “clean energy” schemes get any crazier?
Paul Driessen’s article notes that Federal agencies are designating area where the sea bed is so deep that a conventional offshore wind turbine won’t work.
The US Interior Department’s Bureau of Ocean Energy Management recently designated two Wind Energy Areas in deepwater areas off the Oregon coast. BOEM is also reviewing offshore wind energy development options for the Gulf of Maine, Central Atlantic, Gulf of Mexico, and maybe Great Lakes.
They’re part of Team Biden’s plan to deploy 30,000 megawatts of offshore wind energy capacity by 2030 and 15,000 MW of floating offshore wind energy capacity by 2035. Capacity is what the turbines could generate, when the wind is blowing at optimal speeds, perhaps 30-40% of the year.
I was particularly attracted to his article because he used New York as an example of to put these numbers in perspective. For the record, the Climate Act mandates 9,000 MW of offshore wind and the outline for implementing the transition in the Integration Analysis projects that the 2040 total will be 14,364 MW. Driessen notes:
30,000 MW is what 2,500 12-MW turbines could generate. It’s enough to meet New York State’s current peak electricity needs on a hot summer day. Add the electricity required to replace gasoline cars and natural gas furnaces and stoves, meet surging AI, data center and streaming video demands, and charge grid-scale backup batteries – and New York alone would likely need 10,000 12-MW offshore turbines.
Meeting the soaring electricity needs of all US states would require hundreds of thousands more.
Not unlike New Yorks shameless promotion of clean energy solutions, Driessen comments on the information accompanying the announcement:
BOEM nevertheless insists that “Offshore wind is a once-in-a-generation opportunity to build a new clean energy industry, tackle the climate crisis, and create good-paying jobs, while ensuring economic opportunities for all communities.”
Note to be outdone in baseless puffery, the Department of Energy extols the Administration’s goal of “decarbonizing” the entire US electric grid by 2035 and says “offshore wind is especially well-suited” for generating “clean energy.” Two-thirds of all US offshore wind potential, it says, exists over ocean areas so deep that turbines must be mounted on floating platforms anchored to the seafloor by mooring lines tied to suction piles sunk into bottom sediments.
DOE even claims it will somehow reduce the cost of floating deepwater wind energy to $45 per megawatt-hour by 2035. (That’s 45¢ per kilowatt-hour, triple what most Americans now pay.) To buttress its claims, DOE presents maps, artist’s renderings and images of floating turbine arrays.
These claims exhibit the same departure from reality as New York:
It’s almost as though these government officials actually believe they can solve the alleged climate crisis by simply issuing proclamations, regulations, drawings, press releases and subsidies – and Voila!
Mines open, raw materials materialize, and millions of wind turbines, billions of solar panels, billions of vehicle and grid-scale batteries, millions of miles of transmission lines, millions of transformers and other technologies get manufactured and installed – affordably and with no fossil fuels, greenhouse gas emissions, toxic air and water pollutants, child and slave labor, or other evils (all at minimal cost), while endangered species and other environmental conflicts disappear (or are relegated to irrelevance) … and cornucopias of clean, renewable, reliable, affordable electricity are rapidly generated worldwide.
Driessen describes some other issues with floating wind turbines:
12-MW offshore turbines are 850 feet tall, carry three 350-foot-long blades, and weigh thousands of tons. To date, few have been installed anywhere, none have been subjected to major hurricanes, and none have been mounted on deepwater floating platforms. Indeed, no such platform-mounted turbines exist outside the realm of concepts and ten-foot models in wind tunnels and test tanks.
The Kincardine floating turbines in the North Sea southeast of Aberdeen, Scotland are much smaller, and the strongest wind gusts recorded there were in the 83–123 mph range. Sustained wind speeds for category 3-5 hurricanes range from 111 to 157 mph and greater. Some of the worst US landfalling hurricanes reached 126 mph (Katrina, 2003) to 167 mph (Andrew, 1997). The strongest winds ever off the Oregon coast exceeded 100 mph (1962 and 1995).
Subsurface and semisubmersible structures for the smaller 2.0–9.5-MW deepwater turbines weigh 2,000 to 8,000 tons. New semisubmersible platforms for deepwater oil production can be over 30,000 tons and cost a billion dollars or more. Yet even they are probably not large enough for the monstrous 15-MW beasts that the Biden Administration, CNN and others are extolling.
The Climate Act mandates that all conceivable associated impacts with fossil fuels are considered. On the other hand the upstream impacts of the “zero-emissions” resources are ignored. Driessen points out:
It’s almost impossible to conceive of the amounts of steel and other raw materials that would be needed for each of these gigantic turbines and support systems; the amounts of ore that would have to be extracted to obtain those materials; the fossil fuels required to mine and process the ores, manufacture the turbines, blades and support systems, and transport and install them; the cost to build each of them.
Based on average deposits being mined today, the 110,000 tons of copper required for 30,000 MW of offshore turbine alone would require removing some 65,000,000 tons of ore and overlying rock. That doesn’t include copper for marine cables, transmission lines, transformers and other equipment – or the other metals and minerals.
It is inconceivable that these deepwater wind turbine systems could ever recoup all the energy and costs – or offset all the greenhouse gas emissions – involved in building them, no matter how many years they generate electricity. Indeed, those years may be very short, due to violent storms and constant salt spray.
Driessen notes that some companies are bailing out of deepwater wind projects but others are still playing the game:
That Shell Oil, among the world’s most experienced offshore oil developers, has dropped out of deepwater wind projects should say a lot about the viability of the far-fetched deepwater schemes Team Biden is promoting, to forcibly transform America’s energy and economic system.
That some companies are still in the game underscores how their risks are being forcibly subsidized and underwritten by taxpayers and consumers, who are being dragooned into these schemes by politicians and bureaucrats who likewise have no real skin in the game. Their leasing bids are plummeting, their electricity price demands soaring.
Interesting Comments
In addition to the article itself there were interesting comments at Watts Up With That. For example, the following comments provided more background information on floating wind:
Orsted have a quick guide to the 4 different types of floating offshore wind – Tension leg platform, Semi submersible, Barge and Spar buoy and their advantages and disadvantages.
That salt eats the heck out of everything-a well known fixed data point for all manner of marine (meaning ocean going) structures. Maritime ships, for example, seldom operate more than 30 years because of salt except for some military ships that carry such an abundance of high cost technology that the extraordinary cost to repair salt-induced failures is (or may be) worth it. Ships plying the Great Lakes can easily exceed 50 years or sometimes much more, until their basic economic parameters are exceeded by more recent technology.
Wind turbines fixed in the ocean’s bottom are equally subject to the mayhem caused by salt air in addition to the vagaries of wind speed and direction. Currently, because of these vagaries failure of gears and bearings are the major cost centers in keeping such machines operating. Mount them on floating barges and you add increased bearing and gear loading from the pitch, roll, rise and fall of the barges. Even more maintenance will be required. Yes, maritime ships survive such motions but the bearings and gears (if any) are specifically designed to do this and are truly massive structures, far too heavy to be mounted at the top of a 400 foot tall pole. If the Biden politicians think they barge mounted turbines are a good idea, at the very least, they could build just one or two and see what happens in 10 years before building hundreds.
Their proposal to do the latter is truly truly nutty.
I am not a structural engineer, but I can just imagine the torsional loads an 850-foot-tall wind turbine puts on the tower structure and base. The mooring cables would be under tremendous stresses. This paper explores the bucking loads on towers, the most common failure of wind turbines.
Torsion is twisting, you can imagine a torsion load if you picture a stuck drill bit or a drive shaft on a car. The bigger load is bending, which is the loading best imagined by the picturing the centre section of the beam in a see-saw. Bending loads try to change the shape of straight beams into bananas, etc.
Since the wind turbine nacelle is going to rotate to orient it into the wind, the torsion loads can be managed. It would be significantly worse if the nacelle was incorrectly aligned, with the blades aligned so that the rotating axis of the fan was at 90 degrees to the wind direction. This would result in large torsion loads but is still quite simple to disperse to the foundations.
The issue I see, with a three bladed fan, is that on every rotation two blades will be on one side and then as the top blade swings over, there are then two blades on the the other, etc This will set up a cyclic torsion load, an even number of blades would have eliminated this load. Strange they did this, cyclic loads lead to fatigue.
I’d be more concerned about BENDING loads, eg the ones caused by a horizontal force applied at the top of a post. These forces get larger as the length of the post increases, or as the load increases. Both obviously increasing as the demand for larger fan diameters and taller towers materialise from the dreams of the renewable fraternity.
And of course, no matter what wind speed you design for, sooner or later that speed will be exceeded, it’s just a matter of time. If we are forced to build them, then who gets to pick up the pieces. With heavy falling objects, NIMBY has real meaning, especially if you are in the drop zone.
In the following comment Rud Istvan addressed the effect of increasing wind speeds with height. One meteorological phenomenon that I have not heard much about is a nocturnal low-level jet. Wind speed varies with height due to surface friction. At times nocturnal radiational cooling decouples the mixed layer from upper layers creating a layer of notably higher wind speeds above a relatively calm layer. The description below of turbine wobble has to be exacerbated during these conditions.
The primary failure mode of big onshore wind turbines is axial bearing failure. The problem is inherent, since wind speed is higher aloft so the bearings wobble as each of the three blades reaches peak height.
Any wave induced sway on a floating offshore turbine makes the wobble problem worse and axial bearing failure earlier and less predictable. Beefier bearings have not solved this problem onshore; they for sure wouldn’t offshore.
Not a wild guess, just very good intuition.
The final comment did not directly address floating wind but was too good to not include. One of the hidden challenges of the net-zero transition is staffing.
The one ‘Reality’ that almost everyone misses entirely is the workforce required to achieve everything necessary to reach all this wondrous ‘decarbonisation’.
A report recently written by Michael Kelly, the inaugural Prince Philip Professor of Technology at the University of Cambridge, Fellow of the Royal Society and of the Royal Academy of Engineering exposed this a few years ago, and nothing has changed since.
In the UK, at least, we have one third of the skilled workforce to conduct all the changes required by trained engineers, builders, technicians etc. and our education and training system is not geared up to provide more, and won’t be for many years even assuming changes are made now.
A traditional solution to this would be to attract immigrant workers from the continent. The problem here though is, Europe is also short of their own labour to achieve their decarbonisation goals.
The UK’s usual fallback solution (and it’s been done many times before) is to announce to the public, with great fanfare, a job creation scheme where they will launch vocational training at local tech. colleges. Lots of votes in that particular scam.
The routine is, a whole bunch of youngsters are recruited to train up as technicians at local colleges. They recognise an opportunity so rush out and recruit a few untrained mates, start a business to do the rudimentary work like home insulation and perhaps even installing Heat Pumps.
We have seen it all before with the 1970’s double glazing scam, the 1990’s cavity wall insulation scam and the 2010’s domestic Solar Arrays (as they were grandly called) and it all ends with the same result. Thousands of householders spending lots of money to wind up with lots of problems and innumerable Cowboy business suddenly going bust because, well, that’s what Cowboy businesses do. Guarantees are worthless, even if underwritten by the government because the installation was substandard and of course, the government won’t cover that. Caveat emptor.
It takes years for this to manifest itself as an abject failure and the MSM will be recruited by the government to tidy up the loose ends with recognition of the phenomenon, a few cases won in court, and then nothing. It’s all forgotten about.
We already have a shortage of STEM qualified individuals who will be required to deal with the enormous demands of the commercial wind and solar industry. Of course, universities will suddenly take a great deal of interest in STEM subjects instead of Phd’s in Macramé or flower arranging.
Evidence of all this?
My middle aged son landed a job to monitor small scale wind turbines remotely from home. A laptop in his living room. He was a failed musician, dropped out of his college course as an electrician, but excelled as a short order cook in a sandwich bar. He now believes he knows everything there is to know about wind turbines and is, naturally, an passionate advocate for the cause of climate change.
I hasten to add I had no influence on his formative years whatsoever.
These are the rocks the climate scam will perish on, not the theory or counter theory of whether or not CO2 causes warming, it will be the practicalities of implementing the solutions to it.
Conclusion
I published this article because it provides great background information on floating offshore wind turbines. Fortunately, no one has proposed any for New York yet but there probably is some location serving New York where someone will claim this technology is needed.
I concur with Driessen’s conclusion: “It’s time to say, “Enough! We’re going to keep our nuclear and fossil fuel energy, until you prove beyond a reasonable doubt that your alternatives provide equally abundant, reliable, affordable energy.”
Bud’s Offshore Energy blog highlighted a new national energy report card that is of interest to readers here. According to the Mackinac Center press release the report ranks energy sources by ranking eight key energy resource types “based on their ability to meet growing demand for affordable, reliable, and clean energy generation”. The report concludes that “natural gas and nuclear power lead the rest of the class in generating clean and affordable energy”.
Unfortunately, the impractical Climate Leadership & Community Protection Act (Climate Act) mandates a transition to an electric system with zero greenhouse gas emissions heavily reliant on wind and solar. The report card gives wind and solar failing grades so this report is relevant. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Bottom Line Up Front: Each ranking area graded the energy resource on a scale of 1 to 10. If an energy source performed poorly, it received a 1, if it performed well, it received a 10.
The scores in each section were totaled and broken down from 1 to 50. The energy source was given a final letter grade of A to F based on its score out of 50. The grading system results in a comparative ranking that describes the energy resource as excellent (90-100 /A-range), very good (80-89/B-range), average (70-79/C-range), poor (60-69/D-range), and Failure (59 or below/F). This methodology is roughly based on the American Society of Civil Engineers’ methodology described in the annual “A Comprehensive Assessment of American’s Infrastructure: 2021 Report Card for America’s Infrastructure” document.
The score card evaluated each energy source for five ranking areas:
Capacity and Reliability: We estimated the capability of this energy source to produce sufficient energy to meet demand. We also considered how plans to maintain existing (or build new) infrastructure and capacity will meet growing energy demand.
Environmental/Human Impact: We asked what are the environmental impacts, the human rights, or other labor issues associated with using this energy source.
Cost: We asked how the energy source competes with other energy sources in terms of pricing.
Technology and Innovation: We asked what technologies are used and what new technologies are being developed for this energy source.
Market feasibility: We considered whether the energy source relies on free-market forces to supply energy to the public. To what extent do subsidies and/or government mandates drive its adoption and use?
The report includes recommendations for policies that could be implemented to improve this sector’s performance.
Energy Sector Rankings
The report card, ranked by the final grades, puts natural gas and nuclear at the top of the class.
The Executive Summary of the report includes a summary for each energy sector that describes the ranking rationale.
Natural gas tops the energy sectors because it not only provides electric energy but also provides the ancillary support services necessary for the transmission system at a relatively low cost. Aside from the irrational obsession with over hyped greenhouse gas effects it also has a low, albeit not zero pollution impacts. I agree with the concern that reliability would be improved with on-site storage.
Natural gas: 94 % (A)
Natural gas is at a unique position in our energy supply.
The nation has experienced rapid growth in energy demand for a range of activities: electricity generation, home heating, transportation, manufacturing, etc.
As governments around the nation attempt to impose a transition from traditional energy resources to energy sources often referred to as renewables, natural gas is the energy source that is best suited to integrate with the intermittency inherent in the use of wind and solar. Gas provides a reliable, affordable, and increasingly clean source of energy in both traditional and “carbon-constrained” applications.
Gas faces headwinds in the form of increasingly extreme net zero energy policies that will constrict supplies if implemented as proposed. Gas could also improve overall reliability if onsite storage was prioritized to help avoid supply disruptions that can occur in just-in-time pipeline deliveries during periods of extreme weather and demand.
The second highest energy sector was nuclear. The report card recognizes its zero emissions, that it provides electric energy and ancillary support services necessary for the transmission system, and that it is mature technology with the potential for extensive deployment. Were it not for high development costs and market feasibility issues it would undoubtedly be the highest rated.
Nuclear: 88% (B+)
Nuclear energy represents a best-of-all-worlds energy resource for the United States. Given its history as the nation’s safest and most reliable electricity source and its ability to produce near endless amounts of completely reliable and emission-free electricity, nuclear is an obvious choice, especially given the nation’s current hyper-focus on net zero carbon dioxide emissions.
Nuclear’s primary challenges lie in two areas: initial costs and concerns over safety related to fuel storage or the potential release of radioactive materials.
First, while initial costs to build can be high, they can be amortized over a 60- to 100-year expected life cycle. Additionally, costs can be addressed by reigning in the overactive nature of the Nuclear Regulatory Commission. Second, the industry’s record demonstrates it is the nation’s safest source of electricity.
Perhaps no better example of this technology’s safety, reliability, and usefulness exists than the nation’s fleet of nuclear-powered aircraft carriers, submarines, and cruisers. Building on Admiral Rickover’s innovations, the U.S. Navy has reliably and safely powered a significant portion of its fleet with nuclear power for decades. As we have done in many other areas, it is possible to use the knowledge gained in this area in the civilian nuclear fleet.
Given the safety and reliability of both our military and civilian nuclear, concerns over meltdowns or having the fuel used to build nuclear weapons are more in the realm of science fiction than reality. The United States was once the world leader in developing safe, reliable nuclear technologies. We should focus on rebuilding that status.
Coal and hydroelectric are ranked next with the same with a total of 40 points. I think that ranking by electric system characteristics and not weighing environmental impacts is the reason.
Coal is a mature technology that provides electric energy and ancillary support services necessary for the transmission system and has the potential for extensive deployment. I would have ranked the capacity reliability a point higher because coal can be stored on-site and that I think is an important characteristic too often overlooked.
Coal: 80% (B-)
Despite its low cost, abundant domestic supply, and reliability, Western nations—USA, Canada, UK, and across Europe—have targeted coal for closure largely due to climate change concerns. While most pollution concerns associated with coal use can be addressed with widely available emissions reduction technologies, coal does emit more pollutants and CO2 than natural gas.
Due to growing regulatory pressure and effective competition from low-priced, domestic natural gas, coal use is declining in North America, as well as Europe. However, coal use worldwide— especially China and India—continues to grow rapidly. Across Asia, coal use is growing so rapidly that attempts to cease its use in the West as a climate change mitigation measure are being wholly eclipsed.
The primary challenges faced by the coal industry are 1) a long-term campaign on the part of government and green special interests to stop its use, and 2) very effective competition from low-cost fracked natural gas, which is displacing coal as a primary baseload generation option.
The grading for conventional hydroelectric recognized this is another mature technology that provides electric energy and ancillary support services necessary for the transmission system. Unfortunately, there is little potential for further deployment and the current plans to destroy hydro dams are inconsistent with the supposed need to fight the “existential threat” of climate change. In my opinion that is almost as stupid as shutting down nuclear plants prematurely.
Conventional hydroelectric: 80% (B-)
Hydroelectric is the one form of renewable generation that is completely dispatchable and has no emissions associated with its operations (compared with biomass).
While hydroelectric would seem to meet most of the tests of the environmental movement, it is often targeted for removal because it requires a great deal of bulk material in its construction and interrupts or changes natural river flows and floods riparian zones (displacing wildlife and human inhabitants). Given the expansive nature of large hydroelectric facilities, it is unlikely that any new developments could be permitted in North America.
In my opinion petroleum fuels were a bit under-rated. This is another mature technology that provides electric energy and ancillary support services necessary for the transmission system. Admittedly it is important in limited areas but provides critical support in those markets. However, I agree the potential for any further development is very low.
Petroleum fuels: 70% (C-)
Petroleum products play a very small role in the production of U.S. electricity. They are almost a rounding error and are used primarily in older or geographically limited areas (like t
the Hawaiian Islands or Northeastern markets because of historical use).
I probably would have rated geothermal closer to petroleum fuels. As noted, it suffers from the same lack of potential development.
Geothermal: 66% (D+)
Geothermal plays a limited role in the production of U.S. electricity. Much like petroleum products, geothermal is almost a rounding error and is used primarily in geographically limited areas (like the Western states and the Hawaiian Islands)
Wind and solar receive failing grades. Both are rated lowest for similar reasons. When they are compared to the capability of the other energy sources to provide sufficient energy to meet demand the need for energy storage and supporting ancillary services, they are appropriately ranked lowest. Even though they are zero-emissions resources there are “numerous other grid reliability, environmental, economic (or cost), and social issues associated with its use that are often overlooked”. The Climate Act explicitly mandates that every conceivable impact associated with fossil fuels are considered but does not require consideration of these issues. When human rights impacts are included, they should be rated lower than the other sources. Wind and solar are only relatively cheaper if the costs to provide reliable energy and transmission system ancillary services are ignored. I think this ranking correctly scores this category. The technology/innovation category recognized that there are limited opportunities to improve the energy output. The market feasibility scoring considered “whether the energy source relies on free-market forces to supply energy to the public.” I do not believe that wind and solar could survive without massive subsidies so believe this scoring is appropriate.
Wind: 56% (F)
Wind is one of two so-called renewable energy generation sources widely promoted for its claimed ability to reduce the environmental impacts of electricity generation. Wind is marketed as being able to reduce carbon dioxide emissions, protect the environment, reduce electric rates, and improve grid reliability.
While it is true that wind does not produce carbon dioxide as it produces electricity, there are numerous other grid reliability, environmental, economic (or cost), and social issues associated with its use that are often overlooked.
Given that society increasingly relies on a steady and reliable supply of affordable energy, government policies that mandate and heavily subsidize a transition to wind generation represent a growing threat to human health and well-being.
Solar: 58% (F)
Solar is the second of two so-called renewable energy generation sources (wind is the first) widely promoted for its claimed ability to reduce the environmental impacts of electricity generation. Like wind, solar is marketed as being able to reduce carbon dioxide emissions, protect the environment, reduce electric rates, and improve grid reliability.
Like wind, solar does not produce carbon dioxide as it produces electricity. However, there are numerous other grid reliability, environmental, economic, social, and human rights issues associated with its use that are often overlooked.
Given that society increasingly relies on a steady and reliable supply of affordable energy, government policies that mandate and heavily subsidize a transition to solar generation also represent a growing threat to human health and well-being.
This summary of the report is only an overview. The report is comprehensive with 107 pages of text. There is extensive documentation with 297 references. As a result, the rationale for the scoring is extensive.
Conclusion
The conclusion of the report states:
Demands for a hurried transition from conventional, reliable energy sources to unreliable and expensive renewable alternatives are threatening the reliability of the North American electric grid. Pushing for increased efficiency and improved environmental performance is a laudable (and achievable) goal. However, we cannot allow misplaced environmental zeal to obscure electricity’s pivotal role in promoting human health and well-being and powering our society.
Advocates for wind and solar hold them up as essential to environmental and climate health. However, rushing a systemwide transition to these untested and unreliable energy options puts human lives and the North American economy at risk. Their inherent intermittency will strain the ability of the grid to meet growing energy demands and the ability of ratepayers to cover the high costs they impose on the grid. In contrast, the reliability and affordability of fossil and nuclear fuels cannot be ignored. Admonitions from grid managers warning about the dangers of rushing to close reliable sources of electricity generation only serve to highlight the risks associated with the premature rush to transition to wind and solar.
This research demonstrates the high environmental and economic costs of hurrying the grid transition. While fossil and nuclear fuels do have environmental costs, we also have the technological capacity to address those costs as we continue to trust their unparalleled reliability for essential energy services.
Wind and solar energy have been marketed as a means of having our energy and environmental cake and eating it, too. We are told they are clean, cheap, and reliable. However, a closer look at their real costs, growing environmental impacts, and questionable human rights records leads to serious questions about their ability to serve as a realistic energy option.
Transitioning a service as important as the nation’s electric grid cannot be rushed. It requires a far more careful and pragmatic approach than we see from elected officials and utilities nationwide. The rushed transition is neither reasonable nor prudent and must be reconsidered.
I agree with these conclusions. The point about wind and solar that “rushing a systemwide transition to these untested and unreliable energy options puts human lives and the North American economy at risk” is particularly relevant. New York’s electric system has unique features that are incompatible with the intermittent sources of power except at extraordinary costs for backup resources for worst case conditions.
I recently covered an article by Ken Girardin who broke the story of New York’s latest attempt to shore up public support for the Climate Leadership & Community Protection Act (Climate Act). In brief, the New York State Energy Research and Development Agency (NYSERDA) are hiring a public relations outfit, using $500,000 per year of public money, to “maintain a positive narrative” and “respond to negative viewpoints” about the state’s Climate Act. This article shows the likely result of that effort – NYSERDA’s Think You Know Solar – Take the Solar Quiz.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. I have devoted a page to solar issues that describes my concerns with solar development in New York. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. Despite the enormous impacts to energy affordability, threats to electric system reliability, and mandates affecting personal energy choices I believe many New Yorkers are unaware of the law. In 2023 transition recommendations were supposed to be implemented through regulation, Public Service Commission orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.
Solar Quiz
On March 21, 2024 I received an email announcing the Solar Quiz. This link is the web view version. In the rest of this section, I respond to its contents.
The quiz opens with the obligatory picture of roof-mounted solar panels.
The cheerful opening introductory paragraph leads off with the narrative: “free and abundant light” gives us electricity” from this “incredible clean energy technology”.
You may already know that solar panels convert the sun’s free and abundant light into electricity. Pretty great, right?
So, we thought we’d give you a quick quiz to test your solar smarts. Let’s see how much you really know about this incredible clean energy technology.
Sunlight may be a “free” energy source but there are costs to collect and use that energy. That detail must be in the next quiz which will come out when the geothermal energy source from Hell freezes over.
The entire Climate Act legislation and narrative is characterized by black and white cartoon descriptions. Consider the first quiz question:
Q: Do solar panels work on cloudy days?
A: Yes!
Because the panels collect light, they still function on cloudy days even though efficiency is somewhat reduced.
“Somewhat reduced”? A negligible amount or a lot? Let’s take a look at the potential range.
Their illustration:
My illustrations of today’s views from the NYS Mesonet Buffalo meteorological station. This site is notable because it is surrounded by solar panels. I am not sure how much that affects whether the meteorological data collected are representative but it does let us address the question of solar variability on this worst case condition – cloudy and snow covered.
Buffalo March 23, 2024 14:15:28 UTC or 10:15:28 EDT
Buffalo March 23, 2024 17:20:27 UTC or 13:20:27 EDT
Here is a graph of the temperature (red, orange), dew point temperature (green), and solar insolation (yellow) over the last seven days ending 23 March 2024 at 16Z or Noon EDT. Regrettably the parameter of interest is in yellow.
Note that solar insolation is 170 watts per meter squared (W/m2) at 10:15 EDT in the first picture and 420 W/m2 at 13:20 EDT the time of the second picture. Reasons for the difference include the tine of day because the second picture is closer to solar noon and the clouds are darker which could mean they are thicker in the first picture. It would be interesting to see the effect of the snow on the panels if data from that solar facility could be obtained.
To guess the effect of clouds I looked at the last seven days of data from the same site. I have put arrows on the peak solar insolation for the last six days. Presumably there were three days without clouds because the solar insolation exceeded 800 W/m2. There were two days when the peak insolation was around 500 W/m2, one day when the peak was no more than 350 W/m2, and on the most recent day it appears that the data from the daily graph peaks a little over 400 W/m2. I guess the point is that even on a cloudy day solar power is “Somewhat reduced” to half and does not go to zero. I am sure that some power would be generated even when the panels are covered by snow but the reduction sure is more than “somewhat” reduced, closer to nearly zero is my guess.
Of course, solar is zero at night. Not to worry the solar quiz addresses this.
Q: If I have solar panels, will my house still have energy at night?
A: Yes.
Solar-powered homes collect excess energy and pass it to the grid for future use, and if you don’t have excess energy stored you pull energy from the grid at any time, like when it’s dark. Another option for night-time energy use is on-site battery storage, which collects excess energy and saves it for when it’s needed.
This is egregious misinformation. The electric system instantaneously balances load and generation. Any excess energy passed to the grid has to be used at that time or stored. In my opinion the worst subsidy for residential solar is the unacknowledged cost to provide grid energy when the sun does not shine. Somebody else is paying for the infrastructure (storage or alternative sources) necessary so that solar-equipped residences can “pull energy from the grid at any time”. Inevitably the “net-metering” rules will have to be changed so this subsidy is reduced or eliminated. The mention of on-site battery storage is a start, but the reality is that the largest reliability cost is associated with extreme conditions and providing enough solar panels and energy storage to start to address that problem is uneconomic for an individual. If this was not the case, then folks would be going off the grid entirely.
The next question has no interest to me:
Q: When was the first solar panel installed?
A: In 1883, by American inventor Charles Fritts in Manhattan.
Solar energy (the photovoltaic effect) was discovered in 1839 by Edmond Becquerel, a French physicist who studied light.
The next question is relevant. Consistent with the rest of the quiz the answer provides no nuances or specific information.
Q: How long do solar panels last?
A: About 25 years
The efficiency of solar panels decreases over time. However, a lot of factors contribute to lifespan, such as weather, installation, maintenance, and quality.
The narrative answer is that “most residential solar panels should operate for 25 years before degradation (or reduced energy production) is noticeable.” The National Renewable Energy Laboratory notes that “the rate of degradation is typically around 0.5% to 0.8 % per year but varies among different types and brands of solar panels.” If I define “noticeable” degradation as a 10% loss of efficiency, then at 0.5% per year the degradation is noticeable at 23 years and at 0.8% per year the degradation is noticeable at 15 years.
The next quiz question addresses solar panel land use.
Q: What is it called when land is used for both solar panels and agriculture?
A: Agrivoltaics
In some places, farmers are experimenting with grazing livestock (solar grazing), growing native grasses, and even fruits and vegetables around solar panel installations.
Sounds great. Note that they did not talk about agrivoltaics in New York. There is a reason. The State has set up the New York State Agricultural Technical Working Group to address this in New York but there has been no progress mandating this approach. As I will explain in the following discussion, I am unimpressed with that effort.
The last question in the quiz manages to get in a bit of bragging.
Q: Which U.S. state is the top community solar market in the country?
A: New York!
As of December 2023, more than two gigawatts of community solar have been installed in New York – enough to power nearly 400,000 homes.
Of course the point that they can power 400,000 homes only when the sun is shining is unmentioned.
New York’s Disgraceful Solar Implementation Record
So much for the quiz. How is New York’s solar implementation policy going?
I believe that the development of solar resources is considered above all other concerns which will not end well. I submitted comments on the Draft Scoping Plan two years ago calling for a moratorium of utility-scale solar development because the New York State Department of Agriculture and Markets (Ag & Market) policies on solar energy projects that protect prime farmland were being ignored and programs designed to protect prime farmland and reduce impacts were being developed but not implemented. Two years later the policies are still being developed and I estimate that 20 projects have permits to construct and only seven meet the Ag & Markets policy.
In their comments for solar project applications the Department of Ag and Markets prepared testimony has noted that “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.” The lack of a responsible solar implementation policy has meant that of the 20 projects with applications only seven meet this criterion as shown in my Solar Project Scorecard. These results show that it is possible to protect prime farmland, but that New York State has failed to mandate that all projects meet the reqirement. As far as I can tell, there are no provisions in any of the permitting requirements that mandate farmland protections consistent with Department of Ag & Markets recommendations.
If there are no specific requirements for protecting farmland then what about other mitigation strategies. One responsible solar siting mitigation strategy would be to combine agriculture and solar land use – agrivoltaics. Last October, the report Growing Agrivoltaics in New York was released.
The report outlines the results of a limited literature review to advance understanding of opportunities for agrivoltaics by reviewing New York State’s current agricultural landscape; the current situation of agrivoltaics pilots and programs; and solar design considerations related to integration of agricultural activities and solar power generation. In aggregation with additional State efforts to understand land-use implications of large-scale solar (LSS) development, results inform potential future actions to provide education on best practices for implementation of agrivoltaics projects in New York State.
The report provides good background information. It includes a good description of the permitting process. It mentions the New York State Farmland Protection Working Group which was formed in 2021 “to consider and recommend strategies to the State on the siting process of major renewable energy facilities and to minimize the impact of siting on productive agricultural soils on working farms”. It also notes that additional agrivoltaic research has been proposed. They managed to come up with a definition:
A simultaneous use of land for solar photovoltaic power generation and agricultural production of “crops, livestock, and livestock products” as that phrase is defined by Agriculture & Markets Law (AML) §301(2).
I am unimpressed because the report is long on research recommendations and short of any sign of urgency to implement anything.
The fact is that the drive to install as much as possible as quickly as possible is affecting agricultural lands across the state and local communities. One of the readers of my blog, Lenny Prezorski from the Cold Spring Farm in Schoharie County recently wrote me a note. The following is a lightly edited version.
Schoharie County like much of rural NY, is losing prime farmland to solar development. One project is under construction and another is seeking approval from ORES.
Last week our state and local officials held a news conference at the Salisbury dairy farm which adjoins the NextEra East Point solar project in the Town of Sharon. A number of impacts were discussed. This news article details those concerns. For example, the highway superintendent has been fighting with solar contractors since the project started. His efforts to correct the damage to town roads have fallen on deaf ears in Albany. Despite the claims from the developer, they continue to do as they may with no oversight.
On the same day as the news conference our local newspaper ran an article noting that the property for the project was up for sale. The article notes that the parcel has “1,100 acres on a working, income-producing farm, with a log cabin home, and “seeping vista views” stunning views of both the Mohawk Valley and Catskill Mountains.” However, There’s just one catch:
Three hundred thirty five of those acres, across eight parcels, are covered in solar panels as part of NextEra Energy’s 50-MW project mostly off Route 20 and Gilbert’s Corners Road, but also Pomella, Beech and Sakon Roads.
Coldwell Banker is listing the site at 485 Gilberts Corner Road for $15,350,000; the listing went up February 20.
The site, according to the description “is one of the largest working solar farms in all of New York State, secured by a 25-year lease with guaranteed lease payments totaling in excess of $20 million.
“This property portfolio consists of over 1,000 acres of farmland and solar arrays on eight separate tax parcels—including a working farm with barns and residences.
“The largest portion on this income-producing portfolio is from the 25-year lease on the solar panels, covering 355 acres.
Prezorski continues:
How deep are the pockets that these projects can be sold, I assume at a profit, before they are complete? I understand that Rock District Solar in the Town of Carlisle has been sold 2 or 3 times and it hasn’t even received approval.
It is too late for the Town of Sharon but it hopefully isn’t too late for the proposal in Carlisle.
Prezorski describes problems with the accelerated permitting process.
Rock District attempted to get local approval from the Carlisle Planning Board. During the public comment period I submitted a detailed report which exposed errors and omissions in the Environmental Assessment Form. Once appraised of these facts they immediately withdrew their application from the town and submitted it to Office of Renewable Energy Siting. I’ve prepared a report which primarily focuses on the loss the prime farmland and potential impact to groundwater resources in our karst landscape.
The EAF located the project in the wrong watershed. It neglected to document that runoff from the site flows directly into a sinkhole which feeds the longest cave system in NYS. The application submitted to ORES contains the same erroneous data. How do we ensure that NYS follows their own laws? This is the question I posed to our local leaders and to you too.
Unfortunately, I do not have any answer for the question how do we get the state to follow our own laws.
Concluding Remarks
The Think You Know Solar – Take the Solar Quiz is an example of mis-misplaced priorities of the Hochul Administration. The cute little public relations quiz demonstrably misinforms the public. Sunlight may be a “free” energy source but the costs to collect and use that energy are ignored. While it is encouraging that solar panels can generate electricity even on cloudy days the implications of reduced output are not addressed. Claiming that solar panels last for 25 years ignores that they are also expected to generate 10% less power in a shorter period. Finally, the answer to the question “will my house still have energy at night?” displays a lack of understanding of how the electric system works and downplays the enormous challenge and costs to provide that energy that are not covered by residential solar owners.
Meanwhile, back in reality the article describing the local stakeholder concerns with the state’s control over solar farm projects describes what is happening away from Albany. As noted previously, the developers are affecting roads and not fixing damage. The state is over-riding local code enforcement and safety issues are evident. In order to expedite renewable development, the State has implemented new permitting requirements that over-ride landowner rights and local government control.
I believe that this situation has led to a disgraceful solar siting process. Despite assurances prime farmland is not being protected. Proponents of “responsible solar siting” that includes things like agrivoltaics are long on talk and promises of more research but short on urgency to do anything to implement something. Prezorski explained that the expedited permitting process is enabling errors that could have significant consequences. Finally, the state has no requirements that the solar developments are constructed to meet the Scoping Plan performance expectations. As a result, even more solar development will be required to meet the generation and capacity requirements.
No amount of public relations investment to spin stories to be consistent with the Hochul Administration narrative are going to be able to hide the reality of the disgraceful utility-scale solar siting policies. Those policies are going to cause much more harm than acknowledged by the State.
This post was originally posted at Watts Up With That. Special thanks to Charles Rotter for using AI to create this fantastic cover picture used at WUWT.
This is another article about New York’s climate “leadership” that I fear will trickle down to a state near you. Ken Girardin from the Empire Center breaks the story of New York’s latest attempt to shore up public support for the Climate Leadership & Community Protection Act (Climate Act). This article explains that the State “is especially concerned about certain areas of the climate program, noting they should be able to “immediately address emerging unforeseen events that draw media scrutiny”.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. Despite the enormous impacts to energy affordability, threats to electric system reliability, and mandates affecting personal energy choices I believe many New Yorkers are unaware of the law. In 2023 transition recommendations were supposed to be implemented through regulation, Public Service Commission orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.
NYS Seeks Spin Doctor To Fight Climate Law Critics
Girardin discovered that the New York State Energy Research and Development Agency (NYSERDA) are hiring a public relations outfit, using $500,000 per year of public money, to “maintain a positive narrative” and “respond to negative viewpoints” about the state’s Climate Act.
NYSERDA has been charged with supporting the technical analyses that are supporting the development and deployment of the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. Many aspects of the transition are falling behind, and the magnitude of the required actions is coming into focus. As a result, enough questions are being asked that the State has decided it needs to respond.
public relations professionals or public relations firms interested in providing public relations/communications services to advance the goals of NYSERDA and the Climate Leadership Community and Protection Act (Climate Act) by building awareness of and support for the Climate Act and assisting in developing a narrative around New York State’s clean energy and climate priorities and providing rapid response communications services, if necessary.
He describes the genesis of the problem and current situation:
The law was passed without anything close to a cost estimate or feasibility study, and five years into its implementation, the Climate Act has created headaches for state officials. Among other things, the state Department of Environmental Conservation has blown off a statutory deadline to implement related regulations that would, among other things, ban replacement gas appliances and fossil-fuel furnaces and impose an economywide tax-like charge on businesses responsible for greenhouse gas emissions.
None of the reports or analyses have provided a transparent full disclosure of the assumptions, expected emission reductions, and costs for the implementation of control strategies. What is clear however is that NYSERDA has glommed on to the Climate Act funding as much as possible. NYSERDA’s payroll has doubled in the past decade. It already gets funding from a range of grants, taxes and energy-related charges, and Girardin notes that it’s not clear which would be used to fund this contract.
NYSERDA already has a sizable communications and marketing operation so this push to bring in outside help is remarkable. Girardin suggests that this proposal is tasked to what the State policy makers must think is a real problem:
The RFP doesn’t just want someone to promote the Climate Act. It specifically seeks someone who can “rapidly respond to negative viewpoints and perceptions about the State’s climate and clean energy goals under the Climate Act, the costs associated with the Climate Act, and challenges to particular policies and programs.”
Clearly, you can only hide the impacts to the state of a complete transformation of the energy system in the state for so long. Girardin points out that NYSERDA posted the RFP two weeks after a report from the Empire Center showed “how state officials had violated the law, misrepresented Climate Act costs and made fanciful assumptions about how the electric grid would function in 2030.“ I am not the only one who has been making similar arguments for many months so it is not surprising that these issues are getting traction despite the efforts of NYSERDA to date.
I thought Girardin laid out a strategy to raise issues when he described the primary concerns of the request for proposal (RFP). If these are their issues of concern then pragmatists like me should be strengthening our arguments about these topics.
The RFP suggests NYSERDA is especially concerned about certain areas of the climate program, noting they should be able to “immediately address emerging unforeseen events that draw media scrutiny” in areas including:
“Questions and concerns on affordability for New Yorkers and direct costs to ratepayers as a result of the State’s clean energy and climate transition” including the cost of the planned “cap-and-invest” system.
“Concerns related to the cost and practicality of supporting building decarbonization, the implementation of codes for same and a phase out of fossil fuels in new construction;”
“Concerns related to transitioning cars, trucks, and SUVs sold in New York to zero emissions, and requiring all school buses in operation in the state to be zero-emission by 2035;” (This last policy, required by a separate state law, has given school districts sticker-shock, both with the cost premium of electric models and the unexpected cost of electricity infrastructure upgrades).
“Challenges with the lithium-ion batteries and the scale up of stationary battery storage systems, as well as related fires, safety issues, and the work of the associated working groups.”
Girardin lays out an argument why this RFP is troubling at a higher level that I think is irrefutable.
Encouraging people to use less energy or to participate in state programs can serve the public interest by lowering costs for everyone or improving grid reliability. And educating them about a law’s existence to increase compliance is one thing, but spending public funds to “build support” and challenge accurate criticism sounds more like political speech that taxpayers should not be compelled to fund. If not unconstitutional, it certainly is illiberal.
What would the response have been if Governor George Pataki had used funds seized from low-level drug offenders to hire flacks to “maintain a positive narrative” that the Rockefeller drug laws were good and shouldn’t be changed? Or if an upstate county had used sales tax revenue to buy billboards to reduce support for the Climate Act, perhaps by telling residents how Climate Act programs to benefit New York City will soon be funded with hidden charges on their electricity bills?
It’s easy to imagine the—justifiably—breathless tantrums that would have ensued if a different administration had used NYSERDA funds to pressure lawmakers to repeal the state’s ban on natural gas fracking or obstacles to new nuclear power plants.
One of my biggest problems with the state’s implementation plan is the failure to acknowledge the misleading cost-benefit descriptions. Girardin shares my concern:
NYSERDA deserves extra skepticism because the state has gone to great lengths to keep people in the dark about the Climate Act. Legally required cost estimates for Climate Act programs were never released and the revised State Energy Plan, which would show where costs are headed, is several years overdue. NYSERDA spent a year in court fighting to block the release of a Cuomo-era study which appeared to raise doubts about the costs and feasibility of the state’s climate agenda.
He concludes that reality will eventually win out:
Ultimately it matters little what people are told about the Climate Act, by NYSERDA or otherwise. New Yorkers will in short order face higher fuel costs, higher property taxes, higher compliance costs and higher electricity rates, interspersed with news about businesses either leaving or cancelling investments because of energy concerns.
The Climate Act, on its own, will tell people exactly how it works. And that might be what NYSERDA fears most.
Conclusion
As a New Yorker this is yet another embarrassment. The State’s narrative is that everyone is on board with this fantastic plan that will “encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented”. It is not clear whether a plan that requires a spin doctor can serve as an example to others.
Despite the embarrassment it is encouraging that the State is scared enough that they have to go this route. The folks who have ignored this law are starting to wake up as the implementation plans roll out. Hopefully this is a sign that the inevitable pushback is starting.
I recently published an article about the difference between weather and climate that was in response to a friend who consistently links weather events to climate change on his Facebook account. The reason for this post is his response to my latest explanation that ended with him saying “I’m comfortable with being wrong. It’s not a death match.” This post explains why it matters.
I will explain the problem with the successful propaganda campaign to convince the general population that unusual weather events justify New York’s Climate Leadership & Community Protection Act (Climate Act). I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.
Examples of the Causal Link
In order to keep the public’s support for the Climate Act net-zero transition the Hochul Administration links recent extreme weather events to climate change. The impetus of this article were two recent Facebook posts by my friend. The first said that “So it wasn’t so long ago that there was a thing called “snow” and included a memory of a hike during the winter of 2014-2015 when there were “MASSIVE snow dumps in the Catskills”. Yesterday the second post noted that he had heard spring peepers. This small chorus frog is “one sure sign of spring” and my friend noted that hearing them on March 8 was “by far the EARLIEST EVER”.
Climate Change and California Atmospheric Rivers
In my articles responding to the presumption that these weather events are tied to climate change I have explained that according to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.” That article goes on to explain “Climate is what you expect, weather is what you get.” Rather than trying to expand on my arguments I think this recent article by Chris Martz provides good insight.
In his article Martz addresses those who will claim that the recent rounds of atmospheric rivers that have brought rainfall for days and recent heavy snowfalls to California are linked to climate change. He describes the news cycle that had been harping for years on the “megadrought” that would put California in a permanent drought because of climate change. The last two years of above average precipitation have destroyed that story. Martz writes:
Faced with the reality that these “forever drought” predictions from nearly a decade ago were woefully wrong, academics and their media mouthpieces have had one of two options, either:
Admit that the “permanent drought” prediction was wrong, or,
Change their tune quietly to say that human-induced climate change is making California wetter by “fueling” the atmospheric rivers that provide the bulk of the state’s annual rainfall budget, and hope the rest of us don’t notice.
And, of course, the second option is the one academics and government scientists decided to go with (Figure 5).
Martz goes on to describe atmospheric rivers and their potential for serious impacts. Then he addresses the question whether “human-induced climate change plays a role, and to what extent if that is indeed the case.” He notes:
I should prepend this discussion with the disclaimer that climate change itself does not cause any single weather event to occur. Climate is nothing but a statistical measure of various atmospheric state variables over a period of at least 30-years, preferably longer. The statistics may be organized into averages or “climate normals,” distributions and extremes. Each provides some sort of insight as to the weather one might expect at any given point in space or time. As the old saying goes, “climate is what you expect, weather is what you get.” Climate changes, both naturally and through man-made forcings, over a period of several decades. The equations of motion which physically explain how extreme weather phenomena occur do not change with the climatic base state.
I think he does a good job explaining what meteorologists should consider when trying to attribute weather events to climate change.
So, the question becomes, how does a changing climatic base state alter specific characteristics of atmospheric river events? In this case, there are two facets that atmospheric scientists care about:
Has there been a detectable increase in extratropical cyclone activity [and the accompaniment intense winds] that atmospheric rivers are associated with in the observational record? How is this expected to change in the future?
How has extreme rainfall associated with atmospheric rivers changed as the climate has warmed? How is this expected to change in the future?
In a nutshell, depending on which of the two key issues above are examined, we reach contrasting conclusions, showcasing the sheer complexity of the coupled ocean-atmosphere system. To elaborate, if we make the assumption that the planet continues to warm, extratropical cyclone activity and their associated extreme winds should wane, but extreme rainfall, on the contrary, should be enhanced.
Like every other aspect of climate change policy this is much more complicated than it appears at first glance. He does a great job breaking down all the factors at play. For example, the warmer climate means more moisture “super-charging” extreme weather. He says in response: “Simply put, just because more water vapor can occupy the air at higher temperatures does not mean that it will.” I recommend reading his article in its entirety to understand how difficult it is to make a definitive link between climate change and weather events.
Why it Matters
After I sent the link to the article to my friend he responded:
I might quibble with “The equations of motion which physically explain how extreme weather phenomena occur do not change with the climatic base state.” No, the equations don’t change, but the inputs do, right? So, more heat = more [whatever], etc. I appreciate the skepticism, but, clearly, there is something going on out there beyond the bounds of “normal”. But then again, you can be skeptical and say that my human timeframe is far too short to make such judgments – perhaps. But even beyond my mere mortal years, it seems that we’re seeing the furthest outliers of “weather” data that you might expect for a given season.
The frustration to me is that he gets it when he says, “my human timeframe is far too short to make such judgments”. Anecdotal evidence linking weather events and climate change is going to always be wrong because weather is what you get and climate is what you expect and our time frame is too short for climate comparisons.
However, that is not the problem. The issue is his concluding remarks:
I’m comfortable with being wrong. It’s not a death match.
My concern is that ultimately the conflation of every unusual weather event to climate change is linked to the preposterous idea that if New York converts its energy system to meet the Climate Act net-zero goals there will be an effect on the unusual weather events observed. I am convinced that the present trajectory of the Climate Act mandates aspirational goals that are dangerous. In February 2021, the Texas electric grid failed to provide sufficient energy when it was needed. The storm was the worst energy infrastructure failure in Texas history and resulted in at least 246 people dying and total damages were at least $195 billion. The Hochul Administration has not demonstrated that the Climate Act goals are feasible and will not endanger the reliability of the New York electric system. The same thing that happened to Texas could happen in New York.
Discussion
There is another related weather and climate related issue. I fear that the emphasis on ever more dangerous weather in the future due to climate change is diverting resources away from addressing observed weather problems. There is a limit to the resources available to address weather-related issues despite the value in doing so. Over building infrastructure in one place to account for potential issues related to climate change likely means that improving infrastructure elsewhere for observed weather events will not be funded.
I am often surprised how California state and local entities craft policies they believe would put us on the path to addressing the complex dynamics of what we label climate change. Whether these efforts—a bullet train to and from small cities, banning the sale of gasoline cars by 2035, limiting the use of gas appliances, and similar aggressive policies—make real-world sense or whether they are a virtue-signaling crystal ball without a feasible way of measuring those efforts remains to be seen.
This is the nub of the Climate Act problem. Can we come up with net-zero transition policies that will not do more harm than good. Nalven’s article describes how Curry lays out the wicked problem of whether climate action is necessary and how it should be addressed given the uncertainties. Nalven sums up:
Curry’s approach stands in stark contrast to the overreach and catastrophizing by climate justice warriors. Those warriors and their acolytes are unlikely to be persuaded by Curry’s pragmatic, but seemingly slower, approach to a changing climate.
There is no magic wand, no scientific alchemy, that can easily upend cognitive catastrophizing about weather events.
“The disconnect between historical data for the past 100 years and climate model-based projections of worsening extreme weather events presents a real conundrum regarding the basis on which to assess risk and make policies when theory and historical data are in such disagreement.”
Conclusion
Chris Martz sums up my concern about the mis-allocation of resources based on the fear of climate change:
Whether or not climate change is having any meaningful impact on the extreme weather events we care about is irrelevant in the need to raise awareness to the fact that we continue to develop in disaster-prone areas and the necessity to improve societal resilience through better zoning codes and community planning. Mother Nature always has and always will throw curveballs in our direction, regardless of what the climate is doing in the long-term, and being better equipped to mitigate disaster losses or prevent them in the first place must be a focal point of engineers, emergency managers and policymakers in the years and decades to come.
Sitting on our hands and blaming climate change for everything is really a waste of time that would be better spent finding solutions to real-world problems such that our children and grandchildren have a safer world to live in.
Against this backdrop, the cartoon-like presumption that any unusual weather is tied to climate change and thus needs to be addressed whatever the cost needs to be confronted. The difference between weather and climate does matter. N
I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant post I have read. This is a summary of posts that I think would be of interest to my readers.
I have been following the. Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
The Empire Center’s Ken Giradin has written an exhaustive guide to New York’s drive to lower emissions. I recommend it highly. The Executive Summary states:
New York in 2019 adopted a sweeping climate law designed to reduce greenhouse gas emissions through bans, regulations and taxes. The law, the Climate Leadership and Community Protection Act (CLCPA), sets ambitious goals: 70 percent of electricity from renewables and a 40-percent economywide reduction in emissions by 2030, with an electric grid that uses only “zero emission” technology by 2040 and an economy that has effectively zero emissions by 2050.
The state’s approach to these goals is, however, deeply flawed. The Climate Act leaves the bulk of the decisions about how emissions will be reduced to state agencies under direct control of the governor, vesting them with policymaking powers that are supposed to be reserved for New York’s senators and assemblymembers.
The process that has played out in the five years since the law’s passage has been marred by a lack of transparency, with state officials failing to issue legally required cost estimates and crucial studies designed to guide state energy policy. There is growing evidence that the state will be unable to achieve its goals without significantly affecting the cost of living and doing business in New York and harming the reliability of its electric grid.
Giradin offers recommendations including “demanding updated state energy studies, as required by state law and the development of proper cost estimates.” Other steps include:
Giving the Legislature the final say on any regulation or set of regulations with gross compliance costs of $100 million or more;
Ceating an “off-ramp” in case of recession or other financial emergency;
Setting renewable energy credit (REC) purchase requirements through legislation rather than administrative rulemaking;
Pausing awards for offshore wind developers amid exploding costs and making more technologies eligible for zero-emission subsidies; and
Eliminating obstacles to reducing emissions with steps such as making more types of zero-emission power plants such as nuclear, biogas and hydroelectric eligible for state subsidies and seeking an exemption from the federal Jones Act.
So whose grid is it? Is the grid supposed to provide flexible and dependable electricity to the customers when and where they need power? Or is the grid sub-servant to wind and solar? Is it the customer’s job to be ‘flexible’ to accommodate inflexible renewables? Who is the grid supposed to serve:
A. The customer?
or
B. Whatever power source is politically favored at the moment?
Fundamental Climate Model Concern
One of the reasons that I distrust climate models is because they do not model clouds well. It turns out that there is another issue with moisture. Pierre Gosselin explains that “A new study published in PNAS has demonstrated, once again, that climate models fail to simulate what happens in the real world with regard to fundamental climate change variables like water vapor. This is a devastating finding, as water vapor is the most significant greenhouse gas due to its alleged “feedback” capacity, accelerating warming well beyond what CO2 is said to be capable of alone.
The Institute for Energy Research reports that Massachusetts utilities are asking for rate increase:
Eversource and National Grid, the major utilities in Massachusetts, are requesting rate hikes to enhance the power grid and accommodate the growing demand from electric vehicles and heat pumps. They are requesting approximately $2.4 billion over the next five years for grid improvements to convert the grid for renewable energy production and make it more resilient and capable of handling the surge in electrification. That is because Biden’s and the state’s climate agenda will result in Massachusetts homes consuming nearly three times as much electricity by 2050 than they do today. To deliver all that power, Eversource and National Grid will have to invest billions in grid infrastructure upgrades with ratepayers picking up much of the cost. The two utilities have asked the state Department of Public Utilities to begin the process of recouping their investments in converting the electric grid by raising rates over a five-year period.
Taxpayer subsidies and utility profit motives are converging to incentivize the premature destruction and replacement of wind installations throughout America, and this trend will almost certainly become more common as an increasing number of wind turbines are added to the nation’s electric grid. Utility companies and wind turbine operators will seek to renew their access to the PTC to reduce the need for curtailment and to increase their government-approved profits on capital expenditures as long as these subsidies are available.
For your information New York’s October 2023 land-based renewable energy procurement included 612 MW of wind turbine re-powering.
Fundamental Greenhouse Gas Effect Concern
The Science and Environmental Policy Project Weekly Climate and Energy News Roundup #588 explains that physicist Howard Hayden demonstrates that AR6 is inconsistent with itself and with the Stefan-Boltzmann law which specifies the amount of radiation emitted per unit of time from a specific area of a blackbody. A webpage describing observations of infrared radiation compares radiation measurements with temperature measurements. The following results are described:
Both upward and downward infrared radiation can be measured by pyrgeometers mounted 1.5 to 2 meters (4.5 to 6 feet) above the ground. These measurements vary seasonally and by year. The example shown by the Japan Meteorological Agency at Tsukuba, Japan, the home of Tsukuba Science City and the headquarters of the Japan Aerospace Exploration Agency shows this variation and a modest increase in downward infrared radiation but not an appreciable increase in upward infrared radiation indicating a warming.
