Pragmatic Environmentalist of New York Principle 11 Air Pollution Control Costs

I have never seen this principle mentioned as somebody’s rule or law but it is accepted as such in the air pollution control community. In particular: as the control efficiency increases the control cost per ton reduced increases exponentially.

I will illustrate how this works using the example of particulate control on a coal-fired boiler. I used to work for Niagara Mohawk Power Company and they built and operated the Dunkirk Generating Station in western New York. I will describe the history of particulate control there up to the point it was retired several years ago. When the four coal-fired boilers were built in the 1950’s the only particulate pollution control equipment installed was a cyclone. A cyclone is basically ductwork that uses the principle of inertia to remove particles from the flue gas.

In the late 60’s, I believe but am not positive, New York State ordered Niagara Mohawk to do a better job cleaning the flue gas. To its credit, the company installed a hot-side electrostatic precipitator (ESP) that was over-sized and reduced the particulate levels well below the standard in effect even forty years later.

Despite the fact that the particulate levels were below emission standards there was a persistent problem with opacity. This is a measure of how opaque the plume is and before there was pollution monitoring equipment this was used to determine how well a boiler was operated. If the boiler is running efficiently there should be very little smoke visible but a dark opaque plume is a sure sign that it is not being run well. The standard methodology (which is still in use today) is for a trained “smoke reader” to observe the plume in six-minute intervals. An excess opacity emission event means smoke emissions of one or more six minute periods in which the average opacity exceeds 20%, except that one event in every hour may be excluded if the average opacity during the six-minute period does not exceed 27%. When continuous opacity monitoring systems were installed there was an opacity issue that the New York State Department of Environmental Conservation used as an excuse to fine the owners of the plant (NRG Energy after 1999) millions of dollars for the scourge of an aesthetic violation (remember the particulate limits were not exceeded). As a result, NRG installed a baghouse to eliminate the problem which worked extremely well until the station was retired.

For an order of magnitude estimate of costs I used the ESP and baghouse examples in the EPA Air Pollution Control Handbook. In the handbook the example ESP cost was $1,840,000 and the baghouse cost was $569,000. I assume that a cyclone would only cost $100,000.

For my example assume that the boiler generates 100 tons of particulate. A cyclone has an efficiency around 35% so it reduced emissions by 35 tons at a cost per ton of $2,857. The ESP has an efficiency of 98% would reduce the 65 remaining tons by 98% at a cost per ton of $28,885. In order to get the final two tons removed the baghouse cost per ton is $284,500 simply because the additional controls removed so little. Clearly this is an exponential increase in costs for the last little bit of emissions.

This relationship is a primary driver in greenhouse gas control costs. Consider energy efficiency at your home. The first bit of insulation in the attic does not cost much but gets a good reduction in energy loss. As the homeowner progressively adds insulation to the walls, upgrades the windows and doors and audits the last little bit of air infiltration the energy reductions get smaller and smaller so even if the control cost themselves stays the same the cost per efficiency increase goes up. It is true in every control instance.

Ultimately this rule simply quantifies the low-hanging fruit analogy. It is easy to pick the low hanging fruit but the higher you go the more it costs.

Pragmatic Environmentalist of New York Principle 10: Environmental Issues are Rarely Definitive

This is one of the principles that that describe my pragmatic environmentalist beliefs.

Principle 1 states that almost all environmental issues have two legitimate sides. Because that is a given that means that two people can look at the same data and come up with opposite conclusions. This corollary principle asserts that as a result there are two legitimate arguments based on how each side interprets data. As a result environmental issues are not usually definitive.

For an example of this failure, consider “How to use critical thinking to spot false climate” claims by Peter Ellerton, Lecturer in Critical Thinking, Director of the UQ Critical Thinking Project, The University of Queensland. The author states:

Despite scientists’ best efforts at communicating with the public, not everyone knows enough about the underlying science to make a call one way or the other. Not only is climate science very complex, but it has also been targeted by deliberate obfuscation campaigns.

His post describes a paper that describes a “critical thinking approach to climate change denial”.

He describes six steps to evaluate contrarian climate claims and the post provides an example how it can address the following example:

    • Premise one: The climate has changed in the past through natural processes
    • Premise two: The climate is currently changing
    • Premise three: If something was the cause of an event in the past, it must be the cause of the event now
    • Conclusion: The climate is currently changing through natural processes.

In order to prove that this is incorrect he states that “Current climate change is much more rapid than previous climate change” and concludes that they are not the same phenomenon so the argument that climate is changing due to natural processes is wrong.

This argument fails to note that the historical data record for climate rate change is very limited and ambiguous at best. Ideally in order to evaluate climate change you would want to measure a parameter using the same instruments with the same techniques at a location that has had no nearby changes over as long a period of time as possible. Clearly this limits your available data quite a bit so you have to make compromises to get a long period of record. In order to get really long climate change records you eventually have to substitute instrumentals records with proxies. Even if you can find a proxy that has the same accuracy the problem for rate of change estimates is that the observational time scale differs. For example, if you are using coral growth rates, the temperature signal is measured over years whereas thermometers measure over days. As a result, comparison of different rate of change trends are difficult and may not be appropriate due to the classic apples to oranges comparison issue.

The premise in this paper to prove the contrarian argument wrong is that current climate change is much more rapid than previous climate change. The failure to acknowledge that any data used to estimate the rate of climate change is ambiguous weakens that premise considerably.   Pragmatic environmentalism is all about science based decision making that acknowledges both sides of arguments.

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

This is one of the principles that that describe my pragmatic environmentalist beliefs.

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

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

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

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

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

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

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

 

Pragmatic Environmentalist of New York Principle 7: Golden Rule of Climate Extremes

This is a background post for my pragmatic environmentalist principles listed on the principles page of this blog.

Dr. Cliff Mass defines the Golden Rule of Climate Extremes as: The more extreme a climate or weather record is, the greater the contribution of natural variability.

I am posting this soon after Harvey made landfall, dumped extraordinary amounts of rain, and the impact of global warming on it made the news. The question that came up was the effect of climate change on the storm. The Capitol Weather Gang claims the truth is in the middle. Note that Dr. Mass concluded that global warming effects on Harvey were immaterial.

The golden rule of climate extremes is important to keep in mind because I believe it is important to point out that most climate scientists do not have extensive weather forecasting experience. It is that experience that enables meteorologists to properly determine the role of natural variability to a particular event. When an operational meteorologist looks at this kind of weather event, for example Joe Bastardi, natural variation invariably provides most of the impact.

Pragmatic Environmentalist of New York Principle 8: Gresham’s Law of Green Energy

This is one of the principles that that describe my pragmatic environmentalist beliefs.  Jonathan Lesser has coined “Gresham’s Law of Green Energy” that I believe is another principle of a pragmatic environmentalist.

Gresham’s Law is named after Sir Thomas Gresham, a 16th-century British financier who observed that “bad money drives out the good.” Lesser shows that green energy subsidies transfers wealth and does not create wealth. The subsidies or “bad” money take money out of the system that was “good” inasmuch as it was being used productively. In particular he notes that “subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth”.

He explains his rationale as follows:

“The subsidies paid by ratepayers transfer wealth from existing generators to a chosen few renewable resource owners. One may like to rail against the existing generators — as many politicians have — but the long-run implications of such subsidies will be to destroy competitive wholesale electric markets and drive out existing competitors. This course of action will cost jobs because businesses, forced to pay higher electricity prices, will either relocate, contract, or disappear altogether. It will reduce the disposable income of consumers, who will forever be forced to subsidize renewable resources (just as they must now subsidize corn ethanol producers) — all in the name of ’green energy’.”

This is a particularly important principle for renewable energy benefit analyses, in particular “price suppression” such as that used in NY’s Clean Energy Standard. The idea is that increasing the supply of “cheap” electricity causes market prices to decrease so that consumers benefit. However, Lesser shows that these benefits are temporary and costly in the long run. Subsidizing the construction of renewable generation in a de-regulated state results in resources that manipulates the market to make it less efficient. Moreover, it eventually drives out existing generators and reduces the likelihood that new unsubsidized generating facilities will enter the market. Lesser notes that rather than building a better mousetrap, these policies are using subsidies to artificially and temporarily reduce the price of mousetraps.

Pragmatic Environmentalist of New York Principle 5: Observation on Environmental Issue Stakeholders

This is one of the principles that that describe my pragmatic environmentalist beliefs.

Pragmatic Environmentalist of New York Principle 5: The more vociferous/louder the claims made by a stakeholder the more likely that the stakeholder is guilty of the same thing. This observation was also described by Gary: “My experience is that the things people complain about loudly are so very frequently the same things of which they also are guilty. The inability to see oneself realistically is a fascinating human trait.”

The poster child for this particular behavior is Dr. Michael Mann, Distinguished Professor of Atmospheric Science, Penn State University and Director, Penn State Earth System Science Center. On March 29, 2017 he gave testimony before the Committee on Science, Space and Technology that illustrates this phenomenon in three ways.

I prepared a table summarizing Michael Mann testimony with general categories for the contents. There were 26 paragraphs. Dr. Mann used 4 paragraphs to describe his background. Thirteen paragraphs described either “anti-science” attacks on him or Dr. Thomas Karl and his rebuttals to those attacks, two paragraphs attacked other scientists and seven of the 26 paragraphs addressed the science of climate change.

The first example of Principle 5 is the matter of personal attacks which are bad if they directed to him but OK if he is doing the attacking. The majority of his testimony addresses what he characterizes as “anti-science” attacks on him. He notes that “Science critics will therefore often select a single scientist to ridicule, hector, and intimidate.” However, his testimony then ridicules three out of the four individuals at the hearing because they “represent that tiny minority that reject this consensus or downplay its significance”. I think it is reprehensible and clear intimidation to label Dr. Judith Curry as a “climate science denier” equating her views of the consensus on climate change as equivalent to those who deny the Holocaust. He notes “I use the term carefully—reserving it for those who deny the most basic findings of the scientific community, which includes the fact that human activity is substantially or entirely responsible for the large-scale warming we have seen over the past century”.

The second example is the scientific debate on climate change. Dr. Mann invokes the 97% consensus argument that “of scientists publishing in the field have all concluded, based on the evidence, that climate change is real, is human-caused, and is already having adverse impacts on us, our economy, and our planet”.  But then goes on to say “there is indeed a robust, healthy, and respectful debate among scientists when it comes to interpreting data and testing hypotheses”. Obviously no debate is possible interpreting any data or hypotheses that climate change is human-caused. I am also troubled by his lack of qualifiers for what the referenced 97% consensus actually referred to.

The third example is the proper channel for scientific debate. Dr. Mann states “True scientists are skeptics—real skeptics, contesting prevailing paradigms and challenging each other, in the peer-reviewed literature, at scientific meetings, and in seminars—the proper channels for good faith scientific debate.” However, he “proves” that James Hansen famous predictions from the 1980’s and 1990’s were successful by referencing the Real Climate blog. In Congressional testimony he mentions “the huge potential costs if the impacts turn out to be even greater than predicted, something that appears to be the case now with the potential rapid collapse of the West Antarctic Ice Sheet and the increased sea level rise that will come with it.” His citation is a newspaper article “Climate Model Predicts West Antarctic Ice Sheet Could Melt Rapidly” by Justin Gillis, New York Times, March 30, 2016. Two examples of precisely the improper channel he was alluding to in his description of good faith scientific debate.

One final point regarding this testimony. Dr. Mann notes that he coined the term “Serengeti strategy” to characterize his attackers. He describes this as when special interests “single out individual scientists to attack in much the same way lions of the Serengeti single out an individual zebra from the herd”. He is blissfully unaware that his moral of the story “In numbers there is strength, but individuals are far more vulnerable” may not be the whole story. My impression is that the lions single out the weakest link in the herd: the old, the sick, the young and, dare I say it, the one with the weakest arguments.

Pragmatic Environmentalist of New York Principle 4: We can do almost anything we want, but we can’t do everything.

This is one of the principles that that describe my pragmatic environmentalist beliefs.

Environmental initiatives often are presented simply as things we can do. Over at Climate Etc. the Planning Engineer coined this statement when he said that when his children asked “Can we do this?” he used to annoy his children with the answer “We can do almost anything we want, but we can’t do everything.” They came to learn that response meant that something “unthinkable” would likely have to be given up to indulge the extravagance.

This is a fundamental aspect of pragmatic environmentalism. While it is fine and appropriate to propose actions to reduce environmental risks that are technologically feasible, in the real world the costs to implement those policies carry costs that have to be considered. Moreover there could be unintended consequences.

As the Planning Engineer explains in his blog post: “There is no bargain to be found by pushing jointly for both more microgrids and the greater integration of “clean” resources. Having both will require huge sacrifices. If society’s utmost desire is a “clean”, highly reliable grid, resilient, secure grid – we likely can build that at some enormous cost. However, if cost is a factor impacting electric supply then tradeoffs will have to be made from among competing goals and technologies.”