Pragmatic Environmentalist of New York Principle 6: Iron Law of Climate

This is a background post for one of the principles that I believe define pragmatic environmentalists. Other principles are listed at the end of this post.

Roger Pielke, Jr has defined the “iron law” as follows: While people are often willing to pay some price for achieving climate objectives, that willingness has its limits.

Dr. Pielke calls this the iron law of climate but it applies to all environmental objectives so this is closely related to Pragmatic Environmentalist Principle 4: We can do almost anything but we cannot do everything. The fact is that trying to reduce more and more risks costs increasingly more money. Eventually that cost becomes too much to bear and people will stop supporting those costs even if they reduce risk.

For example consider the proposal to get 100% of our energy from wind, water, and solar by Delucchi and Jacobsen. The author of the A Chemist in Langley blog is a pragmatic environmentalist. He has posted frequently on this proposal in his posts on the fossil free future proposal by Delucchi and Jacobsen and other similar initiatives.   In the context of this principle he specifically has observed that “It places tight, and poorly supported, restrictions on a number of important baseline clean energy technologies and in doing so results in a proposal that is ruinously expensive.”

I agree that the proposal for 100% renewable is technologically possible but the economic costs would not be supported by most of society simply because of the enormous costs. Because renewable sources are intermittent and diffuse the electric energy system would have to be overhauled to included storage for intermittency and a vastly different transmission system to address the diffuse sources. Dr. Jesse Jenkins at the Energy Collective Blog points out the difficulty of relying on renewable energy for more than 40% of the energy supplies. While the installed cost of renewables might approach conventional sources the real concern is that all the other aspects necessary to maintain the electrical grid have to be addressed and those costs are overlooked by many advocates.

Pragmatic Environmentalist of New York Principles

Principle 1: Environmental Issues are Binary: In almost all environmental issues there are two sides. Pragmatic environmentalism is all about balancing the risks and benefits of the two sides of the issue. In order to do that you have to show your work.

Principle 2: Sound Bite Environmental Issue Descriptions: Sound bite descriptions in the media necessarily only tell one side of the story. As a result they frequently are misleading, are not nuanced, or flat out wrong.

Principle 3: Baloney Asymmetry Principle: Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”

Principle 4: We can do almost anything we want, but we can’t do everything: Environmental initiatives often are presented simply as things we should do but do not consider that in order to implement those initiatives tradeoffs are required simply because the resources available are finite.

Principle 5: Observation on Environmental Issue Stakeholders: The more vociferous/louder the claims made by a stakeholder the more likely that the stakeholder is guilty of the same thing.

Murphy Editorial “EPA Chief is wrong on the greenhouse gas effect”

On April 18, 2017 the Syracuse Post Standard published a featured editorial by Dr. Cornelius Murphy, Jr. “EPA Chief is wrong on the greenhouse gas effect”. I was given the opportunity to submit a rebuttal but was asked to make it the same length. This presents a problem because of the Baloney Asymmetry Principle, the third of my pragmatic environmentalist principles. In particular, the amount of information necessary to refute BS is an order of magnitude bigger than to produce it. This post rebuts his arguments.

Dr. Murphy’s editorial is an example of the straw man fallacy prominent amongst the critics of the current EPA. He describes the science behind the greenhouse effect and claims that Administrator Pruitt disagrees with those facts to support his claim that Pruitt must not be allowed to provide direction and policy for CO2 mitigation. The Catastrophic Anthropogenic Global Warming (CAGW) hypothesis espoused by Dr. Murphy claims that mankind’s emissions of greenhouse gases are responsible for the recent observed warming of the globe and, unless stopped soon, will have catastrophic impacts on the planet. This post addresses the catastrophic component of global warming which, I believe, are not obvious by simply “looking around” as Murphy suggests.

Robust scientific theories and hypotheses rely on a combination of both empirical and correlative evidence. In the case of a theory that cannot be directly tested through a controlled experiment, we have to rely on long term observations and comparison of projections based on the theory against the observations. Empirical observations and correlative evidence for the CAGW hypothesis are not as obvious as Murphy implies.

I have no issues with Dr. Murphy’s description of the greenhouse effect. The basic greenhouse gas theory is not controversial. Carbon dioxide is a greenhouse gas.  It retards radiative cooling.  All other factors held equal, increasing the atmospheric concentration of CO2 will lead to a somewhat higher atmospheric temperature.  It is not controversial that CO2 has risen in the last century or that at least half of the increase was due to mankind. It is also obvious that average temperatures are increasing over that same period. Dr. Murphy said that Administrator Pruitt “doesn’t think that CO2 is responsible for heating our planet”, but I don’t think Mr. Pruitt would dispute any of the aforementioned facts.

However, those facts do not necessarily lead to catastrophe and there is a healthy debate on most policy-relevant aspects of global warming. In the first place, there is a predicted warming due to greenhouse gases when all factors are held equal but all other things are never held equal in meteorology. In that case, doubling the concentration of atmospheric CO2 from its pre-industrial level would reduce outgoing infrared radiation by about 4 watts per meter squared and the temperature of the atmosphere would increase about 1.2 deg. C. Note that about half of this warming has already occurred. So clearly some of the observed warming is caused by this effect.

The most recent warming period started before the recent rise in CO2. There have been other warm periods of the same magnitude of the current period in the last two thousand years when anthropogenic CO2 was not the driver. At a minimum the CAGW theory has to explain why the causes of the warming between 1900 and 1940 which is of the same order of magnitude as the current warming are not playing a role now.

Dr. Murphy says that Administrator Pruitt should look at what is happening around him and cites several examples: “We have wild extremes in temperatures but annual average global temperatures continuing to rise. The temperatures of our Great Lakes are 6 degrees above average, extreme weather events challenge us all too frequently, and we experience mega droughts globally on a regular basis.” I address those points below.

I do not dispute that annual average global temperatures continue to rise. However, to me, if there is a valid concern about rising temperatures, then we should be able to find evidence that heat waves are increasing. The EPA climate change indicators high and low temperatures web page lists several parameters associated with temperature. The heat wave index shows an overwhelming spike in the 1930’s but there is no suggestion of a recent trend. There is a trend in the area of unusually hot temperatures graph but I wonder how they addressed the development of heat islands in that data so I am skeptical. I see nothing happening to warrant alarm.

His only quantitative claim is that “the temperatures of our Great Lakes are six degrees above average” but his claim does not withstand scrutiny.  According to EPA’s Climate Change Indicators web page on Great Lake temperatures: “Since 1995, average surface water temperatures have increased slightly for each of the Great Lakes”, but that is nowhere near six degrees.  The web site Great Lakes Statistics lists the current temperatures relative to their period of record starting in 1992 and all five lakes are currently less than two degrees above the mid-April average.

Dr. Murphy says extreme weather events challenge us all too frequently insinuating that they are getting worse but, again, looking at data indicates no cause for alarm. In recent testimony before the House of Representatives, Dr. Roger A. Pielke, Jr. addressed trends of extreme events in the United States. He noted that global weather-related disaster losses as a percentage of Global GDP are trending down since 1990; that there is no trend in hurricane landfall frequency or intensity; that the IPCC noted no evidence of a trend for floods; that US flood impacts are going down; and that there low confidence in observed trends for hail or tornadoes.

Dr. Murphy says that we experience mega droughts globally on a regular basis but Dr. Pielke quotes the IPCC: “there is low confidence in detection and attribution of changes in drought over global land areas since the mid-20th century”. If the Intergovernmental Panel on Climate Change concludes no trends in droughts then the only way we can interpret the regular basis comment is that this has been the case in the past and it continues today. His statement is not wrong but it also is not cause for alarm upon inspection either.

Because it is impossible to run a controlled experiment on Earth’s climate (there is no control planet), the only way to “test” the CAGW hypothesis is through models.  If the CAGW hypothesis is valid, then the models should demonstrate predictive skill. However the models are not predicting temperatures well enough to meet that standard because they predict a sensitivity to CO2 two to three times greater than that supported by observations. Dr. Curry’s summary of the global climate models makes five points about the use of these models for this purpose:

  1. GCMs have not been subject to the rigorous verification and validation that is the norm for engineering and regulatory science.
  2. There are valid concerns about a fundamental lack of predictability in the complex nonlinear climate system.
  3. There are numerous arguments supporting the conclusion that climate models are not fit for the purpose of identifying with high confidence the proportion of the 20th century warming that was human-caused as opposed to natural.
  4. There is growing evidence that climate models predict too much warming from increased atmospheric carbon dioxide.
  5. The climate model simulation results for the 21st century reported by the Intergovernmental Panel on Climate Change (IPCC) do not include key elements of climate variability, and hence are not useful as projections for how the 21st century climate will actually evolve.

Finally, Dr. Murphy notes that Pruitt is not a scientist but is an attorney. Although Dr. Murphy is a chemist and not a meteorologist like me I don’t believe that a person’s background necessarily means much. Look at the evidence yourself. When you check the numbers and claims like I did then you can determine whether or not to believe whoever is making the claims. In this case I find little support for Dr. Murphy’s claims but readers should decide themselves.

I have not found sufficient evidence to convince me that CO2 mitigation efforts are appropriate at this time. While it is very likely that human activities are the cause of at least some of the warming over the past 150 years the question is how much.  There is no robust statistical correlation to indicate that CO2 is the primary driver.  The failure of the climate models outline above clearly demonstrates the CAGW hypothesis is flawed.

I conclude that our children and grandchildren are not in imminent danger from CAGW and would be better served by investments to make society more resilient to observed extreme weather rather than trying to mitigate CO2 emissions to try to prevent the speculative weather projected by the flawed models. I believe Administrator Pruitt’s agenda to reign in the ill-conceived CO2 mitigation programs of the Obama Administration is appropriate. On the other hand, I do not agree with any plans to cut the climate monitoring and observing programs at EPA and elsewhere. I support research into all the causes of climate change not just anthropogenic causes. Ultimately, until such time that a cheaper alternative to fossil fuels is available society will continue to use them because of their tremendous benefits. If you believe that we society should stop using fossil fuels then research and development for alternatives is appropriate.

Scott Pruitt Nomination and EPA Approach to Interstate Transport Ozone Attainment

At this time there is quite a bit of noise about potential problems if Scott Pruitt is confirmed to head EPA because he would “hamstring EPA’s authority to set nationwide environmental standards”. As I understand it he is proposing to cooperate more with the states. This post describes a particular example where states proposed an alternative approach but in a recent action EPA continues to ignore the alternative proposed. I hope to show why I think that is a mistake. If Pruitt can get EPA to respond to this type of state action I support his nomination.

In my opinion one of the bigger air quality issues is ozone attainment, particularly as it relates to interstate transport. EPA explains that “air transport refers to pollution from upwind emission sources that impact air quality in a given location downwind”.  Emissions of nitrogen oxides (NOX) and Volatile Organic Compounds (VOC) can each undergo chemical reactions in the atmosphere to create ground-level ozone (smog) pollution.

The EPA website for interstate air pollution explains the “Good Neighbor” provision that requires EPA and states to address interstate transport of air pollution that affects downwind states’ ability to attain and maintain ambient standards. One of the reasons that the ozone limit has proved to be particularly difficult to attain is that the standard was recently tightened. In this example, I want to address the recent EPA Notice of Data Availability for the preliminary interstate ozone modeling data for this new limit.

EPA notes that they have completed preliminary interstate ozone transport modeling relevant for the 2015 ozone national ambient air quality standard. We are currently in the public comment period where the Agency is providing an opportunity for public review of this modeling data, including projected ozone concentrations and contributions for 2023, as well as projected emissions, including emissions from the power sector, that were used for this modeling.

In EPA’s approach the modeling projects ozone concentrations in 2023 at individual monitoring locations to determine the state-by-state contribution. EPA used a 2011-based air quality modeling platform which includes emissions, meteorology and other inputs for 2011 as the base year for the modeling and then projected the 2011 base year emissions to the 2023 base case scenario. The modeling domain covers the entire United States with a grid resolution of 12 km. I refer you to the technical support document for details of this modeling analysis.

I think that there are two glaring problems with EPA’s approach: one related to the emissions and one related to the air quality modeling. Both are related to the fact that the current ozone problem is episodic. Peak ozone concentrations only occur during several-day summertime hot and humid periods which also are periods of peak electrical demand.

EPA’s emissions approach goes to great lengths to project future year emissions at the expense of actual observed emissions. EPA uses the Integrated Planning Model, a massive proprietary planning model to project the emissions in future years. Because emissions are dependent upon fuel prices, technology, regulations, and energy use trying to estimate future emissions is a very complex undertaking and can only provide annual or seasonal average estimates. However, the primary concern are the peak periods and this model does not project these extreme periods well.

In order to address that problem the Eastern Regional Technical Advisory Committee was formed to prepare an alternative to the EPA emissions modeling approach. Basically the states and industry collaborated to develop an alternative based on adjustments to observed emission and operating rates. The result was Eastern Regional Technical Advisory Committee Electricity Generating Unit Emission Projection Tool. Importantly, this approach more accurately represents the actual and future emissions during ozone episodes than the EPA approach.  Unfortunately, this alternative approach was not used by EPA for this modeling.

Although EPA’s air quality modeling analysis is an impressive effort it also falls short of what I think is needed. As noted previously, EPA’s ozone projection methodology covers the entire United States on a 12 km by 12 km grid. My primary interest is New York State and the largest interstate impact of New York sources to ozone monitoring stations is downwind of New York City in Connecticut. I am convinced that the complex meteorological conditions during ozone episodes in this situation (land and sea breezes, elevated terrain concerns, and the nocturnal boundary layer structure along the coast) cannot be represented well enough to be accurate using such a coarse grid. Moreover, using that grid means that the many of the emissions are incorporated into the modeling at the same coarse grid resolution and there are indications that leads to further inaccuracies.

There is another problem with EPA’s modeling. They used a base year of 2011. As part of comments I developed to address the previous round of EPA interstate modeling, I compared daily New York electric generating unit emissions and observed ozone levels on an annual basis by running a regression to determine if there was a relationship. Not surprisingly there always was a statistically significant relationship. However what was interesting is that that strength of the relationship has changed recently. Prior to 2014 the regression analysis always indicated that there was a relatively strong relationship but in the last three years the relationship has deteriorated substantially. In order to accurately determine what is causing high ozone today a base year in the last three years is needed when this different regime of the relationship occurred.

I believe that in order to solve the interstate ozone transport problem it is first necessary to understand what is going on. EPA’s preliminary modeling described in their December 2016 Notice of Data Availability will not provide the necessary level of detail to describe the current situation. The Eastern Regional Technical Advisory Committee emissions modeling approach addresses one aspect that needs to be corrected. If Scott Pruitt’s approach to administering EPA would facilitate EPA using this alternative and modeling this problem differently then I believe his nomination should be supported.