Comments on Climate Leadership and Community Protection Act Land Use Advisory Panel Strategies

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Transportation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


I have described the implementation requirements in a stand-alone document.  In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility.  Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies.  In brief, each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.”  They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration.  This post describes the comments that I plan to submit as part of that public process.

General Comments – Note that this is pretty much the same for all my advisory panel posts

There are major potential land use and environmental impact ramifications of the CLCPA on agriculture and forest lands.  I believe it is necessary to do a cumulative environmental impact assessment of the Scoping Plan’s projections for wind and solar development and I strongly recommend that this panel work with the land use panel to take the lead in developing a strategy to evaluate those impacts.

At the end of September 2020 the Department of Public Service released the  Final Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act (“CLCPA SGEIS”).  Unfortunately, that analysis only evaluated the 70% reduction by 2030 target and did not even use the latest estimates for the wind and solar developments for that target.  Based on the projections by E3 in their presentation to the Power Generation Advisory Panel on September 16, 2020 and the Analysis Group September 10, 2020  presentation of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study significantly more wind and solar will be required than was analyzed in the CLCPA SGEIS process.  Because the capacity estimates from these analyses and others are so much larger than the latest CLCPA SGEIS estimate I believe that another environmental impact analysis is needed when the Climate Action Council finalizes its Scoping Plan.

I extrapolated results from several projects to estimate the potential cumulative impacts for the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last DPS impact statement that evaluated wind energy cumulative impacts.  If all the wind projects are built on agricultural land, then between 12% and 56% of the agricultural lands will be covered with wind turbines.  Of course, it is more likely that wind turbines will be sited on ridge lines but that will affect forest land use.  Nonetheless that study also projected 39,262 MW of utility scale solar that will have to go somewhere.  It is not just land use that will be affected.  The environmental impacts of this much wind generation could cause the deaths of between 91 and 804 bald eagles a year.

I recommend that the Land Use Advisory Panel develop a strategy that includes preparations for the cumulative analysis of the Scoping Plan recommended wind and solar development.  That process should start soon and determine a threshold for unacceptable environmental impacts.  For example, I am worried about eagles.  If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful.  Now that has occurred and I am not willing to chance that environmental victory.  Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines.  There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed.  The ultimate goal should be to refine the NYSERDA on wind power and biodiversity habitat sensitivity maps for the CLCPA resource development planning and siting process.

Specific Comments

The Land Use and Local Government advisory panel presented ten strategies from three subgroups. I will address each of the strategies below.

In the Land Use Strategies category five strategies were proposed.  The “promote and facilitate county and inter-municipal smart growth planning efforts, including focusing development in priority growth centers” and “promote coordinated regional approaches to meet climate goals while integrating transportation, housing, and land conservation needs” smart growth strategies rationales support conservation of areas.  Supposedly smart growth will support the development of open space conservation areas and conserve natural and working lands.  However, 35,200 MW of on-shore wind energy and 39,262 MW of utility-scale solar estimated by the Analysis Group will likely consume far more land than can be saved by smart growth.  The panel should address this contradiction.

The remaining three strategies proposed are:

      • Streamline and incentivize Smart Growth project review
      • Coordinate State planning funds/activities/entities to ensure that transportation, housing, and conservation actions are not in conflict and achieve reduce vehicle miles, clean energy, and equity goals
      • Build capacity at the regional level and provide support to municipalities to promote smart growth, facilitate clean energy siting, and reduce vehicle miles traveled

All three strategies are intended to facilitate smart growth development.  I think there is a huge disconnect between smart growth advocates and the rest of society.  There are reasons why society evolved to today’s land use patterns in New York and smart growth development is an attempt to change those choices all in the name of it’s for your own good.  If their case is good then fine but what this all means should be publicized more.

Three clean energy strategies were proposed:

      • Establish statewide higher energy codes, benchmarking, building performance mandates, and Property Assessed Clean Energy (PACE) Financing to avoid a patchwork of policies.
      • Encourage local governments to initiate Community Choice Aggregation (CCA) programs and community campaigns to increase local access to clean energy products and services.
      • Overcome legal, financial, regulatory, and technical barriers to greening municipal building, facilities, and fleets

I don’t think that there are any surprises in these strategies.  I do have a reservation about the CCA programs that are touted to allow energy choice.  Those programs cannot pay their own way so someone has to support them.  As more and more of these programs are implemented fewer and fewer will have to provide more and more support.  Unless you can guarantee that this initiative does not increase the number of people with unacceptable energy burdens it should not be included.

There were two Adaptation and Resilience Strategies:

      • Develop policies, programs and resources to reduce risks associated with acute climate hazards
      • Seek to ensure State and local investments assess climate change and resiliency impacts of projects

I support adaptation and resilience efforts because they are no regrets solutions to problems that are not going to go away.  However, I cannot help but take exception to the rationale used because whenever I have evaluated climate data the results don’t support the narrative that climate change effects due to mankind are showing up now.  The CLCPA in general and this characterization in particular confuse weather and climate.  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.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”  The reality is that any possible climate effect on extreme weather in the foreseeable future is a small tweak much smaller than normal variations.  Nonetheless acute weather hazards are a problem that should be addressed.


I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study.  It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar.  The only way this might work will require extraordinary amounts of wind and solar development.  When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.  This panel and the agriculture and forestry panel are in the best position to develop a strategy to address this problem.

The Problem with Innumeracy

I am a numbers guy and I am terrified by what appears to be the general perception that numbers don’t matter when it comes to an emotional issue or pre-conceived idea.  This post explains what I mean by data numeracy and offers examples of the problems I worry about.

The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


One of my responsibilities over my career was reporting data from meteorological monitoring stations to regulatory agencies primarily concerned with air pollution transport.  The first problem is that the monitors had to be located where they measured the wind speed and direction that represented the flow in the area.  Ideally the site had to be located in an open field with no nearby obstructions that could affect the wind direction.  Once the wind vane was up and running it was not enough to just report all the data collected.  There is a vital quality control check to make sure the data are realistic.  To do that I developed a program to review the data for oddities.  For example, if the wind direction did not vary at all for several hours that period would be flagged for further review.  If the temperature was below freezing and there was precipitation at the monitor then I would check the local weather station for freezing rain.  If that was observed then it was clearly appropriate to flag the data as missing and note in the data submitted to the regulatory agency that there was freezing rain.  The regulatory agency could easily check that decision and in the end, everyone was confident that the data submitted accurately represented the air pollution transport conditions in the area.


Another responsibility of mine was to report data from continuous emissions monitoring systems (CEMS) from power plants.  Coming from my background it seemed logical that the data should be reviewed in a similar fashion as the meteorological data.  The problem is that there are physical relationships between weather parameters that make it much easier to flag problems.  Eventually I developed a system to review the data in a reproducible manner basically by looking for outliers and trends in the data.  My process flagged data that needed to be checked.  It was possible to compare the raw data against operating information and other information to see if the outlying data were just odd or incorrect.  The analysis did not say that the data were wrong only that they needed to be reviewed and validated.

In some cases, the numbers were measured correctly but were not representative. For example, during startup and shutdown fuel combustion processes are inefficient and some pollutant levels are high.  However, if your concern is the long-term average you don’t want to weigh those short-term values too much because they bias the result.  The Environmental Protection Agency uncritically used the CEMS data[1] in a couple of instances and proposed inappropriate limits as a result.

Global Warming

I am irritated by those who make claims that climate change effects are being observed now whenever there is an extreme weather event or a new weather record and have documented instances where the message is incorrect.  In the first place, the message is never that there might be good news associated with warming and more CO2 but always it is a sign of imminent, inevitable Armageddon.  I could write many posts on examples of this but just want to make a point about temperature trends.  Recall that when setting up a meteorological sensor you have to consider whether it will make representative measurements.  When measuring temperature trends, a big concern is whether conditions around the sensor are changing and over long periods of time that is difficult.  In addition, changes to the observing methods or instruments themselves all affect the trend and have to be considered when evaluating the results.  Ultimately measuring temperature trends is not easy and picking and choosing trends has over-hyped the observed global warming.  Not considering the data correctly for the task at hand undermines the concept that CO2 is the control knob for climate change.


Data numeracy recognizes that data should be reviewed and irregularities need to be checked.  Inconsistent data patterns do not prove that there is a problem only that further review is necessary.  If the data are audited in an open and transparent manner then everyone can be confident in the result.  Sadly, too many people will not accept numerical results that run counter to their pre-conceived notions and biases.

My personal experiences with data reporting were in regulatory contexts that in the big scheme of things don’t matter much.  But I think the data I submitted was unambiguous and believe that my results could withstand scrutiny.  On the other hand, the implications of global warming are a big deal because they are being used as the rationale to completely over-haul the entire energy system of New York and the world.  Unfortunately, much of the numerical evidence purportedly proving that global warming is occurring is ambiguous and the results do not standup to close scrutiny.  My concern is that when I have gone through the process to evaluate data to check a climate change impact and shown that the claim is not supported by the evidence it has not been uncommon that people reject the results.

UPDATE – Revised on January 14, 2021

That brings me to the Election of 2020.  From what I have observed there were sufficient irregularities in the presidential election results that an open and transparent audit of the election results was appropriate.  For example, a verification analysis similar to ones I have done in the past looked at data with an algorithm looking for instances of unusually large sudden additions of votes in batches much faster than almost all the others, and far above the “normal” pace. “Odd” in this case means absurdly unusual — in Minnesota one dump at 5:30am was a net gain of 113,755 Biden votes at 19 standard deviations from normal or a probability of 1 in 1081. I am aware of one instance of a computer forensics analysis of the Dominion Voting System in one county in one state.  Something similar is needed anywhere “odd” data were observed.  These issues do not prove anything except that further review is needed.  I hope that there were valid reasons for the irregularities but now it appears we will never know.

In my opinion the failure to follow up and determine exactly what was going on with these irregularities was a massive failure and anyone who argues that it was unnecessary doesn’t understand, does not want to understand, or is covering up.   The failure to reconcile the data undermines my trust in the process and the system itself.


[1] For example, an arithmetic average of mostly startup data was used to say that facilities were not using their air pollution equipment correctly.

Climate Leadership and Community Protection Act Deep Carbonization Workshop

On December 8, 2020, the New York State Energy Research & Development Authority (NYSERDA) and the New York State Department of Environmental Conservation (DEC) hosted the “Deep Decarbonization Workshop”.  Given the enormous challenges ahead of New York trying to transition the electric energy system to be completely free of fossil-fired generation by 2040 I naively assumed that the workshop would focus on decarbonization technologies that could be used to help New York achieve its ambitious Climate Leadership and Community Protection Act (CLCPA) goals.  Instead, with one exception, it was an infomercial for solutions that ignored New York’s specific needs and any limitations of the technologies described.


On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021.  The Climate Action Council and seven advisory panels: transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting political appointees and supported by agency staff are charged with this responsibility. 

Many of these political appointees were chosen to satisfy particular constituencies rather than for their technical expertise.  I maintain that it would be appropriate for them all to be given an overview of how the energy system, in general, and the electric system, in particular work.  Without that foundational knowledge I fear that their strategy recommendations will either not be grounded in reality or not be effective solutions.  Against that backdrop I hoped the workshop would address this need.

Instead, ”The workshop will feature presentations from nationally renowned technical experts such as the keynote speaker, Saul Griffith, a distinguished energy systems expert, inventor, entrepreneur, and engineer. Mr. Griffith, along with other experts, will discuss the opportunities and challenges around innovative climate solutions such as carbon capture; utilization and storage; green-hydrogen; hydrofluorocarbon replacements and process chemicals; and long-duration storage. The workshop will also feature a roundtable discussion with leading environmental justice advocates across New York State to explore how innovation in decarbonization can help advance environmental justice priorities.”

The CLCPA is the embodiment of the idea that political will can implement policies to meet stringent greenhouse gas reduction targets.  I believe many of the appointees accept that without question.  If anything, this workshop further misled those people.  Nothing in the workshop suggested that there might not be readily available proven technologies capable of replacing fossil fuels, much less the possibility that nothing exists today to solve the multi-day winter doldrum problem. This post briefly describes the presentations and missing context relative to the CLCPA.

Keynote Presentation

Saul Griffith set the tone of the workshop in his keynote presentation. His 15-minute presentation featured 53 slides so you can imagine his carnival barker schtick.  Don’t get me wrong the guy is brilliant. According to the Rewiring America website: “As Founder and Chief Scientist at Otherlab, an independent R&D lab, Saul Griffith helps government agencies and Fortune 500 companies understand energy infrastructure and deep decarbonization. He’s been a principal investigator and project lead on federally-funded research projects for agencies including NASA, Defense Advanced Research Projects Agency (DARPA), Advanced Research Projects Agency–Energy (ARPA-e), National Science Foundation and United States Special Operations Command (SOCOM). He was awarded the MacArthur “Genius Grant” in 2007.”

Unfortunately, his spiel is unrealistic magical thinking.  The underlying premise of his presentation was that a commitment to electrification and decarbonization makes it substantially easier to meet our energy demands.  He claims that 25% of our primary energy needs can be eliminated using distributed renewable energy generation because it reduces energy losses in production and transmission.

He goes on to claim that electrification of heating using heat pumps for homes, offices and some industry eliminates 6-7% more.  He illustrated how that is supposed to work in the following slide.

I will end my description of his presentation with this comment.  Griffith is from Australia and lives in the San Francisco area.  He is not familiar with the Upstate New York winter reality.  Here is my house in a typical winter.  His proposed plan is never going to work here.  By the way it usually is this cloudy and the snow was not particularly deep in this picture.  I can tell because I did not clean the snow off the roof.  One other issue with our winters is the occasional ice storm.  What do these people think will happen when there is no electricity for extended periods? 

Long Duration Storage

Scott Litzelman from U.S. Department of Energy – Advanced Research Projects Agency – Energy gave the most relevant presentation “Long-Duration Energy Storage as a Decarbonization Enabler”.  The organizers should have explained the connection between this resource and the E3 analysis Pathways to Deep Decarbonization in New York State – Final Report . E3 has explained that Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”   While it should be obvious that long-duration storage is needed for firm capacity resources I don’t think that all of the political appointees recognize the enormity of the particular challenge in New York.  The workshop squandered what would have been a perfect opportunity to make the point that if they cannot solve that problem this won’t work.

The presentation itself was pretty technical.  For the Climate Action Council and Advisory Panel members the presentation should have addressed the specifics of New York’s targets.  More importantly, there was no discussion whether the technologies discussed might be ready to be deployed in time for use to meet the CLCPA targets.


Sunita Satyapal, Director- Hydrogen Program, U.S. Department of Energy, presentation “U.S. Department of Energy Hydrogen and Fuel Cell Technologies Office and Global Perspectives” was a pep talk for a hydrogen economy.  For example, he claimed that there has been a 25-fold increase in deployment in the last decade of electrolyzers that produce hydrogen.  Whether the world-wide deployment of 25 MW in 2019 offers hope or not was not discussed.  Just for context, On September 10, 2020 the Analysis Group presented a discussion of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study.  Their analysis included a generic resource that I think is the biggest problem for the CLCPA.  They call this resource the Dispatchable & Emissions-Free Resource.  It was “included to maintain reliability during the highest load hours of each modeling period” to “provide the majority of energy on the peak winter hour during the CLCPA load scenario”.  Their analysis shows that this category makes up 19% (32,137 MW) of the total capacity for their projected CLCPA load scenario.  Clearly hydrogen deployment with a world-wide deployment of 25 MW has a long way to go to provide any meaningful support to the CLCPA.  The rest of the presentation described many potential hydrogen technologies but completely ignored the context of the implementation needs for the CLCPA.  Completely ignored were the significant technological issues with hydrogen and the weak economic case.

Dr. S. Julio Friedmann, Center on Global Energy Policy, Columbia University gave a presentation entitled “Circular Carbon Economy with Carbon Capture, Carbon to Value, and CO2 Removal”.  His circular carbon economy consists of four components: reducing CO2 emissions, reusing CO2 where possible, recycling CO2 by altering their composition, and removing CO2 after it is produced.  The emphasis was on carbon capture and sequestration (CCS) in different forms.  He claimed there are 20 operating plants that are storing 35 million tons of CO2 per year worldwide.  He also claimed that the science and technology is well established.  According to the International Energy Agency there were 33 giga tons of CO2 emissions in 2019.  In other words, CCS is treating about one thousandth of the world’s emissions.  Again, there was no discussion of CCS in the context of New York.  Importantly, for it to be viable in New York there have to be locations where it can be stored but that issue was not discussed.

The final presentation, “Keeping cool without warming the planet (alt: heat pumps that don’t heat the globe), Climate Friendly Alternatives for High GWP Hydrofluorocarbons”, was presented by Kristen N. Taddonio, Senior Climate & Energy Advisor, Institute for Governance & Sustainable Development.  According to her, hydrofluorocarbons (HFC) have high global warming potential, climate friendly HFC alternatives can avoid up to 0.5 °C of warming and combining energy efficiency can avoid another 0.5 °C of warming.  I accept that there are climate friendly alternatives but am a little leery of the claims that 1 °C of warming can be avoided.  Just how much warming are they expecting?  More importantly is the New York context.  New York’s CLCPA 1990 emission inventory only has a total of 0.05 million metric tons global warming potential of HFC (less than 0.1% of the total) and the latest NYSERDA inventory has 10.37 million metric tons global warming potential of HFC which is less than 5% of the total.  We will have to wait to see what the current emission inventory fraction of HFC will be but I have no reason to believe it will be a significant fraction of the total emissions inventory. 


The CLCPA deep de-carbonization workshop wasted a perfect opportunity to bring some reality to the implementation challenges to: reduce greenhouse gas emissions 40% from the 1990 baseline by 2030, produce all electricity from zero-emission sources by 2040, and reach net-zero by 2050.  Based on my observations of panel discussions I believe many of the individuals charged with the responsibility for developing the scoping plan to implement strategies to meet those goals do not understand the enormity of this task.  A workshop to explain how energy systems work and quantify how much energy is needed and where to provide reliable power would give the panel members a common basis. 

Instead, the workshop mostly reinforced the notion that CLCPA targets will be met because of the political will of the State.  Long-duration energy storage is the key need and the presentation provided some hope in this regard.  Unfortunately, the presentation did not address the availability or applicability to New York so it is not clear if there is a viable solution to this critical requirement in the timeframe needed.  The keynote, hydrogen, and carbon sequestration presentations all sound great superficially but no context relative to the New York needs was given and they all have serious technological or implementation issues.  The hydrofluorocarbon presentation showed that there may be a solution to address this greenhouse gas but there was no mention of the fact that this is not a big deal for New York.

Finally, the workshop included an environmental justice representative roundtable discussion.  I did not listen to that, there are no slides from it and no recording has been posted. 

Response to My Comments on Part 496 – Climate Leadership and Community Protection Act 1990 Emissions Baseline

In late October 2020 I submitted personal comments on the New York Department of Environmental Conservation (DEC) proposed Part 496 that defined the emissions limits for the Climate Leadership and Community Protection Act (CLCPA).  That law sets targets based on 1990 emissions and this regulation developed the emission inventory for 1990.  The rule was recently adopted and the regulatory package included a document that assessed public comments.  This post follows up on the post on my comments and describes their response to my comments.  It is relevant to CLCPA implementation because the DEC did not respond to my primary objective – monitoring data do not support the emphasis on methane emissions in the inventory and the CLCPA.

I am following the implementation of the CLCPA closely because it affects my future as a New Yorker.  If DEC gets the 1990 baseline wrong it will be all the more difficult to get to the aggressive CLCPA targets.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


This 1990 emissions inventory is important because many of the targets of the CLCPA are based on reductions from this baseline.  For example, there is a target to reduce GHG emissions to 60 percent of 1990 emissions levels by 2030.  The CLCPA includes specific requirements for the 1990 emission inventory that I am positive no legislator who voted for the law understood.  

The law mandates an aggressive schedule for developing this inventory.  The CLCPA 1990 baseline is supposed to be set by the end of 2020 but the first statewide greenhouse gas emissions report isn’t due until 2021.  The statewide emissions report is defined as a “comprehensive evaluation of the inventory best available science and methods of analysis, including the comparison and reconciliation of emission estimates from all sources, fuel consumption, field data, and peer-reviewed research”.  It “shall clearly explain the methodology and analysis used in the department’s determination of greenhouse gas emissions and shall include a detailed explanation of any changes in methodology or analysis, adjustments made to prior estimates, as needed, and any other information necessary to establish a scientifically credible account of change”.  The 1990 baseline for the statewide GHG emission limits has similar quality requirements: “In order to ensure the most accurate determination feasible, the department shall utilize the best available scientific, technological, and economic information on greenhouse gas emissions and consult with the council, stakeholders, and the public in order to ensure that all emissions are accurately reflected in its determination of 1990 emissions levels”.

I compared the proposed Part 496 1990 emission inventory with the previous “official” New York greenhouse gas emission inventory that was prepared by the New York State Energy Research and Development Authority (NYSERDA) in two earlier posts.  The Part 496 Regulatory Impact Statement (RIS) includes a section titled Key Requirements of the 1990 Emission Baseline section that explains the CLCPA mandates that required DEC to develop a new official inventory.   These requirements significantly affect the greenhouse gas (GHG) emission total for the State.  According to the latest edition of the NYSERDA GHG emission inventory (July 2019) Table S-2 New York State GHG Emissions 1990–2016 the New York State 1990 GHG emissions were 236.18 MMtCO2e The proposed Part 496 regulation 1990 emissions inventory total is 401.38 MMtCO2e for an increase of 165.2 MMtCO2e.  When the draft Part 496 regulation came out, I described the differences between these two inventories.

Summary of 1990 Emission Inventories   
Final Rule Regulatory Impact Statement Table 1 Inventory in GWP20.
Energy259.9671.761.32  4.00337.04
IPPU1.76  0.900.050.012.72
AFOLU0.0513.074.01   17.13
Waste3.0349.350.50   52.88
NYSERDA July 2019 Table S-2 Emission Inventory in GWP100
Energy168.84 3.120.83   172.80
IPPU1.16   0.349.48 0.17 11.15
AFOLU 4.51 4.25   8.86
Waste 12.2 0.61    12.80
Total170 19.835.790.349.480.17205.61

Response to Comments

To its credit New York State requires that DEC respond to comments on proposed regulations.  Unfortunately, too often the answer is in the back of the book and this is considered just a formality.  In my opinion this was the case with the response to my  comment Part 496.  I consolidated and annotated all the responses to my comments in DEC response to Caiazza Comments.  I will just highlight a few of my concerns with their responses.

For a variety of reasons DEC dismissed my comments suggesting that the documentation was inadequate. I claim that in order to “utilize the best available scientific, technological, and economic information on greenhouse gas emissions and consult with the council, stakeholders, and the public in order to ensure that all emissions are accurately reflected in its determination of 1990 emissions levels”, that DEC must document each value listed in the inventory with the emission factor, activity factors or throughput, and the reference and rationale for each.  DEC claims that they provided the information.  I maintain that it is impossible to replicate their numbers with the information provided because the references are so vague that it is impossible to trace the necessary information back to the references provided.

It is particularly troubling to me that the response to comments does not address changes to the draft and final inventory.  As shown below there were substantive changes to the CO2 and CH4 emissions.   As it stands now the council, stakeholders and public just have to accept the numbers without explanation – hardly a hallmark of “best available scientific, technological, and economic information” required by the CLCPA.  Clearly, if there was adequate documentation he derivation of each number and the differences could be easily explained. 

Difference Between the Proposed Total Statewide Greenhouse Gas Emissions in 1990 by IPCC Sector and Gas, in GWP20 and the Final Emissions


My over-arching comment was that there was too much of an emphasis on methane.  DEC summarized my comment as follows: “Some commenters suggested additional or alternative emission limits, including interim limits to maintain momentum or targets that recognize the long-term impacts of GHGs. Otherwise, the law over-emphasizes the role of methane or under-emphasizes the role of carbon dioxide by applying the 20-year rather than the more standard 100-year GWP.”   DEC evaded a direct response by correctly noting that the CLCPA required consideration of the upstream emissions and the 20-year GWP.  The authors of the CLCPA deliberately included those provisions as part of New York’s irrational war against natural gas.  While this accounts for much of the differences between the two inventories, the state’s choice of emission factors also contributes. DEC did not directly respond to a critical question about their inventory.

I have been involved with emissions inventories for over 45 years.   One thing I learned early on was that however much time and effort is spent on an emission inventory the ultimate check on any emissions inventory is comparison of the inventory estimate with observed ambient monitoring.  If there is a high quality, long-term monitoring network that measures the pollutant in the inventory and those measurements do not reflect the trend in the inventory then the inventory is wrong.

Lan et al., 2019 evaluated data from the National Oceanic and Atmospheric Administration Global Greenhouse Gas Reference Network and determined trends for 2006–2015.  This covers the period when the primary target of the CLCPA upstream emissions requirement, Pennsylvania shale-gas production, increased tremendously.  According to the plain language summary for the report: “In the past decade, natural gas production in the United States has increased by ~46%. Methane emissions associated with oil and natural gas productions have raised concerns since methane is a potent greenhouse gas with the second largest influence on global warming. Recent studies show conflicting results regarding whether methane emissions from oil and gas operations have been increased in the United States. Based on long‐term and well‐calibrated measurements, we find that (i) there is no large increase of total methane emissions in the United States in the past decade; (ii) there is a modest increase in oil and gas methane emissions, but this increase is much lower than some previous studies suggest; and (iii) the assumption of a time‐constant relationship between methane and ethane emissions has resulted in major overestimation of an oil and gas emissions trend in some previous studies.”

As a result of the fact that the relevant high quality, long-term monitoring network does not show a trend consistent with the Part 496 presumption that a big source of methane is from Pennsylvania natural gas extraction, I believe that unequivocally shows these calculations of methane emissions from shale gas are invalid.


The CLCPA mandates that the law will be implemented using “best” science.  Part 496 does not meet that condition.  Francis Menton explains the exposition of the scientific method from physicist Richard Feynman’s classic series of recorded lectures: “[W]e compute the consequences of the [hypothesis], to see what, if this is right, if this law we guess is right, to see what it would imply and then we compare the computation results to nature or we say compare to experiment or experience, compare it directly with observations to see if it works.  If it disagrees with experiment, it’s wrong.  In that simple statement is the key to science. . . . “

I found references that directly contradicted the Part 496 methane emissions and, more importantly, a citation that found that the observed monitoring observations of methane do not support the inflated values used in the inventory.  It disagrees, it’s wrong, so the Part 496 inventory fails a basic tenet of science.  DEC’s response to comments did not address this issue.

RGGI Leakage

In November 2019 the Regional Greenhouse Gas Initiative (RGGI) released their annual RGGI electricity marketing report.  I have not been following this annual report but have been looking at emissions leakage and realized that it is supposed to address RGGI leakage.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Emissions Leakage

Emissions leakage refers to the situation where a pollution reduction policy simply moves the pollution around geographically rather than actually reducing it.  Ideally if you want to solve global warming with a carbon price then you want to apply it to all sectors across the globe so that it cannot occur.  In general, I don’t think a global carbon pricing scheme is ever going to happen because of the tradeoff between the benefits which are all long term versus the costs which are mostly short term.  I don’t see how anyone could ever come up with a pricing scheme that equitably addresses the gulf between the energy abundant “haves” and those who don’t have access to reliable energy such that “have nots” will be willing to pay more (as carbon taxes) as they catch up with those who have abundant energy.


Despite this potential problem, carbon pricing schemes including the RGGI cap and auction program have been implemented in small jurisdictions.  When RGGI was being developed emissions leakage was a big concern.  In March 2007, the Emissions Leakage Staff Working Group submitted a report: Potential Emissions Leakage and the Regional Greenhouse Gas Initiative (RGGI): Evaluating Market Dynamics, Monitoring Options, and Possible Mitigation Mechanisms.  The report noted that “Under a “middle-of-the-road” scenario, cumulative emissions leakage was estimated at 27% of net CO2 emissions reductions through 2015” but “Projected emissions leakage is predominantly in the form of a shift in the location of new natural gas-fired power plant builds, rather than decreased utilization of existing plants”. In an independent analysis, Kolodziej and Wing (2008) used theoretical and numerical general equilibrium models to evaluate potential leakage and concluded that “Although RGGI’s economic impacts are small, they induce substantial increases in power exports from unconstrained states which result in emission leakage rates of more than 50%”.

The 2007 Emissions Leakage Staff Working Group report recommended that “for the purpose of quantifying and determining the extent of potential emissions leakage, ensuring that leakage does not undermine the emissions reductions achieved by the program, and supporting RGGI’s goals of monitoring emissions leakage, it is essential to be able to track and verify the environmental attributes associated with all the power being generated and used within the RGGI region, as well as the environmental attributes of power generated in adjoining regions”.  The emissions page in the allowance tracking category of the RGGI website notes “As part of RGGI’s program design process, the participating states determined that regular reports would be made to monitor and track power generation serving load in the RGGI region, as well as the emissions associated with that generation.”

RGGI Leakage

I believe that the RGGI electricity marketing reports represent the commitment to track leakage.  They summarize data for electricity generation, net electricity imports, and related carbon dioxide (CO2) emissions for the states in RGGI.  One metric presented could “provide a preliminary or potential indication of emissions leakage, or a lack thereof”.  However, there is a caveat: “because this report does not establish the causes of observed trends, it should be emphasized that this report does not provide indicators of CO2 emissions leakage”.

The most recent report, CO2 Emissions from Electricity Generation and Imports in the Regional Greenhouse Gas Initiative: 2017 Monitoring Report, states that:

Annual average net electricity imports into the nine-state RGGI region increased by 22.2 million MWh, or 39.6 percent, during the 2015 to 2017 annual average compared to the 2006 to 2008 base period. CO2 emissions related to these net electricity imports decreased by 2.3 million short tons, or 9.1 percent, during this period, indicating a reduction in the average CO2 emission rate of the electric generation supplying these imports of 317.0 lb CO2/MWh, a reduction of 35.0 percent.

Compared to the annual average during the 2006 to 2008 base period, 2017 electric generation from RGGI generation decreased by 54.6 million MWh, or 31.7 percent, and CO2 emissions from RGGI generation decreased by 73.9 million short tons of CO2, or 53.4 percent. The CO2 emission rate of RGGI electric generation decreased by 509.4 lb CO2/MWh, a reduction of 31.7 percent.

One could easily assume that at least some of the observed decrease in generation within the RGGI states was caused by the increased imports. In the worst case 22.2 million MWh of the observed decrease in the 2017 54.6 million MWh electric generation decrease from RGGI generation could be caused by leakage.  However, in order to make that assumption you have to presume that the RGGI effect on prices was the only driver of imports.  I have found analyses that claim RGGI’s effect on emissions ranged from 17% and 24% but because the cost adder of the RGGI carbon price was relatively small I do not believe that the RGGI price drove affected source control decisions.  As a result, I believe that the only reductions from RGGI that can be traced to the program are the reductions that result from direct investments of the RGGI auction proceeds.  Therefore, RGGI investments are only directly responsible for less than 5% of the total observed reductions.  As a result, that suggests that the change in imports wasn’t primarily caused by RGGI but other factors so leakage is not an issue at this time.

However, there could be big changes to RGGI compliance coming.  Because the allowance cap is decreasing and the share of banked allowances owned by investors is increasing, I believe that there will be a significant price increase in the next several years.  Moreover, there are few opportunities left for fuel switching left at RGGI-affected sources and that has been the primary cause for the observed emissions reductions to date.  That will put additional pressure on RGGI region prices.  As a result, leakage may become an issue soon.  One caveat is that New Jersey joined the program in 2020 and Virginia will join soon thereafter and that could defer these issues down the road.


I have to comment on one disappointing aspect of the RGGI monitoring reports.  Leakage was a major stakeholder concern going into the program and I believe that this report was intended to address that concern.  However, the report notes that “because this report does not establish the causes of observed trends, it should be emphasized that this report does not provide indicators of CO2 emissions leakage”.  With all due respect, I think the report should actually make its best estimate of CO2 emissions leakage because it is a potential problem.  However, if the report showed that leakage was a problem, then that would be embarrassing if not a flaw in RGGI.  As a result, it is not surprising that the report ducks the issue.

I conclude that to this point leakage has not been an issue. However, the lack of leakage is because fuel switching reduced emissions without raising prices.  When fuel switching no longer becomes an option, I expect that the costs to reduce emissions will create a boundary price differential that will lead to RGGI leakage.  Unless the addition of New Jersey and Virginia create opportunities for cost-effective reductions then RGGI leakage will become a problem in the next several years.

3 March 2020 New York Climate Action Council Meeting

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  The legislation set up the Climate Action Council to figure out how to implement the rule.  This post summarizes the first meeting of the Council.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  Given the results for other jurisdictions that have implemented renewable energy resources to meet targets at far lower levels I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


The politicians who passed the CLCPA mandated a reduction of New York’s GHG emissions to 60 percent of 1990 emissions levels in 2030 and that emissions from electricity production would be zero by 2040.  However, they just assumed that their targets could be met and only mandated that two years of the effective date of the legislation the Climate Action Council would prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule.  In other words, this is a classic cart before the horse legislation example.

The Albany Times Union described the first meeting of the Climate Action Council as “uneventful” with cordial interactions, they did note “remarks by members signaled the tough questions the group will be grappling with in coming months and years”.  “How do we assess the cost of all this?” asked Donna DeCarolis, president of National Fuel Gas, a western New York energy company.

The New York Climate Act web page appears to be the new face of the program.  It includes a sign-up link to be on the contact list for new developments, and a fact sheet for the Climate Act.  There also is a general description of the Climate Action Council and a list of members.  Finally, there is a link to the first meeting materials and a recording of the session.

March 3, 2020 Climate Action Council Meeting

The web page for the Climate Action Council included meeting materials for the first meeting:

Update March 6, 2020: There is a video of the meeting available at the Climate Action Council website.

The agenda had the following items listed:

      • Welcome and Introductions
      • Co-Chair Remarks
      • Presentation: Climate Science Considerations, Radley Horton, Columbia University
      • Presentation: Climate Act Requirements
      • Climate Act Goals
      • Bylaws
      • Advisory Panels
      • Next Steps

The meeting presentation was a power point covering the agenda items and the climate act requirements presentation.  I am not going to reproduce all the slides in this presentation but will call your attention to some items.  The slide entitled New York’s Climate Leadership list five items including “Groundbreaking Environmental Support: Restore Mother Nature Bond Act – $3 billion “Restore Mother Nature” Bond Act to restore our state’s environment and improve resiliency.”  I think that the presentation should have noted that this is a proposed bond and has not been approved by the public.  For a state that has serious water quality problems my personal opinion is that the majority of those bond revenues should go to those problems rather than climate initiatives but only time will tell how that works out.

One thing that caught my eye was the slide entitled major roles and responsibilities that listed the following items:

      • Climate Action Council: Prepare and approve a scoping plan of recommendations to achieve 40×30, 85×50, carbon neutrality
      • Climate Justice Working Group: Establish criteria to identify and develop a list of disadvantaged communities
      • Just Transition Working Group: Conduct a study on job creation and workforce disruption related to the transition to a low carbon economy
      • PSC: Establish a program requiring load serving entities meet 70×30 and 100×40 targets
      • DEC: Promulgate the statewide greenhouse gas emissions limit regulation; establish a value of carbon; issue annual reports on statewide greenhouse gas emissions; promulgate regulations to implement the scoping plan
      • All Agencies: Implement strategies to reduce emissions; consider consistency with the Act in agency decisions

The climate justice working group will develop criteria for and list of disadvantaged communities and will report on barriers and opportunities for clean energy.  They will “ensure no increase in co-pollutant emissions or disproportionate burden on disadvantaged communities” and “DEC shall establish a community air monitoring pilot program in at least 4 disadvantaged communities”.  There also is a requirement to “Invest or direct available and relevant programmatic resources in a manner designed to achieve a goal for disadvantaged communities to receive 40% of overall benefits of spending on:

    • Clean energy and energy efficiency programs
    • Projects or investments in the areas of housing, workforce development, pollution reduction, low-income energy assistance, energy, transportation, and economic development

This legislation sets very aggressive targets to combat the supposed existential threat of climate change.  Nevertheless, the politicians still established these requirements which dilute resources from the primary goal and may spend money in ways that might not be the most cost-effective way to reach the targets.

I look forward to more information about the PSC responsibility to “establish a program requiring load serving entities meet 70×30 and 100×40 targets.  On the face of it, this is puzzling.  New York is de-regulated and the load serving entities do not generate much electricity so what are they supposed to do?  As a cynical New York resident, I suspect requiring them to meet the targets could ultimately transfer blame when things don’t work out.

Dr. Horton’s presentation “Climate Hazards, Impacts and Opportunities” included the usual litany of scary statistics and catastrophic projections used as rationale for the CLCPA.  One of my pragmatic environmental principles is the Baloney Asymmetry Principle first defined by Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”  There is so much BS in this presentation that I could spend weeks listing the caveats to claims, showing how data shown is often cherry picked to show the worst case, and how some of the information is mis-leading.  A simple list of examples of each will suffice.  The sea level trends and projections slide should be caveated to note that there are plenty of data showing none of the acceleration of sea-level rise that would be needed to reach the scary projections shown.  There are several references to climatic trends but note that the figures start in 1930, 1950 and 1958 which suggests that the starting points were cherry-picked to maximize the effect.  The global temperatures projections slides uses representative concentration pathway 8.5 which is mis-leading “The misuse of RCP 8.5 involves the transformation of what is more accurately described as a worst-case scenario into the sole ‘business as usual’ or baseline scenario that has become a centerpiece of climate policy discussions.”


So it begins, stay tuned.

Rare Snow Storms Today are Blatantly Obvious, Not

This post describes another evaluation of anecdotal evidence that is portrayed as evidence of global warming.  Previously I looked at a NPR radio segment in Great Lakes Vineyard Confronts Climate Change and examined a claim by a senior official at the Department of Environmental Conservation in Hay Harvest Climate Trend?.  This post addresses the frequency of snow storms in my home town.

Thread Posts

On the Facebook page “If you grew up” for my Oneonta, NY hometown group someone posted a conversation starter about the Old Farmer’s Almanac forecast for this winter.  This is the post that got me started:

“The winters we had when we are young are gone. It’s rare when we get a major storm. Amazing how much it has changed in 50 years – but people still deny the blatantly obvious.”

I responded to the first post with:

“If you look at the data rather than rely on anecdotal information and your memory (when I was a kid the snow came up to my waist all the time), then you will find that no one is ignoring the blatantly obvious. See for example: reference and reference

That prompted this response:

“The source you cite is suspect at best. Reference

I responded to that with this:

“My advice is to not trust anybody on any aspect of the global warming problem or purported solution.  Check out the numbers and data yourself.  The posts I referenced showed where they got their data and their data show that there is no “blatantly obvious” snowfall trend. Despite the “suspect” web site I stand by that position.”

That prompted this response:

“You are welcome to your opinions and to selectively choose which data you want to use, but opinions are just that. Some people also firmly believe that vaccines are horrible based on one dubious study that has been disproved, others believe the world is flat. The issue is that the climate is changing faster than it normally would due to man’s activity – some areas are getting dryer, others wetter, overall the temperature is rising but in some areas it will get colder. To dismiss the vast majority (@97%) of trained scientists and the blatantly obvious evidence in favor of the very loud deniers doesn’t make the 3%’s points valid. Reference

My response:

“I said check the numbers and data yourself.  In this instance all I am saying is that don’t confuse weather and climate.  Just because it some observed weather phenomenon is different does not necessarily mean it is related to global warming.

When you combine saying that climate is changing faster than normal due to man’s activity with the suggestion that disagreeing dismisses the vast majority of trained scientists, it is misleading based on my check of the claim and survey.  I think trying to determine the rate of climate change and figure out how much of the observed climate change is due to mankind is too difficult to be conclusive.  I have not found any survey that asked the policy relevant question about the rate of change and man’s actitivity.  Instead they basically asked whether there was a greenhouse effect.

I also said don’t trust anyone.  Search on 97% climate scientist myth and then search to find the other side of the story then decide for yourself.  Trying to do a similar comparison for the rate of climate change and contribution of mankind is more difficult so I don’t think you can do something similar easily.  Although I think I can offer a trained scientist opinion don’t trust me even though I have two degrees in meteorology, certification as a consulting meteorologist and over 40 years experience.”


First, let’s define weather and climate.  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.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”

The Northeast Regional Climate Center data sets provide processed values for temperature and precipitation for many observing sites in New York.  If global warming is affecting the winter storm climatology then there should be trends in either or both the daily snowfall or snowfall accumulation data.  In a previous analysis of weather vs. climate perception I analyzed data from Ithaca, NY which is just about 90 miles away from Oneonta. Because it was readily available and I think representative of snowstorms in Oneonta, I just used the data from that site for daily snowfall and snowfall depth.  I also said trust no one so if anyone wants the data I can provide that for your own analysis.

I did a simple analysis of the daily snowfall and snowfall accumulation.  In both cases, I fit a linear regression model to describe the relationship between the daily values and time for the months November, December, January, February, and March. I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses because it enables the user to choose the best relationship from 27 different linear regression equations.  I determine which linear regression model provides the best fit and then use that model to describe the data. If the calculated probability value (P-value) is less than 0.05, there is a statistically significant relationship at the 95.0% confidence level and I defined the test result as significant.


The purpose of this analysis was to determine if the frequency of major snowstorms in Central New York has changed due to climate change.  In this analysis I looked at climatic changes over the period of record from Ithaca and calculated the trend over the entire period for daily snowfall amounts and daily snowfall depth.  The Ithaca, NY Daily Snowfall Depth December 1899 through March 2019 figure shows quite a bit of variation.  Although there is a statistically significant increase in daily snow depth over this period the trend is only one inch per century.    Given the variation across the graph I do not consider this to be meaningful.  TheIthaca, NY Daily Snowfall (Inches) figure similarly shows so much variation that claiming any kind of trend is dicey but there also is a statistically significant increase in daily snow fall.  These data show that there is no trend towards fewer storms.

So why is there an impression that it is rare that Oneonta no longer gets major storms?  In the Ithaca, NY Extreme Daily Snow Depth and Snowfall (inches)table note that if the winters when you were young were around 1960 there were a couple of years when the snow depth was over 24” out of six in over 100 years.  Similarly, if your youth was in 1971 and 1972 there were two storms with snow over 16” out of the eight storms in over 100 years.  No question that would give the impression that the winters were different in your youth.

Another important point to keep in mind is that you could change the results by picking a different starting point for the analysis.  I also suspect that you could get different results by screening the data differently.  The choices I made were the simplest.  One you start tweaking input assumptions you can be rightfully accused of statistical manipulation.


These data illustrate the point I tried to make in the Facebook posts.  In my experience, whenever I have looked at the data behind a climate change related claim it was more complicated, more uncertain, and often contradictory to the claim made.   It is also difficult to separate whether the observed phenomenon is just weather variability or climate trend.

This post does not prove that there isn’t climate change, that mankind is not having an effect on climate, or that it isn’t appropriate to do something. If this were just a simple scientific disagreement it could be shrugged off as inconsequential.  Unfortunately, in New York State this kind of anecdotal evidence has been used to justify last summer’s Climate Leadership and Community Protection Act (CLCPA) which has been described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act. Look at those references to get a feel for what is in store for New York.

I have spent a lot of time trying to figure out what this law could mean.  For example, my latest estimate for the cost for the energy storage batteries needed when winds are light at night during the winter is $176.3 billion through 2050.  The United Kingdom has similar legislation in place and it was recently announced that their plan would require conversion of all gas central heating to electric.  I expect no less here.  As a result when I see anecdotal information used to justify these costly programs I have to respond.

Hay Harvest Climate Trend?

At a recent meeting I ran into Lois New who, before she retired, was the Director of the New York Department of Environmental Conservation’s Office of Climate Change.  I have known her for years and we worked together during RGGI stakeholder meetings. During our conversation she mentioned that her neighboring farmers were seeing the effects of climate change because they were having more trouble getting hay in before winter.  I said I thought it was more likely weather, she disagreed, and that ended the conversation.  This post looks at data to see if there is, in fact, a climatic trend for worse weather for haying.

First, let’s define weather and climate.  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.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.”

New York State policy is all in that there is an imminent and inevitable climate change catastrophe that can only be averted if we do something.  In this case New York’s version of doing something is the Climate Leadership and Community Protection Act (CLCPA) which was enacted last summer.  It is described as “the most ambitious and comprehensive climate and clean energy legislation in the country”.  When Governor Cuomo signed the bill he said:

“The environment and climate change are the most critically important policy priorities we face.  They literally will determine the future – or the lack thereof. Even in today’s chaos of political pandering and hyperbole there are still facts, data and evidence – and climate change is an undeniable scientific fact.”

In order to rationalize these statements Governor Cuomo has a long history of attributing any observed unusual or extreme weather to climate change’s effects being seen today.

Paul Homewood at the Not a Lot of People Know That web page authored a couple of recent articles slamming NY Governor Cuomo for a couple of examples. The first article points out that his statement that “we did not use to have hurricanes, we did not have super storms, we did not have tornadoes” is dead wrong.  The second article entitled “Cuomo’s Fake Claims About Extreme Rainfall” noted that Cuomo implied in an MSNBC interview (referenced in the blog post) that extreme rainfall was getting much worse in NY State.  However, Homewood showed that “there is absolutely no evidence of that at all” at the long running Ithaca station or a New York City station.

As a member of the Governor’s inner climate circle Ms. New must have been a part of the public relations campaign justifying the CLCPA.  Her claim that farmers cannot complete harvesting hay because of climate change is entirely consistent.  This post will look at the facts, data, and evidence that there is a climate effect on haying.   Homewood referenced a link to precipitation data at which is what I needed to do this analysis.


According to Mother Earth News in a Guide to Growing, Harvesting and Baling Hay “there are three steps involved in turning a green crop into what can rightfully be called hay:

      1. Cutting (followed by partial drying.)
      2. Windrowing (followed by further drying.)
      3. Baling hay or stacking hay.”

For our purposes the key is that freshly cut hay has to be dried because if hay is tied into tight bales when it still contains moisture it will go through a curing process that creates heat which can lead to self-combustion.  Therefore, farmers do not want to bale their cut crop until the moisture is less than 20%.  To do that the cut grass is allowed to dry for up to several days, then raked into rows and allowed to dry out most of the moisture.  Once dry then the hay can be baled.

The Northeast Regional Climate Center data sets provide processed values for temperature and precipitation for many observing sites in New York.  I chose to look at two stations with long records: Ithaca (1894-2019) and Mohonk House (1896-2019 with 1899 missing).  I downloaded the daily maximum, minimum, and average temperatures, precipitation amount, snowfall amount, snow depth and growing degree days.  A growing degree is the difference between average temperature in deg F and 50.  For example, if the average daily temperature is 60 deg F then there are ten daily growing degree days for that date.

I assumed that in order to harvest hay that the farmer would need to have at least four days when there was no precipitation greater than 0.05”.  Whenever that threshold was reached or exceeded the Harvest-Day parameter was set to one.  The total number of days that met this criterion in each month was summed along with the number of growing degree days per month for the growing season that I set as May through October.

I did a simple analysis of the two data sets.  I calculated the growing degrees and number of harvest days for each month in the growing season that I defined as May 1 to October 31.  I summed these values for the whole growing season.  I also summed values for the fall hay harvest season that I defined as August and September.  I fit a linear regression model to describe the relationship between growing degree days and hay harvest days by year for the whole growing season and just August and September. I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses because it enables the user to choose the best relationship from 27 different linear regression equations.  I determine which linear regression model provides the best fit and then use that model to describe the data. If the calculated probability value (P-value) is less than 0.05, there is a statistically significant relationship at the 95.0% confidence level and I defined the test result as significant. In addition, I calculated simple statistics to describe the two data sets.


The purpose of this analysis is to evaluate the claim that farmers are having more trouble getting their hay harvested because of climate change.  If that were in fact the case then we would primarily expect to see a trend in decreasing hay harvest days and to a lesser extent a decrease in the number of growing degree days.  The linear regression statistical results for two sites over the entire growing season and August and September were evaluated.  Overall eight tests were done with the following results:

Mohonk Growing Season hay-harvesting days

      • Insignificant reduction in the number of hay-harvesting days over the growing season

Mohonk Growing Season growing degree days

      • Significant increase in the number of growing degree days over the growing season

Mohonk August and September hay-harvesting days

      • Significant increase in the number of hay-harvesting days in August and September

Mohonk August and September growing degree days

      • Significant increase in the number of growing degree days in August and September

Ithaca Growing Season hay-harvest days

      • Significant reduction in number of hay-harvesting days over the growing season

Ithaca Growing Season growing degree days

      • Significant reduction in growing degree days over the growing season

Ithaca August and September hay-harvest days

      • Insignificant reduction in number of hay-harvesting days in August and September

Ithaca August and September growing degree days

      • Significant reduction in growing degree days in August and September

Of the eight tests: three were consistent with the hypothesis that getting hay harvested is getting more difficult because hay-harvesting days and growing degree days decreased, three were inconsistent with the hypothesis because hay-harvesting days and growing degree days increased, and two tests were statistically insignificant.  Note that if growing degree days are going down that is an indication that temperatures are cooling and not warming.

Another way to look at the climate change impact is to statistically evaluate the data.  The Ithaca Hay Season Climatological Normal and Last 30 Year Dataand the Mohonk House Hay Season Climatological Normal and Last 30 Year Data tables include climatological normal data, the last 30 years of data, and summary statistics.

I believe that one way to check climate change claim effects is to check the 30-year average from the beginning of the period of record with the 30-year average at the end of the period of record.  I also believe that there are multi-year weather cycles of differing lengths and if that is the case then arbitrarily picking these two periods may not be representative.  Therefore, consider this comparison with caution. At Mohonk House the growing season hay harvesting days decreased by two days but the August and September days increase by three days.  The Ithaca growing season hay harvesting days decrease by five days but the August and September days stayed the same.

Importantly, these data also indicate that there is a lot of inter-annual variation in hay harvesting days.  The standard deviation of the August and September data at Ithaca was 6, the minimum was 2 and the maximum was 28. At Mohonk House the standard deviation was 8, the minimum was 0 and the maximum was 43.  The difference between the first 30-years and the last 30-years is less than the standard deviation variation.  Therefore, I don’t think it is reasonable for anyone to claim that they can discern a climatic trend.

So why is there an impression that hay harvesting is getting worse?  A quick review of the last 30 years of data indicates to me that this impression is consistent with weather variations.  At Mohonk House in 2014 and 2015 there were a couple of years that were great for hay harvesting with half the days (31) in August and September suitable.  Jump forward to the last two years and there were only 11 and 12 days suitable.  In that short time frame of reference an alarming trend is evident.  However, also recall that the average number of hay harvesting days is 18 and with a standard deviation of 8.  So even though  2018 and 2019 data suggest there may be a problem, the data are within one standard deviation of the mean which means that they are well within natural variation observed since 1896.


The points that I want readers to remember are that climate numerical analysis results are likely ambiguous, picking a climatic trend out of weather records is not simple, and, most importantly, any statistically significant trends are likely smaller than the observed inter-annual variation.   As a result, anecdotal claims of observed changes of weather parameters due to climate change are likely biased and unsubstantiated.

This data analysis shows ambiguous results.  It suggests that there is conflicting support for a climate-change induced problem with hay harvesting in August and September.  Mohonk House data indicate a statistically significant trend in more days suitable for harvesting hay whereas Ithaca data indicate a trend towards less days suitable for harvesting hay but the trend is insignificant.  At both stations there is a negative statistically significant trend in the number of growing degree days.  Depending upon your intent, statistics can “prove” an argument that there is a problem or there isn’t a problem.

In order to do a comprehensive analysis to settle the question would take a lot of work.  Before doing any more analysis work, the evaluation data used should be confirmed as appropriate.  In order to represent the New York region adequately, stations across New York and the region would all have to be analyzed similarly.  It might also be appropriate to look at each month when haying is done.

I think the comparison of possible trends against inter-annual variation is illuminating.  If there is a climate change signal the difference between the first thirty years of the records with the last thirty years should show changes.  What differences that do exist are smaller than the observed variations.  All changes are less than one standard deviation from the mean.  I believe that this is a consistent problem for lines of the so-called evidence for climate change impacts observed in New York.

Based on this analysis I believe that anecdotal claims of observed changes of problems with hay weather parameters due to climate change are likely biased and unsupported by the data.  The variations noted and ascribed to climate change are in fact due to weather.

I also think that similar analyses of other claims would provide similar results.  The Governor’s claim “Even in today’s chaos of political pandering and hyperbole there are still facts, data and evidence – and climate change is an undeniable scientific fact” and his tendency to blame any unusual weather on climate change are not supported by this analysis.  In my opinion, careful evaluation of data and evidence for most of his claims would find similarly ambiguous and less certain results.

NYS Green New Deal Announcement Summary

Governor Cuomo recently announced the New York State Green New Deal a “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”. I think that the Governor and advocates for this agenda need to explain how this will work, how much it will cost and how much it will affect global warming before we are committed to this path.

This summary of the program is one of a series of posts on the New York State Green New Deal. Cuomo billed this as part of his 2019 Justice Agenda: “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”. There were 12 proposals in part 4 “Launching the Green New Deal” of this agenda. I reference my summary posts on each below and include my indented and italicized comments.

Components of the Green New Deal

Mandate 100 Percent Clean Power by 2040 – This will mandate that all electricity will be “carbon free by 2040.

In 1977 there was a blackout in New York City and the New York System Independent Operator now has a rule that requires 80% of generation to be provided in-City. In 2017 the daily energy needed for the peak hour period was 219,078 mWh. Because renewable energy is diffuse the area needed for that much renewable power is likely unavailable within the City. This could be a fatal flaw in this mandate and the State must develop a plan to confront this reality.

New York’s Path to Carbon Neutrality – The heads of relevant state agencies and other workforce, environmental justice, and clean energy experts will develop a plan to make New York carbon neutral.

The path re-establishes a Climate Action Council and mandates a plan to meet the goals. Presumably they will use existing programs as a template. If the New York Green New Deal were to rely on the “successful” RGGI program for the reductions proposed the State is looking at a cost of $35.2 billion.

A Multibillion Dollar Investment in the Clean Tech Economy that will Reduce Greenhouse Gas Emissions – There will be $1.5 billion in competitive awards to support 20 large-scale solar, wind, and energy storage projects across upstate New York.

The competitive awards announced in January 2019 total $1.5 billion and are supposed to provide more than 2 million tons of carbon reductions. Assuming that they really meant carbon dioxide for the 2 million tons that means 750 dollars per ton reduction cost. In 2015 NYS electric sector CO2 emissions were 32 million tons. If the New York Green New Deal were to rely on the NYSERDA competitive award process for those reductions the State is looking at a cost of $24 billion.

Expand NY Green Bank and Catalyze at Least $1 Billion in Private Capital – The NY Green Bank is a $1 billion investment fund designed to accelerate clean energy deployment and they will expand its charter.

In order to reach the 100% clean power goal by 2040 the plan doubles distributed solar deployment to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023. If the Green Bank were to finance the deployment of 3,000 MW at the rate observed with their existing investments they would need over $2 billion. In 2015 NYS electric generation sector emissions were 32,000 tons. If the Green Bank was to finance the replacement of solar at the rate observed they would need over $41 billion.

 Chart a Path to Making New York’s Statewide Building Stock Carbon Neutral – There are plans for more energy efficiency investments.

New York State is the fourth most energy efficient state in the country now which is no small part due to investments already made which presumably improved the most efficiency at the lowest rate available. Given that the cost-effectiveness of future projects will be less the 20% further reduction goal is ambitious.

Direct State Agencies and Authorities to Pursue Strategies to Decarbonize their Investment Funds and Ramp Up Investment in Clean Energy – Commence a process to review and evaluate the feasibility and appropriateness of divesting from fossil fuels for agencies and authorities.

I think the most important investment strategy for the $240 billion dollars in New York funds should be economic rather than signaling virtue. The rationale for this mandate to divest is clear: divestment is not an investment strategy, or a way of putting direct economic pressure on energy companies. It is a political statement.

Increase Carbon Sequestration and Meet the U.S. Climate Alliance Natural and Working Lands Challenge – This will establish a carbon sequestration goal for our natural and working lands.

Based on results to date it is not clear how cost-effective these programs will be. However, the program that facilitates carbon sequestration in soil is a “no regrets” solution.

Create a Carbon-to-Value Innovation Agenda and Establish the CarbonWorks Foundry – This will create a Carbon-to-Value Innovation Agenda as a blueprint for the future of carbon-to-value technology as well as carbon capture, utilization and storage in New York.

The concept is to turn carbon dioxide into fuel and wasteful chemicals. While I am not a chemical engineer the idea that the waste products can be turned into a fuel without a whole lot of energy going back into the system seems a bit far-fetched. On the other hand the concept of using CO2 instead of sequestering it underground is appealing.

Deliver Climate Justice for Underserved Communities – The Green New Deal will help historically underserved communities prepare for a clean energy future and adapt to climate change by codifying the Environmental Justice and Just Transition Working Group into law and incorporating it into the planning process for the Green New Deal’s transition.

While no one argues that underserved communities should not be treated better, I am concerned that the direct costs of these programs will out-weigh any directed benefits. In my opinion the primary goal of the task force should be to keep electric energy affordable but it is not clear that is the first priority of this component of the plan.

Create a Fund to Help Communities Impacted by the Transition Dirty Power – This will provide funding to help communities that are directly affected by the transition away from conventional energy industries and toward the new clean energy economy

In my opinion this is an example of the political pandering of the Green New deal. If some block of voters is going to be disadvantaged then simply buy them off.

Develop Clean Tech Workforce and Protect Labor Rights – The Green New Deal will continue to require prevailing wage, and the State’s offshore wind projects will be supported by a requirement for a Project Labor Agreement.

In my opinion this is an example of the political pandering of the Green New deal. If some block of voters may benefit from this pork barrel spending then make sure they know there is pork available.

Make New York the National Hub for Offshore Wind and Deploy 9,000 Megawatts by 2035 -The Green New Deal will accelerate offshore wind progress in three specific areas: port infrastructure, workforce development, and transmission infrastructure.

According to the NREL’s 2017 Cost of Wind Energy Review, the levelized cost of energy of off-shore wind is over two and a half times more expensive ($124 per MWh vs $47 per MWh) than on shore wind. For the 9,000 MW of offshore wind mandated the estimated cost would be $6.3 billion.


A recent opinion piece in the New York Times notes that relying entirely renewable power systems is much more expensive and still not practical than a system that incorporates nuclear, geo-thermal and fossil-plants. The research paper notes:

Whichever path is taken, we find strong agreement in the literature that reaching near-zero emissions is much more challenging—and requires a different set of low-carbon resources—than comparatively modest emissions reductions (e.g., CO2 reductions of 50%–70%). This is chiefly because more modest goals can readily employ natural gas-fired power plants as firm resources.

However the opinion piece claims that Cuomo’s Green New Deal did not mandate an all-renewables system. I agree that the plan accepts existing nuclear power but I do not believe there is any indication that existing fossil fueled power would be replaced by anything but renewables aside from a platitude that mentions carbon sequestration. The Cuomo administration has consistently delayed or disapproved fossil fuel infrastructure so I believe it is appropriate to assume that the 51,473,000 MWhr of electric energy produced by coal, oil and natural gas in 2017 would be replaced entirely by renewables in the Green New Deal.

This is the challenge that Climate Action Council must address. How will that electrical energy be replaced, how much will that cost and what effect will that have on the environment.