Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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9/16/22  5:19 pm
Commenter: Kenneth Haapala, SEPP

Virginia Energy Plan, 2022

Thank you for the opportunity to comment on the comprehensive Virginia Energy Plan, 2022. I have reviewed the submission by Patrick Michaels, Gregory Wrightstone, James Ferguson, John Christy, and William Happer of the CO2 Coalition and fully endorse it.


My wife and I have been residents of Virginia since 1975. Several years ago, she was surprised when I agreed with her to explore moving to another state. We did not wish to be in the same trap our daughter in California is experiencing – high energy prices and blackouts brought on by governors and legislators who demonstrate the critical thinking skills of teenagers – if it feels good it must be right.


Early in my professional career I was an energy economist with skills in mathematical modeling. In 1976-77, I was hired to provide an independent review of the National Energy Models, particularly the Natural Gas Model. The models predicted that the US would soon run out of natural gas and that the world was running out of oil.


The computer code of the Natural Gas Model had a fundamental flaw which, when mathematics was rigorously applied, yielded economically absurd results – the higher the price of natural gas, the more gas consumers would buy – a positively sloped demand curve. This may occur in luxury goods such as diamonds, but not in commodities. The results of the model were meaningless. [Since I was unable to obtain the code of the oil model, I could not confirm it had a similar error.] However, nobody who reviewed my work disagreed with the conclusion, though they did not like it.


In the late 70s, the Carter administration continued price controls on oil and gas, enacted high taxes, appealed to conservation, and subsidized wind, solar, and biofuels as well treating coal as the miracle fuel. OPEC added to the intensity of the energy problem but did not create it. It became evident that for many in Washington, the purpose of computer modeling is to persuade, not to produce accurate testable results that match reality – physical evidence.


The Reagan administration partially alleviated the problem by removing price controls on the production of oil and gas. Many in Washington accused the administration as naive.


In North America starting about 2007 in the Barnett Shale formation near Fort Worth, Texas, the energy problem was eliminated by combining hydraulic fracturing [long used] with the use of sand or other proppants to keep the fractures open, combined with directional drilling. This has increased the ability to extract oil and gas from dense shale rock in many locations in North America and worldwide. Further, advances in high pressure-high temperature drilling have opened vast reserves in the Gulf of Mexico and elsewhere.


Back then, the energy crisis was a looming shortage; the world was about to run out of oil and gas. Now, the energy crisis du jour has become excessive availability of coal, oil, and natural gas, supposedly causing climate change, according to models. The global climate models that are being used to claim dangerous future warming have problems similar to those that claimed that the world is about to run out of oil and gas. They produce absurd results when compared with reality – that is, physical evidence.




The California Trap: Since these comments are on the 2022 Virginia Energy Plan replacing the 2018 plan the comments will focus on the deficiencies of the previous plan which are largely mitigated by the new plan. Only the principal deficiencies in global climate models that render them meaningless are presented near the conclusions.


Virginia’s 2018 energy plan was aligned with the California’s net-zero plan. Indeed, legislation was passed stating that Virginia would follow the appointed bureaucrats of the California Air Resources Board (CARB) in the sale of new automobiles. CARB has banned the sale of new gasoline powered automobiles by 2035 with the phase out beginning in 2026. This is a total abrogation of legislative responsibility of Virginia government to out-of-state bureaucrats with no accountability to the citizens of Virginia.


Further, the 2021 Multi-State Medium- and Heavy-Duty Zero Emission Vehicle Memorandum of Understanding committed to 30 percent of new truck and bus sales to be zero-emission by 2030 and 100 percent zero-emission by 2050. The supporters of that agreement have no concept of the cost of such vehicles or the capability of zero-emission emergency vehicles. According to reports, a new electric fire truck being delivered to Vancouver, Canada, is far more costly, has a pumping capacity of only 60% as compared to a diesel fire truck, It has an effective range of 20 miles – hardly suitable for suburban Virginia.


Worse, the 2020 Virginia Clean Economy Act requires the state to replace all fossil fuel generated electricity with renewable energy by 2045. The legislature and the governor had no understanding of what is required to replace fossil fuels and the cost of such action.


Fairfax and Loudoun Counties in Northern Virginia are home to many “cloud” storage facilities. Such facilities require 100% reliable electricity at all hours of the day and night, or they crash. Wind and solar cannot provide reliable electricity.


Many Virginia politicians talk of high-tech manufacturing such as computer chips. Computer chip manufacturing requires 100% reliable electricity within very tight tolerances for 4 to 8 weeks, depending on the complexity of the chip. A slight hic-up and the entire production line (one to two months of product) is lost. Wind and solar cannot provide reliable electricity.


In Virginia, much was made of proposed Dominion Electric’s offshore wind turbines. But Dominion Electric – indeed, cannot – guarantee even 50% generation, one-half of what is required for modern civilization. Dominion and its partners know that wind cannot produce reliable electricity. Any Virginia offshore sailor recognizes that in the summer high pressure systems, called Bermuda Highs, produce heat waves and no wind for extended periods. The actions by the legislature and the previous governor left the public to shoulder the cost of reliable electricity while they fantasized.


California is experiencing real electricity problems but claims these problems are caused by “climate change.” On September 6, the California Independent System Operator (CAISO) warned of a blackout and asked consumers to reduce energy use and not charge electric vehicles. The governor promptly blamed an unprecedented heatwave, but the heat was not unusual for the southwest US. Further, the state constitution makes clear that the legislature is responsible for electric utilities, and the legislature’s actions have been counterproductive.


With heavy subsidies for electric vehicles and decarbonization of the state’s power stations supplying the grid, which is dependent on natural gas for 32% of its average electricity power, there are no options. Even the UK appears to realize that green dreams are over, but California does not.


According to the CAISO website, on September 6 total demand for electricity was 51,424 megawatts at 5 pm and 43,986 megawatts at 9 pm. At 9 pm natural gas supplied 26,694 megawatts (61%) of the 9 pm demand and imports from other states supplied 7,821 megawatts (18%). Solar power was generating zero megawatts, and batteries were down to 335 megawatts. California is suing to prevent a pipeline from expanding. The gas comes from Canada. Yet 79% of the electricity it needed, when it was warning of blackouts, came from fossil fuels and imports. When it goes net zero, where will California get the electricity it needs to keep the lights on and the cloud operating? Why should Virginia follow its lead? See


Politicians talk about storage. My organization, SEPP, and others have searched for a demonstration project showing what storage is required for wind and solar to provide 100% reliable electricity. We have not found a single example anywhere in the world that is successful. King Island off Tasmania (population 1700) and El Hierro Island the smallest of the populated Canary Islands (population 11,000) both failed. Neither is a highly industrial economy, and both require about 40% diesel generation to fill in gaps. King Island uses a combination of back-up mechanisms, and El Hierro Island uses pumped-hydro storage.


Worldwide the largest successful pumped-hydro storage, is in Bath County, Virginia, which is replenished daily by nuclear and coal-fired power plants. No one knows how much it will cost to make Virginia net zero as now required by the 2020 Virginia Clean Economy Act and no realistic basis exists for making such estimates. The Act is a product of teenage dreams rather than mature critical thinking.


The Virginia Energy Plan 2022 offers more mature thinking than the prior one. It is a reasonable, not too expensive, compromise over the ideologically driven prior plan. Perhaps a utility-scale, affordable form of electricity storage may appear in the next few years. The plan offers to those who believe that affordable storage exists, or will appear shortly, the opportunity to develop forms of electricity generation they prefer without placing excessive burdens on those who are skeptical. What is important is that the true cost be shown to the consumer, not just the cost of electricity consumed but the cost of maintaining 100% (actually 99.99%) reliable electricity and how much of that is paid by wind, solar, and other unreliable generators.




The Greenhouse Effect: The Greenhouse Effect is necessary for life on this planet. Without it, growing vegetation would freeze at night, making land masses as barren as Mars (which has approximately the same rotation rate as earth.). In 1672, Isaac Newton published his experiments using a prism to divide white (clear) light into the color spectrum and then using mirrors to refract the colored light back into white light proving that the prism did not cause the colors of light. These types of experiments are now called spectroscopy – the measurement and interpretation of electromagnetic wavelengths (frequencies) that result from the interaction between electromagnetic radiation and matter. (For an analogy, think of turning the knob of an AM radio. Some stations come in with strong signals, and others are very weak.)


In the early 1800s many scientists questioned why the earth was so warm given its distance from the sun. The Irish / English Physicist John Tyndall solved the problem by using early spectroscopy to experimentally determine that certain gases absorb-reemit and scatter different wavelengths of heat energy (infrared radiation) given off by the surface of the earth. The principal gas is water vapor; carbon dioxide is a secondary gas. The others are minimal. Unfortunately, many scientists misunderstood Tyndall’s experiments including the noted chemist Svante Arrhenius, who published a paper on the influence of carbon dioxide (called carbonic acid) in 1896. In 1906, Arrhenius later backed down from his earlier calculations, but the latter paper is largely ignored. To justify its claim that carbon dioxide is a pollutant, the EPA used the earlier work of Arrhenius which he admitted was erroneous.


The use of spectroscopy in understanding the greenhouse effect is well established in physics yet ignored by global climate modelers. Based on studies by G. Hettner, in 1928 George Simpson noted a gap in the ability of greenhouse gases to absorb-reemit and scatter infrared radiation. This gap was given the term “atmospheric window.” (akin to a range on the AM radio dial where no stations appear). [Interestingly, over 20 million years ago some snakes, particularly pit vipers, developed sensitive organs that can pick up slight variations in infrared radiation to locate warm-blooded prey such as mammals and birds. Without the “atmospheric window” such an ability would not be possible.]


During World War II, German scientists further researched the “atmospheric window” in hopes of developing a missile guided by the heat of an airplane engine. In the 1950s, US Naval researchers expanded the German research and named an infrared guided missile after a local pit viper, the Sidewinder. With refinements, the missile has become extraordinarily successful even when used in head-to-head combat.


Additional weapons such as the Stinger shoulder-fired antiaircraft missile and the Javelin shoulder-fired anti-armor missile have been built on the concept. The success of these weapons depends on careful calculations of the influence of greenhouse gases from ground level to 60,000 feet, and above. The high-resolution calculations of the influence of greenhouse gases in the atmosphere are publicly available. These careful calculations are ignored by climate modelers. There is no evidence that adding carbon dioxide, or other greenhouse gases, will close the natural cooling of this “atmospheric window.”


Worse, climate modelers ignore over 40 years of comprehensive atmospheric measurements of temperature trends. The average warming over the entire record is about 0.13 degrees Celsius per decade (0.23 degrees F per decade) from all sources including volcanic activity cooling the atmosphere at the beginning of the record. Since the greenhouse effect occurs in the atmosphere, the projections, predictions, from models that ignore the atmospheric measurements are meaningless.


Unfortunately, the leading proponent of climate alarm is the UN Intergovernmental Panel on Climate Change (IPCC). what the IPCC terms atmospheric measurements are actually measurements taken from the surface or less than 7 feet above the surface. These measurements are influenced by changes at the surface such as urbanization, paving green areas and draining wetlands. They do not include the varying greenhouse effect which changes by altitude and latitude.


Finally, in its Third Assessment Report (AR3, 2001), the IPCC recognized that the climate system it was trying to model resulted in a coupled, non-linear chaotic system which cannot be modeled with any accuracy. The model predictions are meaningless and useless for energy policy.




There is no demonstration that wind, solar, and storage can deliver the reliable and affordable electricity within tight tolerances civilization needs. Continuing to assume they do is a waste of resources.


There is no energy crisis and no climate crisis. The models use to declare a climate crisis are highly flawed and unfit for predictions.


Virginia Energy Plan, 2022 is a solid replacement for Virginia Energy Plan, 2018 which contained multiple false beliefs. It benefits the citizens of Virginia with realistic critical thinking rather than dreams.



Kenneth Haapala, President

Science and Environmental Policy Project (SEPP)

Fairfax, Virginia



The Science and Environmental Policy Project (SEPP) was established in 1990 by the late S. Fred Singer, an atmospheric physicist, to challenge government environmental policies based on poor science. SEPP stands for objective science, based on physical evidence. SEPP examines questionable governmental policies, no matter how popular, to determine if policies are based on the rigorous application of the scientific method and not just a passing fad. In physical sciences the scientific method requires the examination of all physical evidence. SEPP is a non-profit, 501-(c)-3, educational organization. incorporated in Virginia.


Ken Haapala joined SEPP in 2010 and took over assembling and publishing its weekly newsletter, The Week That Was, now distributed electronically. It consists of about 7 pages of original writing and about 18 pages with links to scientific papers, articles, and reports of concern. Directly and indirectly, it is distributed to over 60,000 interested professionals worldwide including Europe, Russia, and China.

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