Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Stage Proposed
Comment Period Ended on 3/31/2023
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3/31/23  11:32 am
Commenter: Kenneth Haapala / SEPP

Repeal of CO2 Budget Trading Program

My wife and I have been citizens in Virginia since 1976. Although past retirement age, I am the president of a small, non-profit 501-(c)-3 corporation registered in Virginia and continue to work long hours on energy. My background is in Science and Mathematics including creating mathematical models. I’ve been commended for having an unusual ability to find errors in complex work, such as mathematical modeling.


Mathematics is the language of science. However, like every language it can mislead and deceive. Often, those most completely fooled are those who rely on the mathematics the most. In physical sciences, the results of models must be tested against all available physical evidence to avoid error.


In 1977, under a Federal contract I was tasked with reviewing the National Energy Model for natural gas which predicted that the nation would soon run out. I discovered a significant error in the mathematics that made the results meaningless. The efforts to dissuade me from producing these findings convinced me that for many in Washington the purpose of modeling is to persuade, not necessarily to make accurate predictions. My work was quickly buried. The fear of the nation running out of natural gas became a national policy.


We have seen many examples of model failures. In 1972 the Club of Rome used state-of-the-art mathematical modeling to predict limits to economic growth. The Club claimed without limiting population growth, civilization will plunge into war, famine, and chaos. The UN adopted this notion. But many societies ignored the dire predictions, and humanity is more prosperous than it has ever been, with a lower percentage of people in extreme poverty (substance living) than ever.


Today, mathematical models are being used to predict that rather than running out of coal, oil, and natural gas, we are using too much and will cause economic collapse with dire results. Elaborate mathematical models are used to claim that fossil fuels (coal, oil, and natural gas) are creating so much carbon dioxide that it will intensifying the greenhouse effect to the point the earth will become uninhabitable.


In the early 1800s many speculated why did the earth support life because it was so far from the sun? What heat it received by day would quickly dissipate at night. Starting in 1859, John Tyndall used early spectroscopy to develop experiments that gave the answer. Certain gases, he called greenhouse gases, in the atmosphere allowed sunlight to pass through to the surface, but slowed the loss of surface heat to space, keeping the earth warm enough to support life as we know it. Now we have groups using models who claim that which gives life is harming it. Where is the evidence?


The greenhouse effect occurs in the atmosphere, most importantly the lowest part, the lower troposphere. Over forty years of measurements from satellites show that the lower troposphere is warming at a rate of 0.13 °C per decade from all causes. This is one-quarter of a degree Fahrenheit per decade. On a typical spring morning in Virginia, it may rise by more than that in 5 minutes between nine and ten AM. The satellite measurements provide the most comprehensive measurements of temperature trends existing. They are independently supported by measurements with instruments on weather balloons and weather reanalysis data.


The global climate models used to predict dangerous future climate change from increasing carbon dioxide fail when tested against atmospheric temperature data, so the modelers ignore atmospheric data. In doing so, they shift from physical science to the art of political persuasion.


[The reasons for this failure are too complex to discuss here, but they include use of surface data rather than atmospheric data, great overestimation of increasing water vapor, and confusing natural trends as caused by carbon dioxide.] In short, the climate modelers fail to give physical evidence that carbon dioxide emissions are causing dangerous warming.


The foolish notion that carbon dioxide emissions are leading to dangerous global warming has led to the foolish notions behind Virginia’s CO2 Budget Trading Program. When this was passed, my wife and I began to seriously consider moving to another state where the politicians are not dominated by teenage-group think. “It seemed like a good idea at the time.”


Electrical power from wind and solar are offered as alternatives to fossil fuels., but few understand their limitations in generating electricity. They fail for long durations. There is no demonstration project showing how much storage of electricity is needed to provide power when they fail. I have searched for examples where a modern society is self-sufficient in energy without fossil fuels. [Areas with unique geothermal power such as Iceland and those relying on nuclear power are excluded.] There were two efforts: 1) King Island off Tasmania (population about 1600); 2) El Hierro in the Canary Islands (population about 12,000).


King Island uses wind and solar and an elaborate system of battery, dynamic resister, and flywheels for storage and demand side management to reduce electricity use. Yet, it requires diesel about forty percent of the time.,and%20peaking%20at%202.5%20MW.


El Hierro uses wind power and pumped hydro for storage. It requires diesel over 40% of the time.


Those who dream of a fossil fuel free future have no idea how to achieve it and how much it will cost. Costs are escalating in those political entities leading the pack in an imagined renewable energy future: California, Germany, and the UK, despite predictions that more wind or solar will drive down costs. New York City requires that large residential buildings meet high energy standards or face high fines may be the first to realize the folly.


In northern Virginia, many data “server farms” which require 100% reliable power have solar panels for show. As maps from National Renewable Energy Laboratory (NREL) demonstrate, Virginia is a poor location for solar, largely ranking below 4.45 kilowatt hours per square meter per day (kWh/m2/day). Even Southern California with the highest rankings of over 5.75 kWh/m2/day has great problems as can be seen from its need to import significant electricity from other states and its heavy reliance on natural gas each day despite the largest solar installations and chemical batteries in the country.,


The NREL wind maps appear to offer promise for Virginia, but anyone who has sailed offshore recognize Bermuda Highs, extensive periods during the summer when there is no wind. Also, Nor’easters and hurricanes would force offshore wind to shut down.


Very simply, those promoting Virginia’s CO2 Budget Trading Program do not understand the importance of the greenhouse effect for life on this planet, the failure of global climate models, and the complexity involved in delivering 99.99% reliable electricity. Instead, they rely on a form non-critical thinking exhibited by a pack of teenagers.


Governor Youngkin is correct in repealing the CO 2 Budget Trading Program. Unless repealed, it will create great damage to the economy of Virginia and general prosperity for no benefit.


Kenneth A. Haapala

Fairfax, VA

CommentID: 216057