This Was Passed to File at the 10:00Am Hearing on May 23

THIS WAS PASSED TO FILE AT THE 10:00AM HEARING ON MAY 23. 2018 BY ALAN CARLIN CASE NUMBER: PUR-2017-00162 Hi

Why the SCC Should Not Grant Certificates of Public g Convenience and Necessity for Proposed Pleinmont ^ Solar Farm Development in Spotsylvania County, with @ Emphasis on Science and Particularly Energy ^ Economics

Testimony by Dr. Alan Carlin, Fairfax, VA, at SCC Hearing on May 23, 2018 in Richmond, VA Oral Testimony

I am Dr. Alan Carlin, a 39 year scientist/economist with the USEPA, retiring in 2010. I have a BS in physics from Caltech, and a PhD in economics from MIT, and have carried out, supervised, and published considerable research over the last 50 years on the economic and scientific aspects of environmental problems, particularly energy and electric power issues. Further details are in the written version of this testimony in opposition to the proposed Pleinmont Solar Farm Development in Spotsylvania County. Climate alarmists for many years have claimed that 97% of climate scientists agree that the earth is warming primarily because of human emissions of CO2. Science, however, is based on use of the scientific method, not who claims to have the largest number of supporters.

As far as climate in general, it is true that many scientists dependent on a salary from the Federal Government support (whether they believe it or not) the 97% claim, but those believing otherwise do not dare say so, as they would not only be fired for deviating from the so-called "consensus," but also be blackballed from the industry, and financially ruined for life.

At no time has my salary been paid directly or indirectly by either natural resource development interests or non-governmental environmental organizations. But there is a lot of new and credible science that has been produced, some within the last year, and there is a growing body of retired scientists and others not in fear of ruin who have dared to speak up. As explained in my written testimony, I find the proposed Pleinmont Solar project to be one of the worst projects from an economic and environmental viewpoint I have reviewed.

It is not in the public interest that this project be built and the SCC should not allow it to be built in Virginia.

1 Substantive Overview • Carbon dioxide (CO2) is a beneficial gas, not a pollutant-so the social cost of carbon (SCC) is negative-since CO2 is so very critical to plant growth and therefore human life; reducing CO2 emissions hurts plants and indirectly humans, and may have catastrophic consequences during the next ice age due to plant starvation for CO2.

• Credible recent research shows that increases in atmospheric CO? levels have had no significant effect on global temperatures over the last half century or so; that leaves only green vanity (sometimes called virtue signaling) as an argument for the proposed Pleinmont Solar development.

• Green vanity might help Microsoft reduce the Climate Industrial Complex's criticism of its energy use, but will not help Virginia and Virginians, who will be stuck with the loss of ten square miles of land useful for other purposes, higher prices for electricity, reduced reliability of its power grid, substantial risks from catastrophic wind damage to the panels and release into the environment of the toxic materials they contain, and likely severe damage from greatly increased water runoff resulting from the clearing of the land and the building and operation of the solar farm. This is a very steep price to pay for Microsoft to increase its bragging rights for increasing the percentage of "green" energy that it uses.

• Since there are no significant temperature effects from reducing CO2 emissions, all future Federal, state, and private sector decisions regarding the Nation's electric power grid need to focus solely on minimizing consumer electricity prices as well as maximizing grid reliability and resilience since. I hope these reflect the goals of the SCC. No consumer electricity price increases should be permitted by the SCC that result from increased renewables/energy storage grid penetration. There is no economic justification for subsidies for such facilities to be given at any level of government.

2 The proposed Pleinmont Solar development in Spotsylvania County does not meet these requirements. If such developments must ever be approved elsewhere they at the very least need to be placed in areas without high winds, and with little rain, comparatively flat ground, and abundant sunshine, such as the Southwestern deserts, not in Virginia. The results will be no better and perhaps worse than the disastrous experience in Germany.

The SCC should deny approval of Certificates of Public Convenience and Necessity for this proposed project in Spotsylvania County. It will only provide unreliable, intermittent power, not the base load power Microsoft (and other users) needs to keep its servers operating reliably to meet the needs of their customers. Virginians will be left with no benefits but increased electricity costs, decreased reliability of the electric grid, many environmental risks, and impaired land in and near the 10 square mile site, including an adjacent residential area. Additional Written Testimony

Outline

1.1 Summary of Scientific Arguments for Denying CPCNs 1.2 Detailed Scientific Arguments 2.1 Summary of Energy Economic Arguments for Denying CPSNs Appendix A: My Background Appendix B: My Publications Appendix C: Detailed Energy Economic Arguments Appendix D: Congressional Testimony by Dr. John Christy

1.1 Summary of Scientific Arguments for Denying CPCNs

The science section of this testimony makes clear that the UN and EPA findings, claiming GHG/CO2 emissions were causing dangerous global warming, do not satisfy the scientific method. The EPA findings were predicated on three Lines of Evidence that are quite readily specified as hypotheses that can be tested via the scientific method. As challenges to such global warming theories began to emerge, the alarmists first changed the subject to climate change and then just carbon. But these theories too are subject to hypothesis testing. This Comment's detailed science section shows the results of testing both sets of hypotheses.

The three EPA Lines of Evidence offered in their 2009 Endangerment Finding are each shown to be invalid. In fact, they are each shown to be invalid using two separate and mathematically distinct approaches that are spelled out in detail in two separate peer-reviewed Research Reports. The numerous and distinguished peer reviewers are identified and all statistical work may be readily replicated. The reports were both published on multiple websites frequented by, and free to, climate scientists.

This Comment's science section also presents rebuttals of ten typical climate change alarmists' claims. The authors of these rebuttals are all recognized experts in the relevant scientific fields. The rebuttals demonstrate the falsity of all ten of the claims merely by citing the most credible empirical data on the topic. The ten alarmist claims are as follows:

1. Heat Waves are increasing at an alarming rate and heat kills. 2. Global warming is causing more hurricanes and stronger hurricanes. 3. Global warming is causing more and stronger tornadoes. 4. Global warming is increasing the magnitude and frequency of droughts and floods. 5. Global Warming has increased U.S. Wildfires. 6. Global warming is causing snow to disappear.

4 7. Global warming is resulting in rising sea levels as seen in both tide gauge and @ satellite technology. w 8. Arctic, Antarctic and Greenland ice loss is accelerating due to global warming. ^ 9. Rising atmospheric CO2 concentrations are causing ocean acidification, which is ® catastrophically harming marine life. H> 10. Carbon pollution is a health hazard. ^

1.2 Details of the Science Arguments Summarized Above

New Research Findings Make it All but Certain that CO2 Is Not a Pollutant but Rather a Beneficial Gas that Should Not Be Regulated or Reduced

Among the new developments was an extensively peer reviewed April 2017 Research Report by Wallace, Christy and D'Aleo (Wallace 2017). Wallace 2017 can be found at: https://thsresearch.files.wordpress.com/2017/04/ef-data-research-report- second-editionfinal041717-1 .pdf. See also Dr. John Christy's comments on the report in Appendix D. My comments can be found at www.carlineconomics.com/archives/3533.

Wallace 2017 estimates the impacts of the key natural factors, including solar, volcanic and oceanic/ENSO activity, on tropical and global temperatures. It concludes that once these natural factor impacts on temperature data are accounted for, there is no "natural factor adjusted" warming remaining to be attributed to rising atmospheric CO2 levels.

That is, these natural factor impacts fully explain the trends in all relevant temperature data sets over the last 50 or more years. This research found that rising atmospheric CO2 concentrations did not have a statistically significant impact on any of the (14) temperature data sets that were analyzed. Wallace 2017 concludes that, "at this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused what have been officially reported as rising, or even record setting, temperatures." Id. at pp. 4, 71.

New Research Findings Demonstrate that Adjustments by Government Agencies to the Global Average Surface Temperature Record Render That Record Totally Inconsistent with Published Credible Temperature Data Sets and Useless for Any Policy Analysis Purpose

Another important recent research report by James Wallace, Joseph D'Aleo and Craig Idso, was published in June 2017 (Wallace 2017B). Wallace 2017B can be found at: https://thsresearch.files.wordpress.com/2017/05/ef-aast-data-research-report- 062817.pdf

Wallace 2017B analyzed the Global Average Surface Temperature ("GAST") data issued by U.S. agencies NASA and NOAA, as well as British group Hadley CRU. In this research report, past changes in the official previously reported historical data were quantified. It was found that each new version of official GAST historical data (e.g., 1880

5 to 2000) nearly always exhibited a steeper warming linear trend over its entire history. And, this result was nearly always accomplished by each entity systematically removing the previously existing cyclical temperature pattern over this time period. This was true for all three entities providing GAST data measurement, NOAA, NASA and Hadley CRU. However, the magnitude of their historical official data adjustments, that removed the official data's previous cyclical temperature patterns, are shown in Wallace 2017B to be totally inconsistent with published and highly credible U.S. and other temperature data.

The authors have observed:

"Adjustments that impart an ever-steeper upward trend in the data by removing the natural cyclical temperature patterns present in the data deprive the GAST products from NOAA, NASA and Hadley CRU of the credibility required for policymaking or climate modeling, particularly when they are relied on to drive trillions of dollars in expenditures."

The invalidation of the adjusted GAST data knocks yet another essential pillar out from under the lines of evidence that are the claimed foundation of climate alarmism. As the authors have stated:

"It is therefore inescapable that if the official GAST data from NOAA, NASA and Hadley CRU are invalid, then both the 'basic physical understanding' of climate and the climate models will also be invalid."

The climate models used by the UN and depended on by the USERA yield grossly excessive estimates when compared with actual satellite data, the most accurate date we have. Appendix D has a brief summary of this comparison by Dr. John Christy.

Ten Frequent Climate Alarmists' Claims Have Each Been Rebutted by True Experts in Each Field by Simply Citing the Most Relevant and Credible Empirical Data

This Comment's science section also presents rebuttals often typical climate alarmists' claims. The authors of these rebuttals are all recognized experts in the relevant scientific fields. The rebuttals demonstrate the falsity of all ten of the listed alarmist claims by citing the most credible empirical data on the topic. For each alarmist claim, a link is shown to the full text of the rebuttal and a list of the credentials of the Rebuttal's authors. The ten alarmist claims are as follows:

1. Claim: Heat Waves are increasing at an alarming rate and heat kills. Detailed Rebuttal and Authors: EF RRT AC - Heat Waves: https://thsresearch.files.wordpress.com/2017/12/ef rrt ac-heat-waves.pdf 2. Claim: Global warming is causing more hurricanes and stronger hurricanes. Detailed Rebuttal and Authors: EF RRT AC - Hurricanes: https://thsresearch.files.wordpress.com/2017/12/ef rrt ac-hurricanes.pdf

6 # 3. Claim: Global warming is causing more and stronger tornadoes. ^ Detailed Rebuttal and Authors: EF RRT CA-Tornadoes: ^ https://thsresearch.files.wordpress.com/2017/12/ef rrt ca-tornadoes.pdf 4. Claim: Global warming is increasing the magnitude and frequency of @ droughts and floods. P Detailed Rebuttal and Authors: EF RRT AC - Droughts and Floods: ^ https.V/thsresearch.files.wordpress.com/2017/12/ef rrt ac-drouahts-and- floods.pdf 5. Claim: Global Warming has increased U.S. Wildfires. Detailed Rebuttal and Authors: EF RRT AC - Wildfires: https://thsresearch.files.wordpress.com/2017/12/ef rrt ac-wildfires2.pdf 6. Claim: Global warming is causing snow to disappear. Detailed Rebuttal and Authors: EF RRT CA - Snow: https://thsresearch.files.wordpress.com/2017/12/ef rrt ca-snow.pdf 7. Claim: Global warming is resulting in rising sea levels as seen in both tide gauge and satellite technology. Detailed Rebuttal and Authors: EF RRT CA - Sea Level: https://thsresearch.files.wordpress.com/2017/12/ef rrt ca-sea-level.pdf 8. Claim: Arctic, Antarctic and Greenland ice loss is accelerating due to global warming. Detailed Rebuttal and Authors: EF RRT AC - Arctic. Antarctic. Greenland 123117: https.7/thsresearch.files.wordpress.com/2Q17/12/ef rrt ac-arctic- antarctic-qreenland-123117.pdf 9. Claim: Rising atmospheric CO2 concentrations are causing ocean acidification, which is catastrophically harming marine life. Detailed Rebuttal and Author: EF RRT CA-Ocean PH: https://thsresearch.files.wordpress.com/2018/01/ef rrt ca-ocean-ph.pdf 10. Claim: Carbon pollution is a health hazard. Detailed Rebuttal and Authors: EF RRT AC - Health: https://thsresearch.files.wordpress.com/2017/12/ef rrt ac-health2.pdf

While all these alarmist claims are rather easily falsified, these claims are constantly cited to whip up alarm and create demands for ever tighter regulation of GHG emissions. But there is no evidence to support such claims, and copious empirical evidence that refutes them. The government's regulatory authority over GHG emissions cannot lawfully rest upon a collection of scary stories that are conclusively disproven by readily available empirical data.

Recommendations

The parade of alleged horrible calamities that climate alarmists claim to seek to prevent have been comprehensively and conclusively refuted by empirical data. Uneconomic and environmentally risky solar farms such as Pleihmont Solar has proposed should not be approved by the SCC since they primarily involve costs to ratepayers and have no significant benefits.

7 2.1 Summary of the Energy Economic Arguments for Not Approving the Pleinmont Solar Proposal

Increasing the Fraction of Electricity Generation from Intermittent Renewables Causes Enormous Consumer Electricity Price Increases and Serious Negative Macroeconomic Impacts.

Jurisdictions that have succeeded in getting generation from renewables up to as high as about 30% of total electricity supply have experienced about a tripling in the price of electricity to consumers. Getting beyond that 30% level will require prices to multiply by 5 or even 10. Reasons include:

• Need for multiple levels of excess capacity to account for times of low sun and wind. • Fossil fuel plants must be kept on-line and used for "back-up." • To get to higher fractions of renewable generation, storage (e.g., reservoirs, or batteries) must be added at huge cost. • There is need for additional transmission lines to bring power to places where wind is calm.

California in 2016 got 17.2% of its electricity from wind and solar (vs. 6.5% for U.S. as a whole) and its consumers paid about 50% more per kWh for electricity. As shown in the figure below, Germany, now getting more than 30% of its electricity from renewables, has consumer electricity prices per kWh about triple those in the U.S.

Scatterplot, Electricity Cost vs.. Installed Renewable-Capacity

Trent* — 0.02 cenLsSKitowatl-tiour per ecScOtlonal kW of capacity RA2 = 0.84. p-value - -j_se-e

» Australia ZJ0tXa£aj*cl, - - * StSpoLTboT « QJn-tcc^KirtpCom • SwoCcrs • 0rC4 » France

200 400 600 SOO lOOO Installed Capacity. Renewables (watts/capita)

Among large jurisdictions, the one with the highest contribution to electricity generation from wind and solar is South Australia at about 50%. South Australia's consumer electricity prices are the highest in the world and electric reliability one of the

8 ©0 worst in the developed world. Jurisdictions that have succeeded in increasing the @ percent of electricity from renewables illustrate the proposition that the more renewables w the higher the electricity price, with price increases accelerating as the percent of JjJ electricity from renewables gets higher. J,

A new study by IHS Markit, titled Ensuring Resilient and Efficient Electricity "4 Generation: The Value of the Current Diverse U.S. Power Supply Portfolio analyzed the economic effects of state and federal energy policies that are driving electric utilities away from coal, nuclear and hydroelectric and towards renewables and natural gas. Such policies are forecast by IHS Markit to lead to a tripling of the current 7% reliance on wind, solar and other intermittent resources, with natural gas-fired resources supplying the majority of generation.

The Study's Findings are that current policy driven market distortions will lead to: U.S. power grid becoming less cost-effective, less reliable and less resilient due to lack of harmonization between federal and state policies and wholesale electricity market operations. Id. at p. 4 (Emphasis added).

The study forecast that these policies will cause significant increases in the retail price of electricity. The following economic impacts of these price increases were forecast: The 27% retail power price increase associated with the less efficient diversity case causes a decline of real US GDP of 0.8%, equal to $158 billion (2016 chain-weighted dollars).

Labor market impacts of the less efficient diversity case involve a reduction of 1 million jobs.

A less efficient diversity case reduces real disposable income per household by about $845 (2016 dollars) annually, equal to 0.76% of the 2016 average household disposable income." Id. at p. 5. (Emphasis added).

It should be noted that the Study's projected 27% increase in average retail power prices is predicated on the wind and solar renewables share rising by three-fold from 7% to "only" about 21%. The case studies discussed in the Comment make very clear the enormous increases in power prices that would result as policy makers attempt to move the renewables share higher than that. Moreover, the study found that policies that promote increased use of wind and solar would likely result in little to no reduction in the level of electric sector COa emissions.

Recommendations

Based on this comment's science arguments above, the SCC should deny approval of CPCNs that increase electricity costs and reduce reliability. Dispatchable fossil fuel, nuclear, and hydro power should not be replaced with intermittent power because increasing the fraction of electricity generation from intermittent renewables will

9 cause (1) enormous consumer electricity price increases, (2) the Grid to become even less reliable and less resilient, and (3) even more serious negative macroeconomic impacts but would have no impact on the climate as outlined above.

Based on the Energy Economic Analysis in Appendix C: The current Federal, State and private sector policies that are now increasing the fraction of electricity generation from intermittent renewables must be stopped/reversed in order to avoid/mitigate very severe micro and macroeconomic impacts.

Other Ramifications of the Energy Economics Findings

Since there are no real temperature reductions from reducing CO2 levels, no consumer electricity price increases should be permitted by the SCC that results from increased renewables/energy storage grid penetration. Any other approach will result in adverse economic effects on Virginians with no significant economic benefits for them.

DETAILED EXPLANATIONS OF ENERGY ECONOMIC ANALYSIS RECOMMENDATIONS CAN BE FOUND IN APPENDIX C; EXISTENSIVE ADDITIONAL RELATED INFORMATION ON BOTH SCIENCE AND ENERGY ECONOMIC ANALYSES CAN BE FOUND IN MY CLIMATE BOOK (#1 IN APPENDIX B) AND ON MY WEBSITE (CARLINECONOMICS.COM)

10 p Appendix A—My Background ^ ui I have carried out or supervised economic and scientific research on ^ environmental issues for over 50 years, first at The RAND Corporation in Santa Monica, California from 1963 to 1971, and from 1971 to 2010 at the U.S. Environmental p Protection Agency in Washington, DC. At no time has my salary been paid directly or indirectly by either natural resource development interests or non-governmental environmental organizations. During my careers at RAND and EPA I carried out or supervised over two hundred policy-related studies on climate change, pollutant assessment, energy economics and development, environmental economics, transportation economics, benefit-cost analysis, and economic development. Those authored or co-authored by me are listed Appendix B. Those primarily involving economics and funded by USEPA are included in the Environmental Economics Research Inventory on the website of the EPA National Center for Environmental Economics (https://www.epa.aov/environmental-economics/environmental-economics-research- inventorv-ncee-eeri-series). I am the author or co-author of about 40 publications including about 10 on climate change or energy pricing. From 2004 until 2009 I was specifically assigned by the Agency to work on climate economics and science. For seven years I supervised the production of a wide variety of pollutant assessment documents very similar in concept (but not in implementation) to the draft Technical Support Document (TSD) for the EPA Endangerment Finding on greenhouse gases I commented unfavorably on in March. 2009 (http://www.carlineconomics.eom/archives/1) while working at EPA. The pollutant assessment documents were on different compounds, of course. I have a BS in physics from the California Institute of Technology and a PhD in economics from the Massachusetts Institute of Technology. I have an extensive background of working with and in environmental organizations as a volunteer. In the late 1960s I worked very closely with the Sierra Club to present economic arguments against the construction of two proposed dams in the Grand Canyon of Arizona. This campaign was ultimately successful and the dams were not built. In 1970-71 I served as the Chairman of the Angeles Chapter of the Sierra Club, then the Club's second largest chapter. I am the recipient of the Chapter's Weldon Fleald award for conservation work. In response to a request for comments, I prepared unfavorable comments on the science in the EPA's Draft Technical Support Document for the Agency's Endangerment Analysis for Greenhouse Gas Emissions in March, 2009. As a direct result, EPA imposed a gag order, forbade me from further work on climate change, and quashed my comments. These events have been documented in a Congressional Report. These EPA actions led to my retirement in early 2010, but I have continued to research and write on climate economics and science since then. As a result of my Comments, I received a Climate Change Science Whistleblower Award at

11 I I

the International Climate Change Conference (ICCC-9) held in July, 2014, in Las Vegas, NV. In 2015 I published an extensive book on climate economics and science. Much more detailed biographical information (as well as substantive discussion of issues) can be found in my book, available from the book Website (http://environmentalismqonemad.com).

12 §3 Appendix B: Publications in Reverse Chronological Order m yi ui © ©

Cover of book (click to enlarge)

1. Environmentalism Gone Mad: How a Sierra Club Activist and Senior EPA Analyst Discovered a Radical Green Energy Fantasy, 2015, Stairway Press, available from book Web page. Book is available in both printed and eBook versions. Appendices are available from the Publisher if the printed version is purchased from them. The Appendices include three primarily of historical interest and one with a more technical discussion of climate science and economics. 2. Modern Environmentalism: A Longer Term Threat to Western Civilization. Energy and Environment, Vol. 24, No. 6, 2013, pp. 1063-72. 3. The Increasing Need for Research on Geoenqineerinq Approaches to Reducing Potential Global Cooling, in Yu. A. Izrael, A. G. Ryaboshapko, and S. A. Gromov, editors, Investigation of Possibilities of Climate Stabilization Using New Technologies, Proceedings of International Scientific Conference, "Problems of Adaptation to Climate Change" (Moscow, 7-9 November 2011), Russian Academy of Sciences, Moscow, 2012, pp. 24-34. 4. A Multidisciplinarv. Science-Based Approach to the Economics of Climate Change. International Journal of Environmental Research and Public Health, Vol. 8, No. 4, April 1, 2011, pp. 985-1031. 5. EPA: The Administration's High Risk but Pivotal Climate Gamble, paper presented at the Fourth International Conference on Climate Change sponsored by the Heartland Institute, Chicago, Illinois, May 17, 2010. Designed to be printed double-sided. PDF file size is 119KB. The briefing slides used in the presentation can be found here.

13 6. Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act, prepared for the US Environmental Protection Agency as my contribution to the then draft Technical Support Document, final version dated March 16, 2009. Designed to be printed double-sided. PDF file size is 4MB. Summary published as Appendix C in Russell Plante, Solar Energy: Photovoltaics and Domestic Hot Water- A Technical and Economic Guide for Project Planners, Builders, and Property Owners, Academic Press, 2014. Reproduced as Appendix A of Environmentalism Gone Mad. Press coverage includes the following: CBSNews, NYTimes. Wall Street Journal news and opinion, and London Telegraph. For additional information see here and for commentary on a September NYTimes story see here. This blog post is also reproduced as Appendix B of Environmentalism Gone Mad. For a thorough Congressional report dealing with the EPA's Endangerment finding and the release of these comments see here or Appendix D of Environmentalism Gone Mad. For a May 2010 Congressional update see here. 7. Why a Different Approach Is Required if Global Climate Change Is to Be Controlled Efficiently or Even at All. Environmental Law and Policy Review, Vol. 32, Issue 2, Spring, 2008, pp. 685-757. Abstract 8. Risky Gamble. Environmental Forum, Vol. 24, No. 5, September/October, 2007, pp. 42-7. Abstract 9. Global Climate Change Control: Is There a Better Strategy than Reducing Greenhouse Gas Emissions?, University of Pennsylvania Law Review, Vol. 155, No. 6, June, 2007, pp. 1401-97. 10. Implementation and Utilization of Geoenqineerinq for Global Climate Change Control. Sustainable Development Law and Policy, Vol. 7, No. 2, Winter, 2007, pp. 56-58. Abstract 11.The New Challenge to Cost-Benefit Analysis: How Sound Is the Opponents' Empirical Case? Regulation, Fall 2005, pp. 18-23. 12. Measures of Mortality Risks (with W. Kip Viscusi and John K. Hakes), 1997 Abstract; Full Text: Journal of Risk and Uncertainty, Vol. 14, No. 3, May/June, 1997, pp. 213-33. 13. Cost Savings from the Use of Market Incentives for Pollution Control (with Robert C. Anderson, Albert M. McGartland, and Jennifer B. Weinberger), 1997, in Richard F. Kosobud and Jennifer M. Zimmerman (editors), Market-Based Approaches to Environmental Policy: Regulatory Innovations to the Fore, Van Nostrand Reinhold, New York, 1997, pp. 15-46. 14. EPA Comments on Proposed NOA A/DOI Regulations on Natural Resource Damage Assessment. U.S. Environmental Protection Agency, Washington, D.C., October, 1994. Abstract: 15. Environmentally Responsible Energy Pricing (with W. Kip Viscusi, Wesley A. Magat, and Mark Dreyfus), 1994. Abstract. Full text: Energy Journal, Vol. 15, No.

14 p 2, April, pp. 23-42. An earlier version of the report is available here. The full ^ report on which both are based can be found here. vt m 16. The United States Experience with Economic Incentives to Control Environmental Pollution, Report No. 230-R-92-001, U.S. Environmental ® Protection Agency, Washington, D.C., July, 1992. Abstract. ^ 17. Environmental Investments: The Cost of Cleaning Up (with Paul F. Scodari and Don H. Garner), 1991. Full text: Environment, Vol. 34, No. 2, March, pp. 12-45. 18. Environmental Investments: The Cost of a Clean Environment, A Summary (with the assistance of the Environmental Law Institute), 1990, Report No. EPA-230- 90-084, U.S. Environmental Protection Agency, Washington, D.C., December. Abstract. Also available as part of a book published by Island Press. 19. Environmental Investments: The Cost of a Clean Environment, Report of the Administrator of the Environmental Protection Agency to the Congress of the United States, 1990, Report No. EPA-230-90-083, November. Republished with previous entry by Island Press, Washington, D.C. and Covelo, CA, 1991. Abstract. 20. "Introduction," in Thomas D. Crocker (editor), in Economic Perspectives on Acid Rain Control, Butterworth, Stoneham, MA, 1984. 21. Benefits of Pollution Control, March 1974. Full text: Philip L. White and Diane Roberts (editors), Environmental Quality and Food Supply, Futura Publishing Company, Mt. Kisco, New York, pp. 39-47. 22. The Grand Canyon Controversy; or, How Reclamation Justifies the Unjustifiable, 1973. Full text: in Alain C. Enthoven and A. Myrick Freeman (editors), Pollution, Resources, and the Environment, W. W. Norton, New York, 1973, pp. 263- 270. Abstract and order info. 23. Environmental Problems: Their Causes, Cures and Evolution Using Southern California Smog as an Example (with George Kocher), Report R-640-CC/RC, The RAND Corporation, Santa Monica, CA, May, 1971. Abstract and order info. 24. Water Resources Development in an Environmentally-Conscious Era, 1971. Full text: Water Resources Bulletin, Vol. 7, No. 4, April, 1971, pp. 221-223. Reprinted in Charles J. Meyers and A. Dan Tarlock (editors), Selected Legal and Economic Aspects of Environmental Protection, Foundation Press, Mineola, New York, 1971, pp. 53-56. 25. Marginal Cost Pricing of Airport Runway Capacity (with R. E. Park), 1970. Full text: American Economic Review, Vol. LX, No. 3, June, pp. 310-9. Reprinted in Peter Forsyth, Kenneth Button, and Peter Nijkamp (editors), Air Transport Classics in Transport Analysis. Edward Elgar Publishing, Northampton, MA, 2002, pp. 491-5000. Abstract and order info.

15 26. A Model of Long Delays at Busy Airports (with R. E. Park), 1970, Journal of Transport Economics and Policy, Vol. IV, No. 1, January, pp. 37-62. Abstract and order info. 27. The Efficient Use of Airport Runway Capacity in a Time of Scarcity (with R. E. Park), 1969, Report R-5807-PA, The RAND Corporation, Santa Monica, CA, August. Abstract and order info. 28. Alternative Development Strategies for Air Transportation in the New York Region, 1970-1980 (with H. S. Campbell, S. L. Katten, T. F. Kirkwood, D. M. Landi, R. E. Park, L. Rounnau, and A. J. Rolfe), 1969, Report RM-5815-PA, The RAND Corporation, August. Abstract and order info. 29. An Economic Re-Evaluation of the Proposed Los Angeles Rapid Transit System (with Martin Wohl), 1968, Paper P-3918, The RAND Corporation, Santa Monica, CA. Abstract and order info 30. The Economics of Transport Development, 1968, in United Nations Development Programme, Fund of the United Nations for the Development of West Irian, A Design for Development in West Irian, United Nations, New York, pp. 162-170. 31. The Grand Canyon Controversy: Lessons for Federal Cost-Benefit Practices, 1968. Full text: Land Economics, Volume XLIV, No. 2, May, pp. 219-227, Reprinted in Charles J. Meyers and A. Dan Tarlock (eds.), Water Resource Management, Foundation Press, Mineola, New York, 1971, pp. 459-468. Earlier version printed in U.S. Congress, Senate, Committee on Interior and Insular Affairs, Central Arizona Project, Hearings before Subcommittee, 90th Congress, 1st Session, May 2-5, 1967, pp. 507-514. Also in House Committee on Interior and Insular Affairs, Colorado River Basin Project, Hearings before Subcommittee, 90th Congress, 1st Session, March 13-17, 1967, pp. 611- 618. Abstract and order info. 32. Vehicle Safety: Why the Market Did Not Encourage It and How It Might Be Made To Do So. 1968, Report RM-5634-DOT, The RAND Corporation, Santa Monica, CA, April. Abstract. 33. Indian Transportation: A Sectoral Approach to Developmental Constraints, 1967, The Journal of Development Studies, July, pp. 414-439. Abstract and order info. 34. Project versus Program Aid: From the Donor's Viewpoint, 1967, The Economic Journal, March, pp. 48-58. Reprinted in Stephen Spiegelglas and Charles J. Welsh (ed.), Economic Development: Challenge and Promise, Prentice-Hall, Englewood Cliffs, 1970, pp. 350-359. Also in Gustav Ranis (ed.), The United States and the Developing Economies, Revised Edition, W. W. Norton, New York, 1973, pp. 158-171. Abstract and order info. 35. The Grand Canyon Controversy-1967: Further Economic Comparisons of Nuclear Alternatives" (with William E. Hoehn), Senate Hearings, op. cit, pp. 489- 497 and House Hearings, pp. 619-625. Abstract and order info.

16 m 36. Is the Marble Canyon Project Economical ly Justified? (with William E. Hoehn) <© 1967, printed in U.S. Congress, House, Committee on Interior and Insular v Affairs, Lower Colorado River Basin Project, Hearings before Subcommittee, Part ^ II. May 9-18. dp. 1497-1512. Abstract and order info. @ 37. Mr. Udall's 'Analysis': An Unrepentant Rejoinder (with William E. Hoehn), 1966, ibid., pp. 1521-1535. Abstract. 38. Review of "Aspects of Economic Development and Policy" by B. K. Madon, American Economic Review, September, pp. 900-902. 39. A Possible U.S. Policy towards Indian Transportation: An Illustration of Improved Sectoral Policies, 1965, Report RM-4379-AID, The RAND Corporation, Santa Monica, CA, June. Abstract and order info. 40. An Evaluation of U.S. Government Aid to India, June 1964 (partial text through Chapter 2). Abstract

17 Appendix C: Detailed Discussion of How Increasing the Fraction of Electricity Generation from Intermittent Renewables Causes Enormous Consumer Electricity Price Increases and Serious Negative Macroeconomic Impacts

The effort to increase the percentage of electricity generated by intermittent renewable sources like wind and solar, such as the proposed solar farm proposed by Pleinmont Solar, inevitably brings about large increases in the actual price of electricity paid by consumers. This proposition may seem counterintuitive, since the cost of fuel for wind and solar generation is zero. However, the experience in jurisdictions that have attempted to generate more and more of their electricity from these renewables proves the truth of this rising consumer price proposition.

In those jurisdictions that have succeeded in getting generation from renewables up to as high as about 30% of their total electricity supply, the result has been an approximate tripling in the price of electricity for their consumers. The few (basically experimental) jurisdictions that have gotten generation from renewables even higher than that have had even greater price increases, for relatively minor increases in generation from renewables. As the percentage of electricity coming from renewables increases, the consumer price increases accelerate. The burden of these increasing prices for electricity falls most heavily on poor and low-income people.

The reason that increasing renewable generation leads to accelerating consumer prices is that an electrical grid must operate with one hundred percent reliability on a 24/7 basis. A reliable grid requires a very close match between power supplied and power demanded on a minute-by-minute, and even a fraction of second basis. But wind and solar sources experience large and often sudden swings in the power that they supply. Therefore, in a grid using large amounts of power from wind and solar sources, additional costly elements must be added to the system to even out the supply and always match it to the demand. These additional elements are what bring about the increased costs and thus consumer prices. Such elements can include:

Additional renewable sources (wind turbines or solar panels), such that the renewable capacity becomes a multiple of peak usage, enabling the system to work at times of relatively low wind or thick clouds; however, no amount of excess capacity can make a wind/solar system generate any electricity on a completely calm night.

"Back-up" capacity from fossil fuel generating units; however, if such back-up capacity is the only additional element added, repeated calms and nights will mean that the "back-up" will often end up supplying well more than half of the electricity, even if there is substantial excess capacity of the renewable sources.

Storage, such as batteries; however, due to the frequency of calms and nights, multiple days' worth of storage capacity, at huge cost, are needed to have

18 any hope of getting the percent of electricity from renewables up to 50% or above; and un Additional transmission lines; however, there has been no demonstration © of how much additional transmission capacity, and in what locations, and at what cost, might be able to get generation from renewables up to any substantially ^11 higher level.

Each of these additional elements is costly, and more and more of them are necessary as the desired percentage of electricity from the renewables increases.

The following chart, initially prepared by Willis Eschenbach of the website WattsUpWithThat, shows the near linear relationship between installed renewables capacity per capita (in watts/capita) on the x-axis and cost of electricity to the consumer (in cents per kilowatt hour) on the y-axis, where each point is a country. The chart is available at the following link: https://wattsupwiththat.com/2015/08/03/obama-mav-finallv-succeed/ Contrast the current situation in Germany with that of the U.S.

Scattorplot. Electricity Cost vs. Installed Renewable Capacity Tr£?nd ^ 0.02 centsSHJowc»tt~Hour per additional KW of eapoeSly R*2 - O.S-l. p-value - l.5E*e -O^nmnrW •• C^ormnny

* AiiGtralin • r?otaT*ci.. - * " .IP0" OM Sweden ' GrcfJCO

y *JO • Prorcce

L " 0 T O 200 400 600 SOO lOOO Installed Capacity. Renewables (watts/capita)

Germany is the leader in Europe in its power generation per capita from renewables, through its so-called Energiewende, having gotten the percentage of its electricity from wind and solar all the way up to about 30%. However, the consequence of that effort has been an approximate tripling of the cost of electricity to consumers, to about 30 cents per kWh. Analyses of the soaring price of electricity in Germany place the blame squarely on excess costs that have been necessarily incurred to try to get to a stable, functioning, 24/7 system with so much input from intermittent renewables. First, massive "excess" wind and solar capacity has been installed to try to deal with days of light wind and heavy clouds. And for the completely calm nights and overcast winter days when the wind and solar sources produce nothing or next-to-nothing, nearly

19 the entire fleet of fossil fuel plants has been maintained and ready to go, even though those sources end up being idle much of the time. (Actually, since Germany during this time was shutting down all of its Nuclear power plants, it has been building coal plants to back up its renewables.13) And then, some means have had to be found to deal with the surges of available electricity when the wind and sun suddenly blow and shine together at full strength at the same time.

As noted by Benny Reiser at the Global Warming Policy Foundation on April 4, 2015 (http://www.theawpf.com/bennv-peiser-eus-qreen-enerav-debacle-shows-the-futilitv-of- unilateral-climate-policiesA:

Every 10 new units worth of wind power installation has to be backed up with some eight units worth of fossil fuel generation. This is because fossil fuel plants have to power up suddenly to meet the deficiencies of intermittent renewables. In short, renewables do not provide an escape route from fossil fuel use without which they are unsustainable. ... To avoid blackouts, the government has to subsidize uneconomic gas and coal power plants.. . . Germany's renewable energy levy, which subsidizes green energy production, rose from 14 billion euros to 20 billion euros in just one year as a result of the fierce expansion of wind and solar power projects. Since the introduction of the levy in 2000, the electricity bill of the typical German consumer has doubled.

To further illustrate the relationship between the percentage of electricity from renewables and cost of electricity to the consumer, consider two jurisdictions. California is a "leader" in the United States in generating power from wind and solar sources. According to the California Energy Commission, in 2016 California got 8.11% of its electricity supply from solar and 9.06% from wind, for a total of 17.17% from those two intermittent sources. See http://www.enerav.ca.aov/almanac/electricitv data/total system power.html. For the U.S. as a whole for wind and solar was 6.5%. See https://www.eia.qov/tools/faas/faq.php?id=427&t=3.

According to the U.S. Energy Information Agency, California's average electricity price that year was 14.91 cents per kWh, versus a U.S. average of 10.10 cents per kWh; that is, almost 50% higher. See https://www.eia.qov/electricitv/monthlv/epm table grapher.cfm?t=epmt 5 6 a.

There are only a handful of small jurisdictions that have tried to get the percentage of their electricity generation from renewables up much beyond the 30% achieved by Germany. But those jurisdictions have not achieved levels much beyond that of Germany, and even those levels have been achieved only at high and accelerating costs. One such jurisdiction is Gapa Island, a small island of only 178 people (97 households) in South Korea. A report on the Gapa Island Project appeared on the Hankyoreh news site in July 2016 (http://enalish.hani.co.kr/arti/enqlish edition/e national/752623.html).

20 With average electricity usage of 142 kW, and maximum usage of 230 kW, the @ islanders installed wind and solar capacity of 674 kW - about three times maximum m usage, to deal with light wind and low sun. They also bought battery capacity for about w eight hours of average usage. The cost of the wind and solar capacity plus batteries ^ was approximately $12.5 million, or about $125,000 per household. And with all that p investment the islanders were still only able to get about 42% of their electricity from the M sun and wind when averaged over a full month. Even with the storage, they still needed the full fossil fuel backup capacity.

Even much lower solar and wind penetration levels impact electric reliability because they essentially use system reserves as their backup. Unless these reserves are increased, which is expensive, the resulting reduction in effective system reserves reduces system reliability. The choice is either paying for increased system reserves, which are likely to be paid for by general ratepayers rather than only users of "green energy," or decreasing system reliability. Climate alarmists frequently overlook or even contradict this, but there is no free lunch.

Applying a reasonable cost of capital to a system like that of Gapa Island, and considering additional elements of a system, like additional storage, that would be necessary to push the percent of total generation from renewables to higher levels, one can calculate that a system like the Gapa demonstration project for the full United states would lead to electricity prices of at least five times their current level, and more likely, far higher. And even then, the U.S. would be hard-pressed to achieve 50% of electricity from the intermittent renewables.

A somewhat larger demonstration project on the Spanish island of El Hierro (population about 10,000) has had similar results. The idea on El Hierro was to combine a massive wind farm with a large elevated reservoir to store water, which would then be released at times of low wind to balance the grid. El Hierro has the good fortune of a mountainous geography, so that a large reservoir could be placed at a relatively high elevation, in close proximity to the consumers of the electricity. The investment in the wind/water system was approximately 64.7 million euros, or about $80 million - which was on top of what was already a fully-functioning fossil fuel-based system, all of which still needed to be kept. Operations of the El Hierro project began in 2015 with high expectations for 100% renewable generation, but it has not come close.

An operations review of the El Hierro system from inception to date by engineer Robert Andrews can be found at http://euanmearns.com/el-hierro-end-2017- performance-update/. During 2017 the percent of generated electricity that came from renewables ranged from 62.4% in September down to only 24.7% in November, with the overall average for the year at about 40%. Based on the data from actual operations, Mr. Andrews calculates that, to achieve the goal of 100% generation from the wind/water project, El Hierro would need to increase its wind turbine capacity by some 50%, and the capacity of its reservoir by a factor of 40. Clearly, there is no place on the island to put such a massive reservoir; and if there were, the cost would be not in the millions, but in the billions. And that would be for a mere 10,000 people.

21 The geography of the United States does not permit a water storage system like that of El Hierro for most parts of the country. The alternative of storage by large batteries, such as the type used for Tesla automobiles, carries truly astounding potential costs. Current prices for lithium ion batteries are about $200,000 per MWh. At that price, to provide sufficient capacity to cover New York City for three consecutive days of no-to- low wind and sun would cost in the range of $50 billion. And the experience of places like Germany indicates that there could well be five or even seven consecutive dark and calm days in winter in much of the country. Attempting to create an electricity system consisting entirely of renewables backed up by batteries could easily lead to consumer electricity prices at ten times current levels.

Such an economic jolt would hit every Virginian hard, with the possible exception of some of the very wealthiest people. Even middle and upper middle-income people would be forced to make major reductions in their energy consumption. But poor and low-income people would be hit by far the hardest. If electricity prices went to five to ten times current levels, most low-income people would be almost completely priced out of things they now take for granted, like light, refrigeration and computers. They would be forced into energy poverty. This is the route down which the Clean Power Plan, but for the Supreme Court's stay, would surely have taken us - on the now thoroughly discredited assumption that CO2 is a pollutant.

A new study by IMS Markit, titled Ensuring Resilient and Efficient Electricity Generation: The Value of the Current Diverse U.S. Power Supply Portfolio considered the economic effects of state and federal energy policies that are driving electric utilities away from coal, nuclear and hydroelectric and towards renewables and natural gas. Such policies are forecast by IMS Markit to lead to a tripling of the current 7% reliance on wind, solar and other intermittent resources, with natural gas-fired resources supplying the majority of generation.

The Study's Findings are that current policy driven market distortions will lead to:

U.S. power grid becoming less cost-effective, less reliable and less resilient due to lack of harmonization between federal and state policies and wholesale electricity market operations, Id. at p. 4 (Emphasis added).

The study found that these policies will cause significant increases in the retail price of electricity. The following economic impacts of these price increases were forecast:

The 27% retail power price increase associated with the less efficient diversity case causes a decline of real US GDP of 0.8%, equal to $158 billion (2016 chain-weighted dollars).

Labor market impacts of the less efficient diversity case involve a reduction of 1 million jobs.

22 p m a A less efficient diversity case reduces real disposable income per household ^ by about $845 (2016 dollars) annually, equal to 0.76% of the 2016 average ^ household disposable income." Id. at p. 5. (Emphasis added). ^ p It should be noted that the projected 27% increase in average retail power prices is predicated on the wind and solar renewables share rising by three-fold from 7% to "only" about 21 %. The case studies discussed above make very clear the enormous increases in power prices that would result as policy makers attempt to move the renewables share higher than that.

Moreover, the study found that current state and federal policy-driven market distortion will imply: Increased variability of monthly consumer electricity bills by around 22 percent; and an additional $75 billion per hour cost associated with more frequent power supply outages. Id. (Emphasis added).

The study's lead author commented that "[djiversity of supply is an essential bedrock for security and reliability for an electric power system that is as big and diverse—and as crucially important—as that of the United States." See http://news.ihsmarkit.com/print/node/23497

Moreover, policies that promote increased use of wind and solar would likely result in little to no reduction in the level of electric sector CO2 emissions: Ironically, addressing climate change concerns with federal and state policies to subsidize and mandate wind and solar electric generation produced the unintended consequence of distorting wholesale electricity market clearing prices and driving the uneconomic closure of nuclear power plants—a zero-emitting source. The result has been some power system CO2 emissions remaining constant or increasing. Id.

23 Appendix D: Comment on and Excerpts from Dr. John Christy's Congressional Testimony in March, 2017

Dr. John Christy's Congressional testimony in March, 2017 (httDs://science.house.qov/sites/republicans.science.house.aov/files/documents/HHRG- 115-SY-WState-JChristv-20170329.pdf) showed that the temperature trend, projected by climate models on which EPA relies, differs from the actual trend of observations in the tropical troposphere at the 99% confidence level. Id., at pp. 9-10. Thus, the models used by EPA to conclude that greenhouse gases pose a "danger" to human health and welfare have failed a simple "scientific method" test. They have been invalidated.

The testimony was delivered to the U.S. House Committee on Science, Space & Technology on 29 Mar 2017 by Dr. John R. Christy, Professor of Atmospheric Science, Alabama State Climatologist, University of Alabama in Huntsville.

Excerpts:

Summary

"Science" is not a set of facts but a process or method that sets out a way for us to discover information and which attempts to determine the level of confidence we might have in that information. In the method, a "claim" or "hypothesis" is stated such that rigorous tests might be employed to test the claim to determine its credibility. If the claim fails a test, the claim is rejected or modified then tested again. When the "scientific method" is applied to the output from climate models of the IPCC AR5, specifically the bulk atmospheric temperature trends since 1979 (a key variable with a strong and obvious theoretical response to increasing GHGs in this period), I demonstrate that the consensus of the models fails the test to match the real-world observations by a significant margin.

As such, the average of the models is considered to be untruthful in representing the recent decades of climate variation and change, and thus would be inappropriate for use in predicting future changes in the climate or for related policy decisions.

The IPCC inadvertently provided information that supports this conclusion by (a) showing that the tropical trends of climate models with extra greenhouse gases failed to match actual trends and (b) showing that climate models without extra greenhouse gases agreed with actual trends. A report of which I was a co-author demonstrates that a statistical model that uses only natural influences on the climate also explains the variations and trends since 1979 without the need of extra greenhouse gases. While such a model (or any climate model) cannot "prove" the causes of variations, the fact that its result is not rejected by the scientific method indicates it should be considered when trying to understand why the climate does what it does. Deliberate consideration of the major influences by natural variability on the climate has been conspicuously

24 absent in the current explanations of climate change by the well-funded climate science industry....

Tropical Mid-Tropospheric Temperature Variations 1.2 Models vs. Observations 5-Year Averages, 1979-2016 Trend line crosses zero at 1979 for all time series

ACCESS1.0 ACCESS13 1.0 i BCOCMSJ.l BCC-CSMlU(m) ONO-E3M CanESMZ "•••"*• CCSMM (6 runs) •-CESMKBGQ (1 run) — CESM1{CAM5) (3 runs) — CMCC-CM CNRM-CMS - CSJRO-MkS-S^J 0.8 + EC_EABTH — FGOALS^Z FIO-ESM •" GFOi.-CM3 (l run) ' CFOL-ESMZQ(1 run) GfDL*ESM2M (1 run) C1SS^2-H (16 rum) ••• GISS-EZ-R (IB rum) HadGEM2-CS INM-CM4 — iPSt^CMSA-Ut IPSL-CMSA-MR 0.6 IPSUCM&a-Ut — MIROCS MIROC-ESM — Mf>*>ESM-iR MPf-ESM-MR • MFU-CGCM3 NorESMl-M NorESMl-ME •c ^32 Group Mean — Ave . . -Ava Paitoon mmnmhnat 0.4

0.0

-0.2 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

Figure 2: Five-year averaged values of annual mean (1979-2016) tropical bulk Tiuras depicted by the average of 102IPCC CMIPS climate models (red) in 32 institutional groups (dotted lines). The 1979-2016 linear trend of all time series intersects at zero in 1979. Observations are displayed with symbols: Green circles - average of 4 balloon datasets, blue squares - 3 satellite datasets and purple diamonds - 3 reanalyses. See text for observational datasets utilized. The last observational point at 2015 is the average of 2013-2016 only, while all other points are centered, 5-year averages....

(5) A simple statistical model that passed the same "scientific-method" test

The IPCC climate models performed best versus observations when they did not include extra GHGs and this result can be demonstrated with a statistical model as well. I was coauthor of a report which produced such an analysis (Wallace, J., J. Christy, and J. D'Aleo, "On the existence of a 'Tropical Hot Spot' & the validity of the EPA's C02 Endangerment Finding - Abridged Research Report", August 2016 (Available here https://thsresearch.files.wordpress.com/2016/09/ef-cpp-sc-2016-data-ths-paper-ex-sum- 090516v2.pdf).

In this report we examine annual estimates from many sources of global and tropical deep layer temperatures since 1959 and since 1979 utilizing explanatory variables that did not include rising CO2 concentrations. We applied the model to estimates of global and tropical temperature from the satellite and balloon sources, individually, shown in Fig. 2 above. The explanatory variables are those that have been known for decades such as indices of El Nino-Southern Oscillation (ENSO), volcanic

25 activity, and a solar activity (e.g. see Christy and McNider, 1994, "Satellite greenhouse signal", Nature, 367, 27Jan). [One of the ENSO explanatory variables was the accumulated MEI (Multivariate ENSO Index, see https://www.esrl.noaa.gov/psd/enso/mei/) in which the index was summed through time to provide an indication of its accumulated impact. This "accumulated-MEl" was shown to be a potential factor in global temperatures by Spencer and Braswell, 2014 ("The role of ENSO in global ocean temperature changes during 1955-2011 simulated with a 1D climate model", APJ.Atmos.Sci. 50(2), 229-237, D0l:10.1007/s13143-014-001-z.) Interestingly, later work has shown that this "accumulated-MEl" has virtually the same impact as the accumulated solar index, both of which generally paralleled the rise in temperatures through the 1980s and 1990s and the slowdown in the 21st century. Thus our report would have the same conclusion with or without the "accumulated-MEl."]

The basic result of this report is that the temperature trend of several datasets since 1979 can be explained by variations in the components that naturally affect the climate, just as the IPCC inadvertently indicated in Fig. 5 above [not reproduced here but available in the original testimony]. The advantage of the simple statistical treatment is that the complicated processes such as clouds, ocean-atmosphere interaction, aerosols, etc., are implicitly incorporated by the statistical relationships discovered from the actual data. Climate models attempt to calculate these highly non-linear processes from imperfect parameterizations (estimates) whereas the statistical model directly accounts for them since the bulk atmospheric temperature is the response-variable these processes impact. It is true that the statistical model does not know what each sub-process is or how each might interact with other processes. But it also must be made clear: it is an understatement to say that no IPCC climate model accurately incorporates all of the non-linear processes that affect the system. I simply point out that because the model is constrained by the ultimate response variable (bulk temperature), these highly complex processes are included.

The fact that this statistical model explains 75-90 percent of the real annual temperature variability, depending on dataset, using these influences (ENSO, volcanoes, solar) is an indication the statistical model is useful. In addition, the trends produced from this statistical model are not statistically different from the actual data (i.e. passing the "scientific-method" trend test which assumes the natural factors are not influenced by increasing GHGs). This result promotes the conclusion that this approach achieves greater scientific (and policy) utility than results from elaborate climate models which on average fail to reproduce the real world's global average bulk temperature trend since 1979.

The over-warming of the atmosphere by the IPCC models relates to a problem the IPCC AR5 encountered elsewhere. In trying to determine the climate sensitivity, which is how sensitive the global temperature is relative to increases in GHGs, the IPCC authors chose nof to give a best estimate. [A high climate sensitivity is a foundational component of the last Administration's Social Cost of Carbon.] The reason? ... climate models were showing about twice the sensitivity to GHGs than

26 m calculations based on real, empirical data. I would encourage this committee, and our @ government in general, to consider empirical data, not climate model output, when y"1 dealing with environmental regulations. ^ <9