Roger Caiazza
This is an update to some articles that were published early in 2024 about the New York State Department of Environmental Conservation (DEC) proposed Amendments to Part 490, Projected Sea Level Rise (Amendment). Kip Hansen wrote a post entitled New York State Sea Level Rise: Fantasy as Law. A few days later Anthony Watts responded to a New York Post article by Carl Campanile with the headline: Sea levels around NYC could surge up to 13 inches in 2030s due to climate change: state study. I prepared comments which I summarized in a post. In September 2024 DEC adopted the Amendment. Surprising no one, their Assessment of Public Comments blew off all the concerns expressed.
Part 490 Projected Sea-Level Rise
DEC’s Climate Change Regulatory Revisions webpage describes the Amendment to the regulation:
On September 22, 2014, the Community Risk and Resiliency Act was signed into law — Chapter 355 of the Laws of 2014 (CRRA). CRRA is intended to ensure that decisions regarding certain State permits and expenditures consider climate risk, including sea-level rise. Among other things, CRRA requires the Department of Environmental Conservation (Department) to adopt regulations establishing science-based State sea-level rise projections. Therefore, the Department proposed a new 6 NYCRR Part 490, Projected Sea-Level Rise (Part 490). Part 490 establishes projections of sea-level rise in three specified geographic regions over various time intervals, but does not impose any requirements on any entity. An amended Part 490 was adopted in September 2024 with no revisions to the draft released for public comment in January 2024.
Kip Hansen summarized New York sea level rise history and the DEC projections in detail in his post. What you need to know here is that New York City’s sea level has been increasing 3 mm per year over 167 years. Enough of that observed increase is caused by local subsidence so that the remainder is “very close to the standardly cited Global Sea Level Rise figure for the 20th Century of 1.7 or 1.8 mm/yr. (opinions vary – see NOAA here.)” Kip explains that the projected increases included in the Amendment” have not been seen in the decade since the 2014 update report and, based on the historical record, are extremely unlikely to be seen in the near future.” He points out that “all the projections, in the Amendment, in the NYSERDA 2014 report and in the NYS Climate Assessment require doubling and tripling of long-term sea-level rise rates in New York City.”
RCP8.5 Comments
Kip, Anthony, and I agree that the projections are flawed because the methodology estimates an unrealistically high projected sea-level dependent upon an impossible climate model scenario. Depending upon which version of the Intergovernmental Panel on Climate Change report being used the modeling scenarios are known either as a Representative Concentration Pathway (RCP) or Shared Socio-economic Pathways (SSP). The RCP-8.5 scenario has been debunked by many as Anthony reported here and here. My comments focused on the misuse of RCP-8.5 using some of those references and adding others.
The Amendment revises the projections of future sea-level rise required by New York regulations.
I raised the RCP-8.5 concerns in the pre-proposal draft of the amendment. The Regulatory Impact Statement (RIS) uses the label SSP5-8.5 for this scenario and admits that those emission scenarios are implausible:
The Department acknowledges that current GHG emissions policies would result in actual emissions lower than projected by SSP5-8.5. Thus, the inclusion of higher projections of sea level rise, especially those based on SSP5-8.5, could lead to consideration of conditions that are unlikely to occur, at least in the more immediate future.
So how did DEC justify the continued use of SSP5-8.5? The RIS goes to considerable lengths to justify its use with statements like the following: “Unfortunately, current literature does not provide a basis for assessment of the emissions levels at which ice shelf and marine ice cliff instability, important factors in sea level rise in high emissions scenarios, such as SSP5-8.5, become significant.”
Response to RCP8.5 Comments
DEC is required to respond to submitted comments. The Assessment of Public Comments document addressed my arguments in their response to Comment 6. They summarized my concerns saying that “SSP5-8.5 is not plausible, and model outputs based on this SSP, including the rapid ice melt scenario, should not be included in the projections.” The reply stated:
Response to Comment 6: DEC has described its rationale for including SSP5-8.5 model outputs in its projections, including the rapid ice melt scenario, in the RIS. To summarize here, the emission-reduction gap noted above, uncertainties in the causal chain to sea level heights, including ice cliff and ice shelf stability, and reports of accelerating Antarctic and Greenland ice loss reduce confidence that SLR will be limited to the levels projected by SSP2-4.5 models. The CIA methodology report (p. 21) provides additional rationale for including projections based on SSP5-8.5:
• Continuity with previous New York State projections, which were based on representative concentration pathways with the same end-of-century radiative forcing.
• Stakeholder interest in these projections, based on CIA Needs Assessment.
• Value of identifying a broad range of plausible outcomes.
• Current climate impact models’ underestimation of plausible outcomes when driven by only moderate GHG forcing.
DEC maintains that inclusion of high, albeit unlikely, projections to enable consideration of the consequences of low-probability but high-consequence events to be the more prudent alternative to limiting projections to those based on SSP2-4.5.
The crux of my disagreement is the value of incorporating what is essentially an impossible scenario. All the reasons cited attempt to justify what is essentially an executive decision to perpetuate the narrative that there is an existential threat of climate change exemplified, in this case, by extraordinary sea-level rise projections.
It is telling that the response claims that the extreme projections are included because of “Stakeholder interest in these projections, based on CIA Needs Assessment.” New York State agencies love to claim that they have a robust stakeholder process. However, the stakeholder process operates with a loaded deck. The New York Research & Development Authority (NYSEDA) CIA Needs Assessment Steering Committee is a relevant example. The report states “The assessment has been guided by a Steering Committee of climate scientists, assessment experts, and representatives from nonprofit organizations and state and municipal government agencies.” I am very critical of the review process because I know that there is immense pressure to adhere to the narrative within NYSERDA and I am sure no one skeptical of the extreme impact narrative was allowed anywhere near the Steering Committee. In addition, technical analyses performed for NYSERDA will not be funded in the future if the answers do not support the narrative.
Another reason given for using the impossible scenario is the “value of identifying broad outcomes”. In this instance I think the value is primarily for the “scare the bejesus out of the populace” narrative needed to perpetuate the story that New York politicians are here to save the planet even in the face of increasingly obvious enormous costs, threats to reliability, and inevitable reduction in personal choice. This will only stop when there is a change in the political balance of New York.
Conclusion
Surprising no one, their Assessment of Public Comments blew off our concerns. There is no reasonable defense for using RCP-8.5. As long as New York State continues to claim they follow the science but ignore it when it is inconvenient, the more likely the rush to the bottom will become a death spiral.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This represents his opinion and not the opinion of any of his previous employers or any other organization with which he has been associated.
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New York sea level to surge “up to” 13″ by 2030.
At 1.7-1.8mm/year that is 17-18mm/decade or around 1.3″ by 2030.
I think they forgot their “Decimal Point”
As long as New York State continues to claim they follow the science of RCP-8.5, they are bound by their own laws to either:
The Steering Committee of climate scientists, assessment experts, and representatives from nonprofit organizations and state and municipal government agencies need to enact the above, or come up with other alternatives, otherwise they are abrogating their responsibilities.
Screaming at the rest of the world to “do something” will not work.
Get on with it New York State if you truly believe your experts.
No it is a tipping point argument so historical trend is deemed irrelevant.
Unfortunately it becomes the Irrelephant in the room
Don’t you mean mean a “tipsy point”?
18 mm per decade is only .68 inches. 26.4 mm per inch.
25.4
Oops, thanks
So it’s even less worser than we thought
No surprise. Warmunists are apparently immune to facts and logic despite several valiant efforts to the contrary. That is apparently especially so in places like New York. They will carry on until their failures can no longer be ignored. No different than banning heavy diesel trucks from ports in California.
We can only hope that abject failure happens sooner rather than later.
Abject failure has already happened. Atmospheric CO2 is the only control knob addressed. ALL efforts to “fight climate change” by reducing CO2 emissions have not worked at all for over 40 years.
A cubic meter of air contains ca 0.8 grams of CO2 and has a mass of about
1.20 kg. This small amount of CO2 can not heat up such a large amount of air. The IPCC is pack of liars.
.8/1200=.000667 which is 2/3rds of 1/10th of one percent. I agree Harold, I wanted to show the insignificance of CO2.
As long as money keeps coming, use it for yourself, don’t waste it on anything else.
“They will carry on until their failures can no longer be ignored.”
This is how fanatics think. They refuse to acknowledge they are wrong until the whole thing comes crashing down around their heads and they can’t ignore it anymore.
The “Crash and Burn” is devastating for the average citizen.
Put a new-born baby on the annual high tide line.
The baby will be able to walk out of danger before the rising seas reach his mouth.
I don’t think that phrase “existential threat to humanity” means what they think it means.
In my experience (3 children, 5 grandchildren), newborns cannot move themselves.
Read it again, carefully. The new-born does not move.
It “could” surge, but then it “might not” surge at all, and if the past pattern of a 3mm rise per year over the past 167 years continues mainly due to subsidence, no one should lose any sleep over the issue.
Fun factoid. The Sea Level in Boston Harbor is actually declining due to glacial isostatic rebound. At New York part of the SLR is due to subsidence, again from glacial isostatic ‘rebound’. The worse SLR is the mouth of the Chesapeake Bay down to Norfolk VA Navy base, due to subsidence in an about 30mya massive subsea asteroid strike crater. All good, as the Navy appreciates a naturally deeper water port.
What % is due to subsidence? I suspect it’s not “mainly” but I don’t know- just guessing.
I love researching the ‘facts’ for all here. The long term Battery SLR is just over 2.9mm/yr. The best dGPS corrected for vertical land motion tide gauge global SLR estimate is about 2.1mm/yr. (See much earlier post here ‘SLR, acceleration, and closure’ for referenced details.) So the Battery tide gauge subsidence is about 0.8mm/year, which foots to the independent East Coast isostatic glacial adjustment model estimates for that specific location. So about 30% subsidence in NYC.
“Sea levels around NYC could surge up to 13 inches in 2030s due to climate change: state study.”
__________________________________________________________________________
That comes to 22mm/year starting this afternoon. Pure and simple, that’s fraud.
NOAA says: “average global sea level rise rate of 1.7-1.8 mm/yr.” That’s buried in the first paragraph four lines down. Perhaps the Climate scientists running NOAA think nobody will ever find it there.
Seem like they have missed a Tide Cycle. The Dutch, where 1/2 the country is below sea level, seems to have found it, and called it the 18.6 Lunar Cycle.
Local Relative Sea Level
To determine the relevance of the nodal cycle at the Dutch coast, a spectral analysis was carried out on the yearly means of six main tidal gauges for the period 1890–2008. The data were corrected for atmospheric pressure variation using an inverse barometer correction. The spectral density shows a clear peak at the 18.6 -year period (Figure 1). The multiple linear regression yields a sea-level rise (b1) of 0.19 +/- 0.015 cm y-1 (95%), an amplitude (A) of 1.2 +/- 0.92 cm, and a phase (w) of -1.16 (with 1970 as 0), resulting in a peak in February 2005 (Figure 2). No significant acceleration (inclusion of b2) was found.
CONCLUSIONS
Coastal management requires estimates of the rate of sealevel rise. The trends found locally for the Dutch coast are the same as have been found in the past 50 years (Deltacommissie, 1960; Dillingh et al., 1993). Even though including the nodal cycle made it more likely that the high-level scenarios would become apparent in the observations, no acceleration in the rate of sea-level rise was found. The higher, recent rise (van den Hurk et al., 2007) coincides with the up phase of the nodal cycle. For the period 2005 through 2011, the Dutch mean sea-level is expected to drop because the lunar cycle is in the down phase. This shows the importance of including the 18.6-year cycle in regional sea-level estimates. Not doing so on a regional or local scale for decadal length projections leads to inaccuracies
I’m in favor of NY spending their money. But: I think there are
better opportunities for their concerns.
I don’t live there, but I did visit twice. It is a good place to be from.
I hate NYC, and think it would be far better off underwater. Hope my various relatives can get out before that happens.
They do in fact give a relatively detailed rationale for including 8.5 and that needs to be addressed and critiqued. So in that sense I would not say they “blew you off”. The reasoning may well be incorrect but there is a significant amount of it. They disagreed and said why.
In fact I think this is the standard alarmist reasoning regarding coming rapid rise in sea level. It is basically a tipping point argument. All theory with no empirical support.
As I read it, I thought they said they used RCP8.5 because it gave the result they needed. I do confess to not reading it very carefully though.
“All theory with no empirical support.:
Just like the whole Human-caused Climate Change narrative.
The rationale behind these reasons is not very strong:
• Continuity with previous New York State projections, which were based on representative concentration pathways with the same end-of-century radiative forcing.
We got away with it before so we are going to continue despite the fact that there is overwhelming evidence that RCP8.5 is impossible
• Stakeholder interest in these projections, based on CIA Needs Assessment.
I published a longer version of this yesterday on my blog that argued that the stakeholder process is a sham.
• Value of identifying a broad range of plausible outcomes.
Funny how only outcomes that exaggerate the impacts are considered and never any the other way. Bigger issue is that policy based on fantasy can never be pragmatic.
• Current climate impact models’ underestimation of plausible outcomes when driven by only moderate GHG forcing.
This refers to the tipping point argument and the fact that theory without empirical support is another way to promulgate poor policies.
I stand by my they blew me off statement.
Note that not one of the AGW trollettes has appeared to say how ludicrous the 13″ surge number really is.
I noticed that too. It’s very hard to say that 2+2=40.
In other news, Central Greenland was once ice free tundra, with plants and insect etc etc
Central Greenland Was Recently Ice-Free And Covered With Plants When CO2 Was Under 300 ppm
Story Tip ?
Roger – I’d agree, that RCP 8.5 looks to be quite improbable. However, there would seem to be a case for planning for worst case scenarios. For NYC, I should think that would be something like the 1938 Long Island Express hurricane (Catagory 3 and travelling nearly 50 mph — 76kph at landfall) coming ashore near the mouth of the Hudson. You should probably plan to harden critical infrastructure near shore and make sure that owners of non-critical properties are aware that there is a very small chance of total destruction. Also, any new critical infrastructure that is likely to be around for centuries should have a realistic plan for dealing with several meters of sea level rise even though actual SLR will likely be much less.
BTW, I’m none too certain that large cities like NYC, Tokyo, etc won’t go into decline as manufacturing slowly automates (requiring fewer workers) and it becomes easier for many businesses to operate remotely. In fact both my kids now work for businesses that don’t have an office in the classical sense. It might not matter all that much if the sea engulfs some parts of today’s urban centers. But I think for planning, one has to assume that won’t happen.
Adaptation to the worst observed weather makes a lot of sense. What concerns me is tacking the storm surge onto these ludicrous SLR values. New York City had, hopefully they are fixing this, many buildings with electronic infrastructure in the basement. Sandy cause problems with that.
Ultimately the problem is that there are so many adaptation problems we need to address that spending money on impossible scenarios and, even worse, trying to control the weather is a poor choice.
From the article: “Shared Socio-economic Pathways (SSP)”
That made me laugh.
Wordsmiths posing as scientists.
I am going to put my money on 1.66 inches of rise by Jan 1 2040 at the Battery for NYC,
This is based on NOAA past trends as shown here of 2.92 mm per year since the 1800’s.
https://tidesandcurrents.noaa.gov/sltrends/sltrends.html
NY uses the qualifier “COULD” in there projection. I could say SL will rise by 13 feet and still be as truthful as anyone else making projections.
Someone will lose money due to policy based on this nonsense. 2030 is neigh enough to test the prediction in a court of law and to sue for reparations. If I were a lawyer I’d start preparing now, there are fortunes to be made.
I’m originally from NY State, the “God-Forsaken” far upstate (adjective from my ex wife’s family from Suffolk County). I observe from afar now. I chuckled when I read “…change in the political balance of NY”.
Then, I thought of the nation finally having had enough of the Obama administrations (that end this month).
Could it really happen in NY? I remain skeptical.
When the costs hit I hope that there may be enough of a shift so that the Democratic super-majority will be broken up. It may be that the shift will come when moderate Democrats realize that Progressive postions will lead to them losing.
“Value of identifying a broad range of plausible outcomes.”
Are they serious? Exactly WTF does that mean?
These people are insane.