Testimony to Montana Public Service Commission - CO2 Coalition

Testimony of Dr. Frits Byron Soepyan before the Public Service Commission of the State of Montana

Concerning

Petition for Adoption of New Rule I and Declarations Pertaining to the Commission’s Consideration of the Adverse Climate Impacts of Greenhouse Gas Emissions

8 April 2024

Background

My name is Frits Byron Soepyan, and I am a chemical engineer with B.S. and Ph D. degrees from The University of Tulsa. I have been accepted as In-Person Oppositional Commenter #1 at the State of Montana Public Service Commission (PSC) hearing on 8 April 2024 and I am currently employed as a Research and ScienceAssociate at the CO2 Coalition.

Introduction

When institutions of public trust such as the Public Service Commission are considering the implementation of far-reaching policies such as the one being discussed today, it is critically important that all of the best available scientific evidence is considered. The consideration of this proposal must be driven by scientific evidence, not a political agenda.

Unfortunately, the individuals and groups that are signatories of this petition are either unaware of, or have willfully chosen to ignore, the voluminous evidence that is contradictory to their claims of man-made climate catastrophes due to emissions of greenhouse gases, such as carbon dioxide (CO2). The basis for the Petitioners’ request for the Montana PSC to incorporate environmental and societal considerations into its decision-making are based on a lengthy list of alleged threats to ecosystems and human systems driven by man-made warming including:

• Increasing heat waves and high temperatures.

• Increasing areas burned by fire.

• Increasing extreme weather events including droughts, wildfires, heat waves and floods

• Increasing temperature-driven mortality.

• Reductions in wild game and fish.

• Climate-driven extinctions.

The Petitioners state:

In light of these existing and projected impacts, the State of Montana has recognized that “urgent action is needed to address the increasing threats and impacts of climate change...”

We shall show, using data from the National Oceanic and Atmospheric Administration (NOAA), the United States Environmental Protection Agency (U.S. EPA), United States Department of Agriculture (USDA), The National Aeronautics and Space Administration (NASA) and peerreviewed papers that the allegations of catastrophic consequences are not only false, but, in many cases, quite the contrary. Our evidence overwhelmingly shows that Montana’s ecosystems are thriving and prospering and that the citizens residing in Big Sky Country are benefiting from modest warming and more CO2

The science tells us that Montana would benefit from more CO2, not less.

If the Petitioners’ basis for imposition of extraordinarily expensive and economically crippling mandates and taxes are shown to be false, then the PSC has a duty to the citizens of Montana to “follow the science” and reject this petition request.

Historical Carbon Dioxide

As of March 2024, the concentration of carbon dioxide (CO2) in the atmosphere is about 425 parts per million (ppm) (NOAAGlobal Monitoring Laboratory, 2024). This is an increase of about 50% from its concentration at the beginning of the Industrial Revolution (~ 280 ppm) (European Environment Agency, 2019). This increase is attributed largely to human use of fossil fuels. Significant increases in atmospheric CO2 began in the post-World War II period of the mid-20th century, which means that if CO2 is responsible for warming, any CO2-driven warming should be seen beginning at that time (Figure 1).

Figure 1 – Global trends in atmospheric concentrations of CO2 (ppm) (1750–2018)

Data source – European EnvironmentAgency (2019)

When viewed in the long-term geological perspective, this 145-ppm increase is miniscule compared to the average throughout Earth’s history, which is 2,600 ppm, or over 6 times more than our modern CO2 concentration. The ancestors of our modern plants and crops first developed at levels in excess of 2,000 ppm (Figure 2) and current levels of CO2 do not allow plants to grow to their optimal potential due to CO2 starvation. In terms of plant and agricultural productivity, we don’t have too much CO2, we don’t have enough.

TemperatureAnalysis

The primary claim of the petitioners is that recent temperature increases are unusual and unprecedented and are being driven by increasing man-made greenhouse gases (primarily CO2). They state that the recent increase in heat waves and extreme high temperatures are leading to the other climate change disasters listed in the Introduction.

It is widely recognized that the United States and NOAA have the most extensive network of climate and temperature measuring stations in the world. Unfortunately, many of these stations have been corrupted by changes in their surrounding environment and expansion of urban and suburban infrastructure that leads to artificial warming in recent years (Soepyan et al., 2024). A subset of the entire NOAA data was created to remove the worst of the stations affected by this well-known “urban heat island effect.”

We will reference here the United States Historical Climatology Network (USHCN) data that are sourced from NOAA records from 44 weather stations across the state (NOAA National Centers for Environmental Information, 2023). While this data set is better than the full NOAA data set, alterations of the raw data served to warmmodern records, while coolingthe olderrecords, leading to an artificial increase in warming over the last ~ 80 years.

Figure 2 – Carbon dioxide (CO2): ~ 600 million years of data Data source – Berner and Kothavala (2001a, 2001b)

Montana Temperature

Figures 3, 4 and 5 show the annual average mean, minimum and maximum temperatures, respectively, in Montana, obtained from USHCN (NOAA National Centers for Environmental Information, 2023), and the atmospheric CO2 concentrations (European Environment Agency, 2019) These figures show that despite a large increase in the atmospheric CO2 concentration since ~ 1950, Montana has experienced a modest warming, at a rate of about 0.02 °F/year, since at least 1895, whenthe atmosphericCO2 concentrations werelower.Furthermore, at arateof 0.02°F/year, the temperature rise in Montana would be only 0.52 °F by 2050 and 1.52 °F by 2100, which are significantly smaller than the predicted values of 4.5–6.0 °F by 2050 and 5.6–9.8 °F by 2100 presented by the Petitioners.

Figure

Heat Waves

Contrary to the claims of increasing extreme heat and heat waves by the Petitioners, the data do not support these claims. Both in the contiguous United States (Figure 6) (United States Environmental Protection Agency, 2023a) and in Montana, heat waves and high temperatures peaked about 90 years ago during the Dust Bowl years, when the CO2 levels were about 100 ppm lower than they are today.

Figure

Figure

Figure 6 – Heat wave index for the contiguous United States

Data source – United States Environmental ProtectionAgency (2023a)

As for Montana, the record high temperature of 117 °F was recorded on 20 July 1893 in Glendive and on 5 July 1937 in Medicine Lake (NOAA National Centers for Environmental Information, 2024b) According to the data from USHCN (Figure 7) (NOAA National Centers for Environmental Information, 2023), the percentage of days in Montana with temperatures above 100 °F peaked in 1936, with no significant increase. These observations refute the claim that increasing atmospheric CO2 levels are driving extreme heat in Montana.

Figure 7 –

Percentage of days in Montana with temperatures above 100 °F vs. atmospheric CO2 concentrations

Data source – Atmospheric CO2 concentrations: European Environment Agency (2019);

Percentage of hot days: NOAANational Centers for Environmental Information (2023)

Nighttime Low Temperatures

Nighttime low temperatures across the country and in Montana are warming significantly. Figure 8 shows the percentage of nights in Montana with temperatures below 20 °F (NOAA National CentersforEnvironmentalInformation,2023).Risingtemperatures areextendinggrowingseasons in the United States (Figure 9) (Kunkel et al., 2004; United States Environmental Protection Agency, 2023) Killing frosts end earlier in the spring and arrive later in the fall, providing farmers with the opportunity for more plantings. In fact, by 2020, the length of the growing season in the UnitedStates has increasedbymorethantwoweeks (Figure9).Thecombinationofthelengthened growing season and the increasing atmospheric CO2 concentrations has proven to be beneficial for crop production in Montana (which will be discussed in greater details in theAgriculturalAnalysis section of this testimony).

Furthermore, in North America, there were 50 cold-related excess deaths, compared to 6 heatrelated excess deaths, for every 100,000 residents from 2000 to 2019 (Zhao et al., 2021). These data suggest that the cold has killed considerably more people than heat, which means that Montanans should be more concerned about a cooling climate, rather than the warming climate they are currently experiencing. Figure

– Increase in the length of the growing season in the United States relative to the 18952020 long-term average

Annual Precipitation

The Petitioners claim that drought is harming the agricultural sector and will lead to crop failure. Once again, the facts belie this claim. Figure 10 plots the annual precipitation in Montana since 1895. While there are large differences year to year in the amount of precipitation, there is no significant trend, which means that the annual precipitation in Montana is stable, and Montana is in no danger of drying or being inundated.

Figure 10 –Annual precipitation in Montana vs. atmospheric CO2 concentrations

Data source – Atmospheric CO2 concentrations: European Environment Agency (2019); Precipitation: NOAANational Centers for Environmental Information (2024a)

The Palmer Drought Severity Index (PDSI) for Montana (NOAA National Centers for Environmental Information, 2024a) is shown in Figure 11, where the PDSI estimates the relative soil moisture conditions using simplified soil water balance (NOAA National Integrated Drought Information System, 2024) Figure 11 indicates that the most severe droughts occurred during 1934-1938 and 1987-1989, when the atmospheric CO2 concentrations were ~ 300 ppm and ~ 350 ppm, respectively (European Environment Agency, 2019).

Snow

The Petitioners allege that declining snowfall and snowpack is having a detrimental effect on ski resorts. We examined the annual snowfall at eleven Montana ski resorts (Figure 12) (Mountain News LLC, 2024). Similar to annual precipitation, there is great variation year to year. Studying the data from Montana State University (2024) (Figure 13), which go back to 1980, further confirms that Montana is in no danger of losing snow.

Figure 11 – Palmer Drought Severity Index (PDSI) for Montana

Data source – NOAANational Centers for Environmental Information (2024a)

and Glacial Melt

Wildlife

The Petitioners allege that increasing temperatures are contributing to the increasing “mortality of fish, bird and mammal species.” The good news is that Montana’s wildlife is thriving (Montana Field Guide, 2024). Figure 14 reveals that for the last 50 years, the five species of trout in Montana are prospering (Montana Field Guide, 2024). Similarly, Figure 15 suggests that the number of observations for the upland game bird species are increasing (Montana Field Guide, 2024), which refutes the Petitioners’claim regarding the decline in the population of birds. Likewise, Figure 16 does not support allegations of a great decline in the populations of bison, white-tailed deer and pika(MontanaFieldGuide, 2024).Asforthepopulations of antelope,elk andmuledeer,oneneeds to consider that these mammals are migratory (Montana Field Guide, 2024). In fact, the Montana Field Guide (2024) has reported that the mule deer are more migratory compared to the whitetailed deer and “has [a] history of population fluctuations in [the] state.”

Figure 13 –Annual snowfall recorded at Montana State University, NorthwesternAgricultural Research Center, Kalispell, MT

Data source – Montana State University (2024)

Figure 16 – Number of observations of various mammal species in Montana

Data source – Montana Field Guide (2024)

Wildfires

The Petitioners allege an “increased prevalence of catastrophic wildfire with an increase in the size of severely burned areas in western North America.” Data from the National Interagency Fire Center (2020, 2024) (Figure 17) reveal that the number of wildfires in 2023 is about one-fifth of the highest value reported in 1981; and the area burned by wildfires in 2023 is about 5% of the highest value reported in 1930. The slight increase in the area burned since 1983 is a reflection of changes in forest management, rather than any linkage to climate change.

Agricultural

ThePetitionersclaim that“highertemperatures and watershortages haveharmedandareprojected to worsen harms to the agricultural sectors of the state’s economy.” We examined the data and find that, contrary to claims of an ongoing agricultural crisis, crop production in Montana is thriving and prospering.

TheprimaryindustryinMontanaisagriculture,whereoneofsixworkersinMontanaareemployed in agriculture and the top crop in Montana is wheat (NationalAssociation of State Departments of Agriculture, 2022). Figure 18 shows the production of wheat in Montana (USDA National Agricultural Statistics Service, 2024), which has been increasing for the past 150 years. Figure 19 shows the production of ten additional crops in Montana (USDA National Agricultural Statistics Service, 2024), with no visible sign of an ongoing crisis.

Figure 17 – Number of wildfires and burn area in the United States Data source – National Interagency Fire Center (2020, 2024)

Analysis

Figure 18 – Production of wheat in Montana Data source – USDANationalAgricultural Statistics Service (2024)

Figure 19 – Production of additional crops in Montana

Data source – USDANationalAgricultural Statistics Service (2024)

Air Quality

Contrary to the Petitioners’ claim of “reduced air quality,” the data from the United States Environmental Protection Agency (2023c) tell us that the air quality in the United States keeps getting better (Figure 20). In fact, the emissions of most of the pollutants shown in Figure 20 have decreased since 1990.

Natural Disasters

The Petitioners are concerned regarding “changes in the frequency and severity of natural disasters.” However, the data for Montana (Figure 21) show that the reported number of tornadoes has declined since 1991, the reported number of hailstorms has decreased since 2001, and the reported number of floods shows no sign of increasing since 1996 (NOAA National Centers for Environmental Information, 2024c). The increase in the reported number of hailstorms during the 1990s could be due to better reporting of hailstorms, rather than an increase in the number of hailstorms (Alimonti and Mariani, 2023; Happer et al., 2023)

Figure 20 – The emissions of various pollutants in the United States Data source – United States Environmental ProtectionAgency (2023c)

Greening of Earth and Montana

Significant increases in global vegetation have been occurring since at least the early 1980s, when the first satellites enabled large-scale observations (Figure 22). Numerous studies have

Figure 21 – Reported number of tornadoes, hailstorms and floods in Montana

Data source – NOAANational Centers for Environmental Information (2024c)

documented this worldwide expansion of flora for more than 40 years and attributed the growth to the combination of a warming planet and increasing carbon dioxide. In fact, according to a study funded by NASA Earth Science and supported by the U.S. Department of Energy (Zhu et al., 2016), from 1982 to 2009, up to 50% of the Earth’s vegetated area is experiencing “a persistent and widespread increase” in vegetation (greening), while less than 4% is experiencing a decrease (browning). This trend continues well into the 21st century, where from 2001 to 2020, 55.15% of Earth is greening, and 7.28% of Earth is browning (Chen et al., 2024) Multiple investigators, including those employed or funded by NASA, have confirmed that CO2 fertilization is 70% responsible for this greening (Hille, 2016; Schernikau and Smith, 2022; Zhu et al., 2016).

In Montana, the increase in foliage has been extraordinary (Figure 23). Since 2000, the leaf area, as measured bysatellites, has increasedby 20%. If CO2 levels were reduced, theecosystems would revert to former levels of lower plant and ecosystem productivity.

Figure 22 –Agreening planet Source – Modified from Zhu et al. (2016), permission R Myneni

Temperature IncreaseAverted by Net Zero

In 2016, Montana’s CO2 emissions were about 0.6% of the total for the United States (Figure 24)

According to the Model for the Assessment of Greenhouse Gas Induced Climate Change (MAGICC) (MAGICC IPCo, Inc., 2022) (Figure 24), if Montana had gone completely to net zero by 2010, the amount of warming that would have been averted by 2050 and 2100 are 0.0004 °F and 0.0011 °F, respectively (Cato Institute, 2023). This is well below our ability to measure and completely insignificant.

Figure

Figure 23 – LeafArea Index (LAI) in Montana

Source – Frantz (2024)

Summary and Conclusions

In summary:

• The modest warming of 0.02 °F/year since 1895 is neither unprecedented nor dangerous

• Heat waves are not increasing.

• Thewarming and the reducednumberof cold nights increasethe lengthofgrowing seasons for plants, which is beneficial for agriculture.

• Annual precipitation in Montana fluctuates from year to year but is stable overall

• Montana has experienced worse droughts in the 1930s and 1980s compared to today.

• Montana is in no danger of losing snow.

• The wildlife in Montana is thriving.

• Thenumberandareaburnedbywildfiresinrecent yearsaresignificantlysmallercompared to those experienced in the previous century.

• Montana is enjoying increased production of various crops, including its top crop, wheat.

• Air quality in the United States keeps getting better.

• Natural disasters in Montana are not increasing.

• Earth is greening, and CO2 is 70% responsible for this greening.

• Stopping CO2 emissions in Montana would only prevent a 0.0011 °F temperature rise by 2100.

In conclusion, there is no climate crisis in Montana and rising atmospheric CO2 concentrations is beneficial Policies should consider all scientific evidence prior to being implemented Based on the facts presented in this testimony, policies that punish CO2 emissions in the name of combatting a nonexistent climate crisis would do more harm than good.

References

Alimonti G, Mariani L (2023) Is the Number of Global Natural Disasters Increasing? Environmental Hazards, DOI: https://doi.org/10.1080/17477891.2023.2239807

Berner RA, Kothavala Z (2001a) GEOCARB III: A Revised Model of Atmospheric CO2 Over Pharenozoic Time. American Journal of Science 301, 182–204, DOI: https://doi.org/10.2475/ajs.301.2.182

Berner RA, Kothavala Z (2001b) GEOCARB III: A Revised Model of Atmospheric CO2 over Phanerozoic Time, IGBP PAGES/World Data Center for Paleoclimatology Data Contribution Series # 2002-051, NOAA/NGDC Paleoclimatology Program, Boulder CO, USA, https://www.ncei.noaa.gov/pub/data/paleo/climate_forcing/trace_gases/phanerozoic_co2.txt

Cato Institute (2023) Carbon Tax Temperature-Savings Calculator, https://www.cato.org/carbontax-temperature-savings-calculator

Chen X, Chen T, He B, Liu S, Zhou S, Shi T (2024) The Global Greening Continues Despite Increased Drought Stress Since 2000. Global Ecology and Conservation 49, e02791, DOI: https://doi.org/10.1016/j.gecco.2023.e02791

European EnvironmentAgency (2019) Trends inAtmospheric Concentrations of CO2 (ppm), CH4 (ppb) and N2O (ppb), Between 1800 and 2017, https://www.eea.europa.eu/data-andmaps/daviz/atmospheric-concentration-of-carbon-dioxide-5#tabchart_5_filters=%7B%22rowFilters%22%3A%7B%7D%3B%22columnFilters%22%3A%7B%2 2pre_config_polutant%22%3A%5B%22CH4%20(ppb)%22%5D%7D%7D

Frantz WF (2024) Personal Communication

HapperW, Lindzen R,WrightstoneG(2023)Challenging “Net Zero”with Science,CO2 Coalition, https://co2coalition.org/wp-content/uploads/2023/02/Challenging-Net-Zero-with-Science-digitalCO2-Coalition.pdf

Hille KB (2016) Carbon Dioxide Fertilization Greening Earth, Study Finds, The National Aeronautics and Space Administration, https://www.nasa.gov/technology/carbon-dioxidefertilization-greening-earth-study-finds/

Kunkel KE, Easterling DR, Hubbard K, Redmond K (2004) Temporal Variations in Frost-Free Season in the United States: 1895–2000. Geophysical Research Letters 31 (3), L03201, DOI: https://doi.org/10.1029/2003GL018624

MAGICC IP Co, Inc. (2022) MAGICC, https://magicc.org/

Montana Field Guide (2024) Montana Field Guides, https://fieldguide.mt.gov/displayClasses.aspx?phylum=Craniata

Montana State University (2024) Snowfall, Northwestern Agricultural Research Center, https://agresearch.montana.edu/nwarc/weather/SnowfallCY.html

Mountain News LLC (2024) Montana Snow Report, OnTheSnow, https://www.onthesnow.com/montana/skireport

National Association of State Departments of Agriculture (2022) Montana Department of Agriculture, https://www.nasda.org/state-department/montana-department-of-agriculture/

National Interagency Fire Center (2020) Total Wildland Fires and Acres (1926-2019), https://web.archive.org/web/20201224043154/https:/www.nifc.gov/fireInfo/fireInfo_stats_totalFi res.html

National Interagency Fire Center (2024) Wildfires and Acres, https://www.nifc.gov/fireinformation/statistics/wildfires

NOAA Global Monitoring Laboratory (2024) Trends in CO2, CH4, N2O, SF6, Trends in Atmospheric Carbon Dioxide (CO2), Earth System Research Laboratories, https://gml.noaa.gov/ccgg/trends/

NOAA National Centers for Environmental Information (2023) United States Historical Climatology Network (USHCN), Version 2.5, https://www.ncei.noaa.gov/access/metadata/landing-page/bin/iso?id=gov.noaa.ncdc:C00895

NOAA National Centers for Environmental Information (2024a) Climate at a Glance: Statewide Time Series, https://www.ncei.noaa.gov/access/monitoring/climate-at-a-glance/statewide/timeseries

NOAA National Centers for Environmental Information (2024b) Records, https://www.ncei.noaa.gov/access/monitoring/scec/records

NOAA National Centers for Environmental Information (2024c) Storm Events Database, https://www.ncdc.noaa.gov/stormevents/choosedates.jsp?statefips=30%2CMONTANA

NOAA National Integrated Drought Information System (2024) U.S. Gridded Palmer Drought Severity Index (PDSI) from gridMET, Drought.gov, https://www.drought.gov/data-maps-tools/usgridded-palmer-drought-severity-index-pdsi-gridmet

Schernikau L, Smith WH, “Climate Impacts” of Fossil Fuels in Today’s Electricity Systems, Journal of the Southern African Institute of Mining and Metallurgy (SAIMM) 122 (3), 133–146, DOI: https://dx.doi.org/10.2139/ssrn.3968359

Soepyan FB, Wrightstone G, Happer W (2024) Wyoming and Climate Change: CO2 Should be Celebrated, Not Captured, CO2 Coalition, https://co2coalition.org/wpcontent/uploads/2024/02/Wyoming-and-Climate-Change-Digital-February-2024-compressed.pdf

United States Environmental ProtectionAgency (2023a) Climate Change Indicators: Heat Waves, https://www.epa.gov/climate-indicators/climate-change-indicators-heat-waves

United States Environmental Protection Agency (2023b) Climate Change Indicators: Length of Growing Season, https://www.epa.gov/climate-indicators/climate-change-indicators-lengthgrowing-season

United States Environmental ProtectionAgency (2023c) Our Nation’sAir: Trends Through 2022, Air Quality Trends Show Clean Air Progress, https://gispub.epa.gov/air/trendsreport/2023/#air_trends

USDA National Agricultural Statistics Service (2024) Quick Stats, https://quickstats.nass.usda.gov/

Zhao Q, GuoY,Ye T, et al. (2021) Global, Regional, and National Burden of MortalityAssociated with Non-Optimal Ambient Temperatures from 2000 to 2019: A Three-Stage Modelling Study The Lancet 5 (7), e415–e425, DOI: https://doi.org/10.1016/S2542-5196(21)00081-4

Zhu Z, Piao S, Myneni R, et al. (2016) Greening of the Earth and Its Drivers. Nature Climate Change 6, 791–795, DOI: https://doi.org/10.1038/nclimate3004