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The New York City Council today held a hearing on a suite of bills to limit noise from helicopter flights over New York City. The bill most pertinent to carbon taxing is a resolution supporting a proposed NY State $400 “noise tax” on flights taking off or landing at the city’s heliports.

My testimony, presented below, situates the proposed noise tax in the context of social damage costing, also known as externality pricing. Previous CTC posts in this vein have covered NYC’s forthcoming congestion pricing plan, a California growers’ program that taxes excess withdrawals of groundwater for farming, and Berkeley, CA’s soda tax.

Educator from the NYC harbor ecology group Billion Oyster Project, at the April 16 City Hall Park rally organized by Stop The Chop NY/NJ. To speaker’s left are Councilmembers Lincoln Restler and Amanda Farias, lead sponsors of Intro 70 and 26.

As can be seen from photographs of the rally prior to the council hearing, the anti-heli-noise outfit Stop The Chop NY/NJ takes a reformist position on helicopter flights. I’m more militant in both deed, having helped organize a human blockade of the West 30th Street (Hudson River) heliport last September; and in language, preferring the term “luxury fights” to Stop The Chop’s “nonessential flights.” 

That said, I tip my hat to Stop The Chop for their scrappy advocacy raising the profile of helicopters’ aural and other assaults on New Yorkers’ quality of life. The bills in question would almost certainly not have been written without their years of organizing.

Testimony of Charles Komanoff[1] supporting Council Bills banning nonessential helicopter flights using municipal properties, and Council Resolution 0085-2024 endorsing state legislation imposing a noise-annoyance surcharge on nonessential helicopter flights in New York City[2]. Submitted on April 16, 2024. (My statement has been lightly edited for clarity. Bracketed numbers denote endnotes.)

I emphatically support Council bills Intro 26 and Intro 70 banning nonessential helicopter flights from the two City-run heliports. In addition, as an economist specializing in environmental costing,[3] I’d like to single out for praise Council Resolution 0085-2024 endorsing state legislators Kirsten Gonzalez’s and Bobby Carroll’s bills S7216B and A7638B imposing a noise fee on nonessential helicopter flights.[4]

The Gonzalez-Carroll noise fee is $100 per occupied seat or $400 per flight, whichever amount is larger. Although these levies appear to fall short of the average helicopter flight’s full societal cost, they are a commendable starting point. The levies can be raised later on, as methodologies for quantifying helicopter noise costs mature — a process that will be aided by passing a related bill, Intro 27. The fees can also be lowered if quieter helicopters emerge — which the Gonzalez-Carroll bills will incentivize.

“Cost internalization,” as this kind of social-damage pricing is termed, is long overdue for helicopter noise. “Luxury” helicopter flights — a more apt term, perhaps, than “nonessential” — impose other costs like carbon pollution and particulate-exhaust pollution. Moreover, these flights are purely discretionary. Anyone taking a luxury helicopter flight — whether to the Hamptons or JFK or for sightseeing — has money to spare, as revealed by their pricey transportation choice. Taxing helicopter noise is entirely consistent with economic justice.

Consider Blade’s JFK helicopter service from its Manhattan West 30th Street heliport — a flight covering about 15 miles. I’ve made a preliminary but serviceable calculation suggesting that one such flight steals around $2,500 worth of peace and quiet from city residents.[5]

A more militant protest: Extinction Rebellion’s Sept 2023 human heliport blockade. See our post from that month, “Grounding Helicopter Luxury.” Photo: Christopher Ketcham.

The Gonzalez-Carroll noise fee offsets only a fraction of that damage. But it amounts to a roughly 40 percent surcharge to Blade’s $250 standard ticket price to JFK, making it a worthy start. Assemblymember Carroll has been a legislative leader on externalities taxing, and it’s great to see Sen. Gonzalez also taking up the cause.

A noise fee raising the price of a commuter helicopter trip by 40 percent will cut usage, hence, the number of flights, by 30 to 50 perceny,[6] as some would-be passengers opt out. (Yes, just like congestion pricing, except more draconian, and deservedly so). That will not only bring peace and quiet, it will generate $10 to $15 million per year[7] — revenue that New York City can use to expand and enforce noise-abatement rules citywide.

Noise isn’t the sole harm that commuter and tourist helicopters inflict on the millions of residents below. But it is the most egregious and insulting. Every member should vote Yes on the bills to ban nonessential helicopter flights from the two City-owned heliports. And please also vote for Council Resolution 0085-2024 to make clear to your Albany counterparts that New York City’s local elected officials support the Gonzalez-Carroll helicopter noise fee.

Endnotes.[8]

[1] Policy analyst and consulting economist at KEA, 11 Hanover Square, 21st floor, New York, NY 10005. Website www.komanoff.net.

[2] This document is available on line as https://www.komanoff.net/jet_skis/Komanoff_Testimony_City_Council_Helicopter_Noise_Costs.pdf.

[3] My work quantifying and supporting NYC congestion pricing is widely known; much of it is collected here. My body of research also includes Drowning in Noise: Noise Costs of Jet Skis in the United States, a monograph co-authored with Dr. Howard Shaw and published in 2000 by the Noise Pollution Clearinghouse.

[4] Assemblymember Bobby Carroll represents part of Brooklyn. State Senator Kristen Gonzalez represents parts of Brooklyn, Queens and Manhattan.

[5] Key assumptions in my calculation of a $2,500 collective noise cost per flight from W 30 St to JFK Blade include: 625,000 households in Manhattan, Brooklyn and Queens households lie within the helicopter noise field; excess noise of 20 dBA during the average 44 seconds of noise exposure for each flight; a “Noise Depreciation Index” — reduced property value per additional decibel during exposure — of 1%. Some parameters in the calculation are placeholder values, making the resulting $2,500 estimated per-flight collective noise cost preliminary and subject to change. See Excel spreadsheet referenced in final endnote.

[6] The 30 percent reduction is associated with a price-elasticity of helicopter flights of negative 1, while the 50 percent reduction comes from a price-elasticity of negative 2. The respective calculations are: 1.4^(-1) ~ 0.7, and 1.4^(-2) ~ 0.5. (My high price-elasticity figures reflect the discretionary and luxury nature of helicopter travel.) See Excel spreadsheet referenced in final endnote.

[7] The number of helicopter flights per year that would be subject to the Gonzalez-Carroll noise tax appears to be between 50,000 and 60,000 per year. I have used the lower figure (50,000) in my calculations. Taking into account that the incorporation of the proposed tax into the price of helicopter flights would be expected to reduce the number of flights by 30 to 50 percent, and applying a per-flight noise fee of $400, the annual tax revenues, rounded, calculate to between $10 and $15 million per year (50k x $400 x 50% or 70%).

[8] An Excel spreadsheet (NYC_Helicopter_Flights_Externality_Costs.xls) with assumptions, calculations and citations supporting my preliminary $2,500 per-flight noise cost estimate, my tax revenue estimate of $10 to $15 million, and other figures in my testimony may be downloaded via this link: https://www.komanoff.net/jet_skis/NYC_Helicopter_Flights_Externality_Costs.xlsx.

Carbon Footprint

McKibben opts for a small-tent climate movement

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A few months ago I went to a climate change forum at the Center for Brooklyn History. The panel I attended, “Confronting Climate Change: Understanding Deniers,” featured the prominent climate activist, Bill McKibben.

Bill McKibben. Courtesy https://billmckibben.com/.

I was curious to hear McKibben’s take on climate change deniers. I don’t regard the true deniers as a big problem – they’re only 11-15% of our country, according to most polls. Rather, I wondered if McKibben would label as “climate deniers” people who agree that climate change is a significant problem but disagree with his framing and his proposed solutions. I have worked for decades on energy and climate matters as an energy lawyer. Now, more than ever, I believe that to address climate change we need to build a big tent.

In the Q&A I tested where McKibben is on this by asking if he would label as a climate denier someone who subscribes to the main tenets of climate change science yet holds that natural gas has a role to play as a bridge fuel. (Our exchange starts at 1:12:45 of the video.)

This could have been a chance for McKibben to make clear that such a view isn’t climate denialism, even if he feels it’s misguided. But he punted, saying “I don’t care whether they’re deniers or not.” For good measure, he threw in his long-standing refrain that swapping coal for natural gas makes climate change worse, despite coal’s far higher carbon content per unit of energy.

674-MW methane-powered generating station, Salem, MA.

As you can hear in the recording, McKibben’s claim that gas is worse than coal draws on the work of Cornell scientist Robert Howarth. Yet McKibben didn’t mention that Howarth’s work is controversial and disputed by many scientists. The crux of the dispute is whether methane’s impact on warming should be measured with a 20-year or 100-year time frame.

Methane is a relatively short-lived greenhouse gas, with a lifetime of around 10 years, versus the 100-year life applicable to carbon dioxide. But each ton of methane is far more potent while in the atmosphere, trapping roughly 100 times as much heat as a ton of CO2. These cross-cutting facts about atmospheric methane — shorter life but greater potency than CO2 — have resulted in two opposing camps: one insisting on a 20-year timeframe for greenhouse gas accounting, the other adhering to the established 100-year frame. This matters because with a 20-year timeframe, generating electricity with natural gas (which, chemically speaking, is essentially all methane) is more damaging to climate than coal-fired electricity.

McKibben blew past this dispute. To hear him at the Center for Brooklyn History, one would have no inkling that there’s an active disagreement over which timeframe to use, that there are staunch climate activists who favor the 100-year time frame, and that the Intergovernmental Panel on Climate Change  (IPCC) generally uses the 100-year timeframe.

McKibben’s latest (2025) book. Published by W.W. Norton & Company.

McKibben also insisted that a discussion about natural gas’s potential role in mitigating climate change as a replacement for coal is irrelevant because solar “is now our cheapest resource.” McKibben’s claim, of course, suffuses “Here Comes the Sun,” his 2025 book that extols solar power as the cheapest solution for all of our energy needs. But this too is questionable, because it’s based on cost comparisons between solar farms and natural gas power plants (or nuclear power plants) that fail to consider that electricity supply and delivery is a complex system of wires and plants rather than individual power plants. Based on his remarks, McKibben is choosing to ignore studies such as the comprehensive 2025 report from the Clean Air Task Force that concluded that plant-level cost comparison “is a good metric to track historical technology cost evolution [but] is not an appropriate tool to use in the context of long-term planning and policymaking for deep decarbonization.” And the task force is not alone in finding that when electricity is treated as a system, solar loses its place as the cheapest low-carbon resource.

The dogmatism McKibben displayed at the Brooklyn meeting was unfortunate. We’re in a time when efforts to combat climate change are in retreat. A unified front is required to turn the tide. Instead of doubling down on absolutist positions, activists like McKibben who seem convinced that the solution to climate change is all-renewables, end of discussion, should be seeking common ground with others who want climate action but believe that nuclear power and natural gas must also play a role.

NYC Climate March, Sept 17, 2023. Photo: C. Komanoff.

Climate change activists need to build a bigger tent, rather than call anyone who disagrees with their positions a climate change denier. It is striking that McKibben stuck to his guns after saying in the same talk that the most important goal for everyone right now is to help climate change realists win more House and Senate seats in this year’s midterms. As some have noted, an absolutist position on natural gas appears less likely to achieve that win and politicians are following that advice.

Will McKibben evolve? He has demonstrated that he knows how to build a national climate movement centered around issues like divestment. Given the current political situation, he should focus on building an even bigger tent by welcoming all of the 85% who believe that we need to address climate change but do not agree with his ideological positions.

Rich Miller is an energy lawyer who has worked for a variety of stakeholders and now gives walking tours in lower Manhattan on the history of electricity. 

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Carbon Footprint

Rebranding ‘Balcony Solar’ as ‘Guerrilla Solar’ won’t lift its climate value.

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Image generated with Claude. Why have we juxtaposed a bicycle with balcony solar? Read on.

First it was Plug-In Solar. Then it was Balcony Solar. Now it’s Guerrilla Solar, at least according to Inside Climate News, which yesterday proclaimed that The ‘Guerrilla Solar’ Era Has Arrived.

“It,” of course, is Modular solar panels. They’re the hot new photovoltaic solution: cheap enough to buy at Home Depot, easy to hang or prop to catch maximum rays, and small enough to fit on a balcony (if you’ve got one) and plug into your “home grid.” But, alas, too meager a generator of electricity to be more than a bit player in decarbonizing most U.S. homes.

How do I know? I’ve done the math.

A standard, lower-end 220-watt balcony solar array will produce 337 kilowatt-hours a year, or 28 kWh a month averaged over the course of a year. That’s for a 220W unit measuring 3.5 feet by 3.5 feet. (220W x 1/1000 x 17.5% x 8760 hours per year = 337 kWh. Calculation assumes a 17.5% full-year capacity factor, which is arguably generous for New York, where I live. )

Our balcony solar mashup. Top: an install in Germany. Bottom: Home Depot advert.

A typical U.S. home consumes 10,500 kWh a year, or 28 to 29 kWh per day, says Solartech, drawing on U.S. Energy Information Administration data. That puts a home’s daily power needs on par with a balcony solar unit’s monthly output. In effect, once each month the balcony array gifts a homeowner or renter a bit more than day’s full complement of electricity. And earth’s atmosphere gets the same respite: a 3 percent reduction in carbon emissions caused by the home’s electricity usage.

(The 3 percent figure could also be calculated directly by dividing 337 kWh per year of solar production by 10,500 kWh per year to run the home. For bigger or smaller arrays, just prorate your assumed wattage by my 220W; for 440W, say, double my figures.)

Balcony Solar metrics

Why write about balcony solar if it’s so inconsequential? CTC’s mission includes puncturing would-be climate balloons before they ascend too far. In the same vein, we practice quantification to make clear what does and doesn’t move the climate needle. (More on that further below.)

The best way to depict balcony solar’s climate value is to express it in terms of tangible metrics. We’ve selected two. Both assume the basic, lower-end PV array I assumed at the top: a 3.5 foot-square array whose peak output is 220 watts.

1. It would take 50 million 220W balcony solar units (bsu’s) to restore the climate benefit we destroyed in 2020-2021 when we shut the high-performing Indian Point nuclear power plant 32 miles from Midtown Manhattan.

2. A single person cutting back their driving by a mile a day would provide the same climate benefit over the course of a year as a single 220W bsu.

(Calculations in sidebar. Now you know why we led with images of an urban dweller as cyclist and balcony solar user.)

Yes, it’s dense — as befits a sidebar. The numbers tell a story. Follow the color co-ordination.

Ponder that: It would take fifty million smallish bsu’s to level up to the fossil fuel carbon emissions that Indian Point was keeping at bay by supplying the New York City area year in and year out with abundant carbon-free power. Deploying that many balcony solar units would entail 10 bsu’s for each of the 5 million households in the MTA’s service territory. (The Metropolitan Transportation Authority provides subway, bus and commuter rail transit in the five boroughs and seven suburban counties.) Or, if those same households upgraded to 1100-watt bsu’s, collectively they would still make up only half of the lost Indian Point power.

The second comparison, involving driving, is perhaps trickier to grasp but more interesting, since it relates to people’s behavior. Living differently isn’t part of public discourse, at least not in the USA, and especially when what’s being served up is using less. But “reducing,” as we might call it (remember “Reduce, Reuse, Recycle”? or, “Insulate, then Insolate”?) is just as potent for cutting emissions as switching to renewables — even more so when the reducing means driving less, considering the multitude of benefits that accrue from diminishing cars’ imprints on our communities. Still, staying on topic: driving just one fewer mile per day brings about the same shrinkage in carbon emissions as deploying one 220W solar array.

What Balcony Solar boosters are really saying

To be fair, our friends at Inside Climate News and, yes, The New York Times appear to be trying to modulate their balcony solar enthusiasm.

ICN‘s Dan Gearino, whom we cited up front, said he looked to Germany, the birthplace of balcony solar, to see if the units made sense for U.S. households. His takeaway: “It may make more sense financially to spend the cost of plug-in solar on insulation, air sealing or other basic measures to reduce energy use.” Hooray: insulate before you insolate.

Gearino helpfully interviewed renewables guru (and U.S. emigré) Craig Morris, who currently heads Germany’s plug-in solar trade association, Bundesverband Steckersolar. To Morris, balcony solar’s main advantages are that it provides power without taking up land, and that it affords people a way to “become participants in the transition to clean energy.” Behold, guerrilla solar. That, in turn, bolsters “the political consensus that supports the transition.” But Morris also made clear that widespread adoption of plug-in solar would only meet “about 2 percent of Germany’s electricity demand.”

Morris’s “about 2 percent” feels right for Germany. But not for the U.S., where widespread adoption of virtually any individual carbon alternative seems forever out of reach, and where the energy pie is so much larger — think giant fridges, freezers for beer, steroidal homes bursting with piles of powered toys, not to mention industrial and institutional electricity use that Morris correctly excluded from his figure.

Don’t forget to micro-dose. NYT headline + image for David Wallace-Wells’ guest essay (see text). Image by Rui Pu.

Both Gearino and Morris seem more measured than climate journalist Robinson Meyer, founding editor of Heatmap and frequent contributor to The Times, where he wrote about balcony solar in mid-June.

“New zero-carbon power kits will allow Americans to make their own energy choices,” declares the callout to the print version of Meyer’s NYT guest essay, The Tiny Solar Panel That Could Change America. (The even more expansive print headline invites us to “Forget Roofs. Backyard Solar Is the Next Frontier.”)

Wallace-Wells is of two minds. He calls balcony solar “a small way that apartment- and condo-dwelling Americans can take ownership of their energy choices and cut down their pollution on the margins.” No quarrel there, thanks to his qualifiers “small” and “on the margins.” Earlier, though, he opines that balcony solar units “have the potential to change how Americans understand and consume energy,” But read further and you’ll again see Wallace-Wells cautioning that “Balcony solar will play one small role in [the] drama” of transiting to the new world of clean, abundant energy.

Any such caveats are welcome these days, amid widespread solar hoopla. Still, it doesn’t seem to be in Wallace-Wells’ toolkit — or that of Inside Climate News and other mainstream climate journalists — to tutor their audiences as to the  true limits of balcony solar and other panaceas. Just like it wasn’t in their field of vision a decade ago to lay out the true stakes of shutting Indian Point as Riverkeeper was singing its siren song.

What’s Next for NY Balcony Solar

Meantime, as Canary Media reported recently (and helpfully), New Yorkers concerned with climate and affordability are waiting for NY Gov. Kathy Hochul to sign the recently passed SUNNY (Solar Up Now New York) Act legalizing balcony and other plug-in solar. It would be head-spinning (and politically suicidal) if she didn’t, given near-universal support ranging from Con Edison to DSA Assembly Member Emily Gallagher, who told Canary Media, “This is the most popular bill I’ve [ever] worked on.”

My guess is that Hochul is waiting for the right moment, and perhaps the right “package,” that can advance and not undercut her push to launch five large new nuclear power plants around the state — one to be built by the public New York Power Authority, the others to be constructed and operated privately. A little bit of math, a la what we offered here a la Indian Point, might help her out.

The governor also must manage the veritable hot potato of her deferred implementation of the landmark 2019 Community Leadership and Climate Protection Act. She might do well to consider jettisoning the act’s unwieldy cap-and-invest centerpiece in favor of a straight-up carbon tax (with the revenues distributed pro rata to the state’s households) in its place. That, far more than balcony (or guerrilla) solar, could blow open the door to the “innovations and technologies we cannot yet imagine” that Wallace-Wells fantasized about in his Times essay.

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Carbon Footprint

The new SBTi Corporate Net-Zero Standard: what it means for business

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On 11 June 2026, the Science Based Targets initiative (SBTi) published the most substantial revision of its flagship corporate framework since its introduction. The SBTi Corporate Net-Zero Standard Version 2.0 takes effect on 1 February 2027 and reshapes the way companies approach their net-zero targets.

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