Climate Leadership and Community Protection Act Energy Efficiency and Housing Advisory Panel Strategy Comments

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets.  This is one of a series of posts describing aspects of that process.  This post is my reaction to the Energy Efficiency and Housing Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability.  There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

 General Comments

I believe that the primary consideration of any implementation strategy should be affordability and reliability for the energy system of New York.  Energy use is largely inelastic so increased energy costs are hidden regressive taxes.  Our society needs dependable energy so current reliability standards must be maintained.  In general, each strategy must address potential costs and who would pay, whether there are co-benefits that would offset costs, any impacts on energy reliability, the feasibility of the proposed action, and the GHG reduction potential.

I believe that the CLCPA implementation strategies should consider cumulative environmental impacts of the renewable energy development proposed.  As far as I can tell the only related environmental impact analysis was the Department of Public Service (DPS) Final Generic Environmental Impact Statement and the Final Supplemental Environmental Impact Statement for CASE 14-M-0101 – Reforming the Energy Vision and six other cases.  The supplemental impact statement evaluated the potential environmental impacts of the Clean Energy Standard mandating that 50% of all electricity consumed in New York by 2030 be supplied by renewable resources.  Of course, the CLCPA upped the ante and now 60% of all electricity of all electricity must be supplied by renewable resources by 2030.  The important point is that the amounts and types of new renewable generation that may be needed to meet the CLCPA goals are much larger than anything evaluated by the State to date.   The supplemental impact statement evaluated a base case large scale renewable on-shore wind increment of approximately 29,000 GWh (9,508 MW) and a high-end case of approximately 40,000 GWh (14,504 MW) of large-scale on-shore wind energy would be necessary to meet the goal.  The Analysis Group “Climate Change Impact Phase II – An Assessment of Climate Change Impacts on Power System Reliability in New York State” draft final report released in October 2020 projected that New York would have to develop all of the projected National Renewable Energy Lab’s technical potential on-shore wind capability of 35,200 MW – three times what has been evaluated.  Similarly, no one has evaluated the environmental impact of the latest estimates of utility-scale solar and off-shore wind.

I have a general concern about the CLCPA mandates for investments.  It is entirely appropriate that there should be an emphasis on environmental and social justice but I have concerns about the State’s approach.  Given that all other jurisdictions that have attempted to reduce GHG emissions have increased the cost of energy, it is likely that will be the case in New York too.  I think strategies have to consider cost-effectiveness to reduce the regressive impact on those who can least afford those increased costs, regardless of location, who are living in energy poverty or already have a disproportionate energy burden.  This means that strategies that do not reduce costs or have low GHG reduction potential should be ranked very low for future consideration.

Comments on Proposed Strategies

The Energy Efficiency and Housing Advisory Panel had 16 strategies in five scoping categories.

The first scope was titled as “Mandates that require energy efficiency improvements and on-site emissions in building and appliance with dates as market signal” and included two strategies:

      • Expand State energy & building codes (with date signals) to drive the transition to electrification & building efficiency and
      • Modify State Appliance Standards (for example, ban fossil fuel appliances sales and installations). Consider building performance standards for large buildings to meet 2050 and interim targets with a focus on onsite emissions.

I don’t think the public is going to be willing to make the sacrifices called for in these strategies.  It would be best for all concerned to get out there with publicity now to gauge acceptability.  There are all sorts of issues. For starters, how will house trailers be considered.  For the rural poor this is often all they can afford and it is simply not possible to improve energy efficiency much.   There also is an implementation issue associated with housing sector date-certain efficiency standards.  What happens to someone trying to sell an old house after the certain date. Presumably, they will be on the hook to spend whatever is needed to get up to the efficiency standard to be able to sell and that means losing a big chunk of equity in their home or the house is priced out of the market and they cannot sell the house.

Three strategies were listed in the “Financing and incentives for building efficiency and electrification at scale” scope:

        • Inducing market/behavioral change (e.g., taxes, registration fees, carbon levies) that incentivize market providers (owners, developers, lenders etc.) and residents to reduce emissions and transition to electrification;
        • Shift lenders to quantify energy efficiency in single/multifamily/commercial (e.g. underwriting to savings); and
        • Financial incentives for owners, developers and residents (e.g. cash incentives, pay as you save, low-interest financing, more agile of existing programs to get to 2050 and interim targets, etc.), with emphasis on low and middle income owners.

The biggest hurdle for these strategies is cost.  In many instances the capital cost of the electric option is more expensive than the fossil fuel option.  Moreover, I see absolutely no reason to expect that the cost of electricity will go down because that has not been the case in any jurisdiction that has attempted to meet GHG reduction targets.  I also have reservations about taxes, registration fees or carbon levies and the proposed emphasis on disadvantaged communities.  In the first place the requirement for targeted investment benefits may have the perverse effect of increasing the overall cost of energy because those investments may not be the most cost-effective approaches to reducing CO2 emissions.  If that is the case then anyone who is not a direct beneficiary of financial incentive benefits is going to be hurt. The Climate Action Council needs to track energy poverty or energy burden and the effect of these policies on those who can least afford additional energy costs so that no one (whether or not they are in a dis-advantaged community) is literally left out in the cold.

The third scope was called “Training and education of building decarbonization to improve behavior and operations for health and comfort and build workforce (enabling strategy)”.  Three strategies were included:

        • Workforce development to provide skilled professionals to design, build, operate, & enforce decarbonized building stock;
        • Education -owners, developers, design professionals and other stakeholders: resources on capital planning, all-electric buildings, electrification-ready, etc. Mandatory energy performance disclosures and building consumption data (public facing); certified product declarations for materials/equipment; and
        • Education-residents/businesses: performance, economics., environmental quality, operation and maintenance for low-carbon technologies.

Clearly, we need to train professionals to design, build, and operate the decarbonized building stock but what is the meaning of enforce decarbonized building stock? When proposing building decarbonization strategies you have to prove that decarbonization will be affordable, maintain current levels of reliability, not lead to unintended environmental consequences that exceed the alleged impacts of climate change in New York, and actually have some sort of quantifiable effect on climate change.

The “Technology innovation and demonstration to drive better performance, reduce costs, and increase customer confidence” scope had four strategies:

      • Research and development to improve cost/performance of solutions for all-electric buildings (e.g., cold climate heat pumps, geothermal, etc.);
      • Research, development, and demonstration for hard-to-electrify buildings (e.g., on district steam, steam-heated, hydronic distribution) and advance scalable solutions and potential cost reductions (e.g., community geothermal, industrialized fabric/modular, virtual tools);
      • De-risking demonstrations to help critical customer groups who may lack access to resources and information (e.g., coops/condos); and
      • Approaches to reducing embodied carbon (e.g., new tech to reduce GHG emissions from materials/construction/transportation).

The American Council for an Energy-Efficient Economy published a paper that raises issues with air source heat pumps:  Field Assessment of Cold Climate Air Source Heat Pumps.  The 2016 report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps (ccASHPs ) were directly compared to propane and heating oil furnaces.  The study found these systems have the greatest potential for adoption in cold-climate regions where natural gas is not available for space heating; ccASHPs can offset the use of more expensive delivered fuels, and for homes with electric resistance heat, can result in a significant reduction in electrical use; that it is feasible for a utility energy efficiency program to receive credit for the energy savings achieved from ccASHPs through the reduction in fuel oil and propane;  and that during periods of very cold temperatures when ccASHPS do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.  These conclusions are not compatible with the CLCPA targets.

In addition to the feasibility of wide-spread use in New York there is another issue.  I did a simple case study that illustrates my concern that wide-spread implementation of air source heat pumps coupled with increased use of renewables will be difficult.  In my analysis the meteorological conditions on New Year’s Eve 2018 show that the proposed Horseshoe solar facility with a nameplate capacity of 180 MW and a wind farm with a nameplate capacity of 100 MW would have been just able to cover the conversion of 2,737 homes to air source heat pumps.  However, energy storage capable of at least 372 MW-hr also has to be available somewhere.  There already are 47,000 homes using electricity and another 15,000 homes that are supposed to be cost-effective candidates for conversion just in two neighboring counties to the facility.  Most importantly, this is just one component of residential electricity load which is one component of total load.

The strategies proposed by this Advisory Panel are appropriate but the details should make it clear that a similar study in New York on the latest air source heat pumps is required.  That should be coupled with an assessment of the renewable energy resources.  It is not clear to me that it is possible to meet the multi-day winter doldrum period while relying on wind and solar.  Analysis of the data shows that no amount of over-building solves this problem.  Extraordinary amounts of storage are needed.  In order to determine just how much of energy storage will be required much better estimates of the load expected for electrifying homes and transportation are needed.

The final scope “Resilience and climate adaptation strategies for all-electric building, hazard mitigation planning and building retrofits” had four strategies.

      • Supporting/coordinating improved resiliency solutions for all-electric building & resilient spaces for vulnerable pops.;
      • Grid and transmission resilience and independence;
      • Electrification paired with supplemental heating sources;
      • Improving building stock to withstand the impacts of climate change.

Resiliency is a buzz word employed to suggest that these policies will be improvements to systems so that they can better recover from difficult events.  What are the resiliency solutions for all-electric buildings when there is an ice storm?  According to Wikipedia ( “The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern Quebec, New Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months.  The only way those people survived is because they had alternatives to electricity.  When electricity is the only option available then what?


I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study.  It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar.  The only way this might work will require extraordinary amounts of energy storage, wind, and solar development.  When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.

From what I have heard the consensus opinion on the advisory panels is that air source heat pumps are an unqualified solution to residential heating.  The Minnesota field study suggests otherwise.  It would be appropriate for the panel to include a strategy for New York to replicate that study to prove that this solution will work here. In addition, a strategy to assess the potential impacts to society when the inevitable next severe ice storm occurs should be included.


Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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