Climate Act Draft Scoping Plan Comment on Residential Heating Electrification

New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. This post describes comments on residential heating electrification retrofits that I submitted on 2/15/22.  I found that the documentation is insufficient and that the cost estimates are low.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented.   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.

Climate Act Background

The Climate Act establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. Starting in the Fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023.

The Integration Analysis estimates that the buildings sector is the largest source of existing GHG emissions.  In all the future scenarios building emissions reductions are driven by “rapid electrification, increased energy efficiency, and improved building shells”.  For home heating electrification that means conversion to heat pumps and improvements to building shells to minimize the energy needed to heat homes.  Late last year I published an article that provided background for this sector.  It also included a table that was updated last month that used the Integration Analysis documentation that could estimate the costs to replace existing home heating systems with all electric systems.  More recently, I documented my fruitless search for the cost numbers presented as graphs in the Draft Scoping Plan.  My comment was based in large part on the material in those posts.

Summary of the Comments

The comment submittal is available along with the calculation spreadsheet.  In my opinion, home electrification is a primary concern for New Yorkers given the importance of affordability and the widespread impact to every household.  Accordingly, I spent a lot of time trying to replicate the costs to retrofit existing furnaces with heat pumps so that I could provide substantive comments explaining whether I thought they were doing it right.  Unfortunately, the documentation was not of sufficient quality to enable me to match their numbers.

One of the points of my comments is that this level of documentation is not acceptable. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan (my emphasis added).  The fact that the only description of net direct costs is a bar chart without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in the Draft Scoping Plan.

I also pointed out that there is a Public Service Commission mandate that needs to be considered.  Public Service (PBS) CHAPTER 48, ARTICLE 4, § 66-p. Establishment of a renewable energy program (4) states:

The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

I maintain that the only way to ensure that there won’t be a significant increase in arrears or service disconnections is to provide fully documented cost numbers.

In addition to the comment document, I attached a spreadsheet that replicated relevant tables from the Integration Analysis spreadsheets, explained how I thought the cost to retrofit residences with heat pumps should be calculated and compared that to what was available.  The comments describe the missing documentation that is needed to replicate their projections.

My analysis found that a primary driver of home heating electrification is the building shell cost.  I argued that a more refined climatology of cold weather was appropriate.  The Draft Scoping Plan claims only 26% of residences need deep shell upgrades.  I estimate that more than half actually will need to have deep shell upgrades using a more refined climatology.  As far as I can tell from the graphs, I estimate that the entire building sector component cost is $230 billion relative to the reference case in the Draft Scoping Plan.  I calculated that just the residential retrofit heat electrification costs range between $259 billion and $370 billion using one methodology and between $295 billion and $370 billion using a different methodology.  The primary driver of costs is the number of residences that need deep building shell upgrades.   

In order to support my contention that there was insufficient documentation I documented my calculations to show where the documentation is inadequate.  While some aspects of the cost projections are documented in the Integration Analysis spreadsheets, there are critically important numbers missing.  Moreover, the calculation flow is not documented well enough to reproduce the cost projections.  It is unacceptable that the component costs shown in the figures of the Draft Scoping Plan are not provided.

The residential home heating retrofit component of building costs discussed in my comments are a good example of what should be provided for a publicly available evaluation.  The spreadsheets should provide all the data used in the calculations and describe the flow of data between table calculations should also be provided.

Other additional information is needed. I provided examples from my evaluation of the residential heating retrofit spreadsheet.  I suspect that the device costs vary over time but there is no documentation.  Any other values that change with time should also be documented. Building shell assumptions and values used are particularly important given their out-sized impact on the final costs.  What was the rationale for the values used?  Was there an uncertainty analysis of the effect of these assumptions?  How were the building shell assumptions used to estimate air and ground source heat pump distributions?  How were mobile homes addressed?  How many residences were deemed inappropriate for heat pumps?  What is the technology expected for those residences in the future?

Finally, I recommend that the Climate Action Council have a technical workshop that focuses on home electrification.  It is important that this workshop explain how the Integration Analysis calculated all the numbers presented.  An opportunity for stakeholders to provide questions beforehand to be addressed at the workshop would be appropriate as well as the chance for stakeholders to ask clarifying questions during the workshop itself.  The emphasis should be on the exchange of technical information without any opportunity for personal comments.  Throughout the implementation process to date, only one side of the transition challenge has been heard.  It is time to open up the discussion.

Conclusion

My comments on the Draft Scoping Plan addressed several issues related to the lack of documentation and provided suggestions for going forward.  The Climate Act requires the Climate Action Council to make evaluation of the total potential costs and potential economic and non-economic benefits “publicly available”. The fact that the only description of the net direct costs in the Draft Scoping Plan are bar charts without a breakdown of the cost components clearly demonstrates that this Climate Act requirement has been ignored in Plan.  I outlined what is needed to provide satisfactory information in the supporting spreadsheets and suggested that a technical workshop focused on electrification of residential heating given that impacts to most citizens.

My analysis highlighted the importance of building shell technology on heating electrification.  Because the documentation is so limited it is difficult to determine the assumptions used to project the requirements.  However, I believe that the Draft Scoping Plan underestimates the number of buildings that need deep shell upgrades.  That affects the cost projections significantly.