Climate Act Draft Scoping Plan Building Sector Scenarios

The 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. The comment period for the Draft Scoping Plan is open until June 10, 2022.  The Council requested feedback on the components of three mitigation scenarios.  The overview summary of the components described the scenarios.  This post discusses the control measures in the building sector

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions 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 (85% reduction and 15% offset of emissions) 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”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. Comments on the draft can be submitted until June 10, 2022.

Integration Analysis Reference Case and Scenarios

Appendix G: Integration Analysis Technical Supplement of the Draft Scoping Plan was prepared by Energy and Environmental Economics (E3) and Abt Associates in December 2021.  The primary reference for the scenario descriptions is Appendix G Section I: Techno-Economic Analysis (Section I).  The Integration Analysis initially “evaluated a future that represents business-as-usual inclusive of implemented policies (Reference Case) and a representation of a future based on the recommendations from the Council’s Advisory Panels (Scenario 1)” (Section I p.11). The initial analysis found that the Advisory Panel recommendations in Scenario 1 did not meet the Act emissions limits (Figure 1).

The consultants developed three mitigation scenarios that were “designed to meet or exceed GHG limits and achieve carbon neutrality”.   The three mitigation scenarios are described in Section I on page 14.  This article describes the building sector actions.

The Annex 2: Key Drivers and Outputs Spreadsheet, Tab: Scenario Definitions table lists specific programs in the Reference Case.  The entire description of the contents of this information in Appendix G text is: “Scenario assumptions and level of transformation by sector and action for mitigation scenarios 2, 3, and 4 are summarized in the tables below.”  The lack of documentation makes it difficult to provide meaningful comments.

Table 1 extracts assumption data from that spreadsheet so that the Reference Case and four scenarios can be compared.  The table lists data for four categories of energy efficiency and electrification.  Note that I have added some numbers from the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet Space Heating-Res tables.  There are some slight differences between those tables and the Scenario Definitions table which could be because the table lists data for all buildings and I am only using the data for residences because that is my primary interest.

New Sales of Heat Pumps

The primary difference for new heat pump sales for the scenarios is the ramp rate.  Note that according to this modeling that the rate of heat pump sales for the Reference Case stays at 4% through 2030 in the table and until 2050 in the Reference Case Space Heating-Res table.  If heat pumps are all that they are cracked up to be then shouldn’t the rate of adoption be higher in the business-as- usual case?  As it is it seems to confirm that heat pump adoption cannot stand on its own. 

Scenarios 3 and 4 accelerate the deployment of heat pumps in 2030 by mandating early retirement of existing furnaces instead of waiting until their end of useful life.  It is easy to include this in a framework but there are at least a couple of implementation issues.  What criteria would be used to determine who would get stuck with the added expense for premature retirements?   Shouldn’t the affected owners get an additional subsidy to cover their costs?

The final condition in this category combines multi-family/commercial sales.  These numbers are not listed together anywhere in the Space Heating-Res tables.  Moreover, in 2030 none of the commercial or multi-family residential building sub-sectors are 100% so there is an inconsistency between the Space Heating-Res tables and Scenario Definitions table.

Mix of Heat Pump Technologies

I believe that this category represents the mix of heat pump technologies sold.  Another problem with the residential heating documentation is that the types of heating technology are not the same across all the different tables.  For example, the table that lists device costs provides values for four kinds of heat pumps (air source, hybrid oil electric heat pump, hybrid gas electric heat pump, and ground source heat pump).  The Space Heating-Res tables add ductless air source heat pump.  Unfortunately, for Scenarios 2-4 the ductless air source heat pump is the most common type of heat pump sold in the modeling results.  It was not my understanding that the ductless air source heat pumps were the primary choice for air source heat pumps.  Instead, I thought that the plan was to replace an existing furnace with an air source heat pump furnace.  The lack of documentation makes it impossible to determine the intent of the Integration Analysis modeling.

The biggest difference between mitigation Scenario 2 and Scenarios 3 and 4 is that Scenario 2 includes an option to use air source heat pumps with fuel backup.  This option is included to address the following statement in the Draft Scoping Plan:

In the State’s coldest regions, where heating systems are designed for temperatures of zero (0F) or lower, some homes that install cold climate ASHPs may therefore use supplemental heat (wood, home heating oil, propane, or gas) for peak cold conditions to avoid unnecessary oversizing of heat pumps and to mitigate electric grid impacts.

I agree that this is necessary but I think that there are issues with this option.  In the first place I presume that in Scenarios 3 and 4 these homes will have to rely on electric resistance heating for the supplemental backup needed.  What are the impacts of oversizing heat pumps and the electric grid impacts on affordability?  Oversizing the heat pump adds direct costs which are not reflected in device cost table.  If too many people have to rely on electric resistance heating, then there will be a spike in energy demand during the coldest periods.  That could mean the electric distribution system will have to be over built for those conditions.

In order for heat pumps to work they have to transfer energy.  At some extreme of cold weather air source heat pumps won’t have enough energy to provide heat.  This issue is an example of a clean energy technology that doesn’t work all of the time and the time when it does not work it is needed the most.  Advocates for the net-zero transition often ignore the significant costs needed to provide a reliable system for these worst-case conditions.  In this instance homeowners can address the problem by installing a ground source heat pump ($34K instead of $15K), installing a deep shell insulation and infiltration envelope instead of a basic shell ($45K instead of $6K), or adding electric resistance heat ($1K).  The problem with just adding electric resistance heat is that electric service to the home and neighborhood will have to be upgraded and that adds between ($4K and $9K) and who knows how much more for the added generation needed.  The alleged lower costs of Scenarios 3 and 4 suggest that this issue has not been included in the costs.

The other issue with this option is that the alternative to use home heating oil, propane, or gas may not be viable when most homes have converted to electricity.  Fuel oil and propane dealers probably won’t have enough customers to remain in business.  Delivering natural gas to an ever-decreasing number of homes will also likely have similar viability issues.

Share of Electrified Buildings

In 2050 the percentage of electrified buildings is 92% for all three mitigation scenarios.  Scenario 2 projects that 631,351 housing units will still use combustion heating sources and in Scenarios 3 and 4 634,66 housing units will use combustion sources. First point is that it is not clear that the two scenarios that are supposed to get away from combustion are projected to have more residences on combustion sources.  The same viability issues with oil, propane and gas suppliers are also a concern.

Share of Buildings with Efficient Shell

The Draft Scoping Plan approach depends upon “making energy efficiency improvements in all buildings, with the emphasis on improvements to building envelopes (air sealing, insulation, and replacing poorly performing windows) to reduce energy demand by 30% to 50%.”  The Plan documentation describes building shell improvement characteristics but does not describe the rationale for applying basic vs. deep shell packages.  There is an enormous difference ($45K instead of $6K) between the costs of the two types of building shells and there is insufficient documentation to determine how the Integration Analysis apportioned the technology across buildings in the state.  I submitted comments earlier that addressed the types of building shells.  I concluded that the Draft Scoping Plan underestimates the number of buildings that need deep shell upgrades.  That affects the cost projections significantly.

There is no difference in the percentage of building shell types for all three mitigation scenarios.  Importantly, note that 8% of the buildings are projected to not receive shell upgrades.  I guess that the same 8% of buildings that are not electrified don’t get building shell upgrades.


The Climate Action Council is obligated to provide a Draft Scoping Plan to fully account for costs.  I believe that means that all the control measures should be listed, the assumptions used referenced, the expected costs for those measures and the expected emission reductions for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  That information is not available.

Because this information is not available it is not possible to comment on the glaring inconsistency that Scenario 3: Accelerated Transition Away from Combustion and Scenario 4: Beyond 85% Reductions are projected to cost less than Scenario 2: Strategic Use of Low-Carbon Fuels.  As shown here if combustion is prohibited in more homes, then residential heating costs will have to go up significantly to address the problem of performance of air source heat pumps in extreme cold.

In my opinion, it is necessay to do a feasibility analysis for all three mitigation scenarios.  I think a properly done analysis will show that Scenario 2 has tremendous reliability and affordability risks.  I cannot believe that Scenarios 3 and 4 would not increase those risks.  The only rational scenario choice is number 2.

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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