The Climate Leadership and Community Protection Act (Climate Act) final draft Scoping Plan framework for the transition plan has been released. It has become clear recently that the Hochul Administration approach to the net-zero transition is to follow the narrative that meeting a net-zero by 2050 target is simply a matter of political will. As with all political descriptions, the components of this narrative are overly simplified and conflicting information is ignored or disparaged. This post discusses the heat pump “solution” to home heating.
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 submitted comments on the Climate Act implementation plan and have written over 250 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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 outline how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric gride with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council is required to finalize the Scoping Plan by the end of the 2022.
I have published a couple of recent articles about this process. I noted that the Climate Action Council treatment of stakeholder comments basically ignored anything that conflicted with the narratives of the Draft Scoping Plan so the Council lost the opportunity to correct any deficiencies. The second article pointed out that the Hochul Administration has not included responses to stakeholder comments in the process. As a result, it is not clear whether the issues raised were even considered.
The buildings sector is currently the largest source of greenhouse gas (GHG) emissions in New York State. As a result, reducing emissions from home heating is a key component of the Scoping Plan implementation framework. Heat pumps are a prominent part of the state’s residential electrification plans and its narrative that installing a heat pump is easy, cost-effective, and will provide a satisifactory level of comfort. If you are interested in more home heating background information, an article describing my interview with Susan Arbetter at Capital Tonight gave an overview of heat pump technology and described building shells. In the energy efficiency world, building shells refer to the insulation, infiltration, window treatments and ventilation components of the building.
Political narratives over-simplify their solutions and this is a major flaw in the heat pump story preached in the Scoping Plan and by its acolytes. Last summer I did an article about heat pump technology that concluded that it can work in New York State. However, I showed that it is not simply a matter of swapping out a fossil-fired furnace for a heat pump. The potential for the conversion to be done improperly is high because there are numerous complications. Based on a discussion with an expert HVAC technician I now understand that it is not just the furnace but the whole heating system and building shell that needs revisions too. The air infiltration, inflow, interior duct, and exhaust requirements are much higher priorities than I realized. Some of these issues are mentioned by the Hochul Administration in the Scoping Plan and the public education indoctrination public service advertising but the implications on heat performance are ignored.
This article addresses one detail of the residential home heating challenge that I believe did not receive proper emphasis in the Draft Scoping Plan. It is based on comments that I submitted that to this point have not been acknowledged. The Council has recently repeated its promise that comments will be acknowledged but has not clarified what that means. In particular, I am going to discuss the New York regional differences in climate presentation at the November 21, 2022 Climate Action Council meeting.
Council Presentation New York Regional Differences in Climate
During the buildings discussion of the staff response to Climate Action Council comments two slides were included. The discussion of the first slide explained the importance of cold temperatures for heat pump performance. Apparently, the Council asked why three regions were called out in the Draft Scoping Plan text as the coldest regions of the state. The presentation noted that the Draft said that the North Country, Mohawk Valley, and Capital regions are the coldest and went to say that heating systems there are designed to keep buildings warm even when temperatures fall below zero Fahrenheit.
The Hochul Administration narrative is that “These cold climate air source heat pumps do work well in New York’s climate” and this point was explicitly included in the presentation. The presentation mentioned the appropriate qualifiers shown in the figure that equipment quality, proper design and installation, envelope efficiency, and the temperature difference between indoors and outdoors also impact performance.
The presentation explained that Northeast Energy Efficiency Partnerships (NEEP) maintains a specification and product list that identifies specific air source heat pumps that work during extreme cold weather. The presentation noted that “in very cold conditions the heating capacity, or output from the heat pump efficiency drops.” The explanation noted that the NEEP list includes equipment that report the heating capacity at 5o F and meets or exceed a specified efficiency at that temperature.
The discussion of the regional differences in temperature claimed that in southern and coastal regions and along the Great Lakes the minimum winter temperatures stay above 5o F. The map on the preceding figure was used to show this visually. The implication was that as long as you use an air source heat pump from the NEEP product list that meets the 5o F criterion that you are good to go.
The next slide includes a table with 99% design values for heating capacity calculations. This is the outdoor temperature that a location stays above 99% of the hours in a year, based on a 30-year average. The presentation claimed that the North Country, Mohawk Valley, and Capital regions had the lowest heating design temperatures so that was the basis for their being listed in the text as the coldest regions.
Caiazza Comments on Residential Heating Electrification
My residential heating electrification comments on the Draft Scoping Plan noted that home electrification is a primary concern for New Yorkers given the importance of affordability and the impact to every household. The Draft Scoping Plan considers two aspects of residential heating electrification in Appendix G: Integration Analysis Technical Supplement. The first aspect is conversion of furnaces.The second aspect is the energy efficiency and building shell improvements necessary. In order to determine which technologies are needed for a particular location, the regional differences in climate within New York State must be considered. The Appendix G documentation includes NYSERDA climate zone categories for each county. As far as I can tell, these climate zones use the International Energy Conservation Code. As shown below there are only three climate zones and they are similar but not the same as the normal minimum January temperature map in the presentation described ablove.
Figure 1: New York State Climate Zones in the Integration Analysis
My written comments argued that there is a better, more detailed climate zone map for building shell upgrade estimates. The United States Department of Agriculture plant hardiness map has nine zones for New York (Figure 2). It uses the average annual extreme minimum temperature for its classification that I believe that is a better indicator for building shells when using heat pumps. Notably there are prominent differences that I believe make a more refined classification system appropriate. In my comments I argued that the average minimum is above zero for only two of the nine zones, corresponding roughly to Integration Analysis climate zone 3. I categorized this as zone 4. For the most part it appears that New York Climate zone 5 should correspond to NYSDA zones 6a and 6b. As a result, I limited zone 5 to the lower Hudson Valley and counties along the Great Lakes. I categorized all the counties in the Mid- and Upper Hudson Valley as zone 6 as well the counties along the Pennsylvania border except Chautauqua County along Lake Erie. If the average annual extreme minimum temperature is less than equal to -10oF (USFDA zones 3b, 4a, 4b, 6a, and 6b) then I believe another climate zone should be included. I categorized Allegheny and Cattaraugus counties as well as counties in the Adirondacks as climate zone 7 to meet this criterion.
Figure 2: USDA Plant Hardiness Map
My comments used this more refined climate zone categorization and found that the building shell categorization used in the Draft Scoping Plan underestimates the level of building shell upgrades needed for effective air source heat pump installations. The Draft Scoping Plan claims only 26% of New York residences need deep shell upgrades. I estimate that more than half will need to have deep shell upgrades. Consequently, the Integration Analysis cost estimates for electrifying residences significantly underestimates the costs and the ease of implementation for air source heat pumps.
Discussion
There has been no acknowledgement that my comments were made known to the Climate Action Council and certainly no indication that the Council considered them in their comments to the Agency Staff who are responsible for the final draft of the Scoping Plan. Nonetheless, there is a link between the response to the cold region question in the presentation at the November 21, 2022 meeting and my comments. My comment that a different approach (such as Figure 2) to define the appropriate heating technology requirements than the climate zones shown in Figure 1 was inadvertently confirmed by this presentation. In the presentation they showed a different graphic to describe the climatic differences and referenced an even better metric – the 99% design values.
I believe that a comparison of a map of the 99% design values and the plant hardiness zone map would show much better agreement than the NYSERDA climate map does to the 99% design values. I do not believe that the Integration Analysis did not used the 99% design values when they estimated the cold-climate air source heat pump requirements or the appropriate building shell upgrades necessary to make air source heat pumps effective in New York’s climate. I found that a better metric nearly doubled the number of residences that would have to be upgraded to a better building shell standard. The presentation did not mention the relevant issue that I brought up in my comments.
The Hochul Administration narrative is that cold climate air source heat pumps work well in New York’s climate and that is true but with a whole host of caveats that make a difference. Cold climate air source heat pumps all have a drop off in performance if the outside temperature gets cold enough. If the only consideration was the quality of the heat pump, then I believe the overarching issue would be the acceptability criterion. If the heat pump works acceptably 99% of the time that means there still are 87 hours a year when they will not provide sufficient heat. It would be useful to the public if the differences between the 99% design values and the plant hardiness zone maps were explained because the county-wide 99% design value may not be appropriate everywhere in the county. The greatest flaw in the Scoping Plan narratives is that “what if” questions are not addressed like what will happen when heat pumps are improperly installed and there isn’t sufficient heat.
Another aspect of political narratives is over-simplification. The presentation did include the appropriate qualifiers explaining that in addition to the heat pump other factors, like proper design and installation; appropriate specification of the design value; and envelope efficiency must be considered. The impact of these considerations and any related stakeholder comments was not discussed. In my opinion this furthers the incorrect impression that simply installing in a cold-climate air source heat pump is easy and effective.
Conclusion
The November 21, 2022 Climate Action Council meeting discussion of the cold regions of New York exposed several flaws in the Hochul Administration’s Draft Scoping Plan revision process. In response to the question about the cold regions a different description of the New York cold temperature climatology was used than what was in the Integration Analysis documentation. My comments on the Draft Scoping Plan argued that the Integration Analysis cold regions were not detailed enough and the choice of a different document supports that. In my opinion the heating 99% heating design values are an even better indicator of cold regions in New York.
I believe that a comparison of a map of 99% design values and the plant hardiness zone map I porposed would show much better agreement than the NYSERDA climate map does to the 99% design values. The important point is that the Integration Analysis did not use the 99% design values when they estimated the appropriate building shell upgrades necessary to make air source heat pumps effective in New York’s climate. I found that a better metric nearly doubled the number of residences that would have to be upgraded to a better building shell standard. The presentation did not mention the relevant issue that I brought up in my comments.
I conclude that the residential home heating plan proposed in the Scoping Plan under-estimates the degree of difficulty of this transition. The political narrative suggests that residential heating electrification is mostly just about installing heat pumps. However, proper design and installation, envelope efficiency, and the temperature difference between indoors and outdoors impact performance as much as the installation of a high-quality heat pump. The State is doing a disservice to the residents by not clearly acknowledging the complications for an adequate electric heat source. Finally, they have yet to propose a plan when heating is electrified and an ice storm knocks off power for days in the winter. It is very disappointing that my comments in this regard have been ignored.
Pragmatic Environmentalist of New York 
