Category: Climate Act Implementation Components

For over three years one of my particular concerns associated with the New York State Climate Leadership & Community Protection Act (Climate Act) net zero transition is residential electrification with an emphasis on home heating.  I have been meaning to do an update on this topic but have had other priorities.  Empire Center fellow James Hanley has prepared a new study that provides a great update: Cold Reality: The Cost and Challenge of Compulsory Home Electrification in New York (“Cold Reality”).  This post summarizes the study and my impressions of the analysis.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant cumulative environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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 develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, utility rate cases, and legislation. 

I have written extensively about residential home heating strategies in the Scoping Plan. In Climate Act Draft Scoping Plan Building Sector Scenarios I compared the Draft Scoping Plan residential heating scenarios and concluded a feasibility study is needed to determine whether any of the recommendations can be implemented.  I submitted comments on the costs of residential heating electrification in the Draft Scoping Plan.  My comments showed that the Plan did not provide sufficient information to assess the potential costs of the electrification strategies proposed.  One of the key factors affecting cost and feasibility is the need to upgrade the building shell to ensure comfort during the coldest weather when using heat pumps.  I also did a post that documented the results of my home energy audit that consolidated all my concerns with heat pumps.  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.  Like every other aspect of the Climate Act transition heating electrification is more complex and costly than the Scoping Plan admits.

NY’s Electric-Heat Push Faces Cold Reality

James Hanley’s Cold Reality is described as follows:

New York’s plan to steer homeowners and landlords toward electric heat could backfire due to high costs and practical concerns, according to a new study from the Empire Center for Public Policy.  

In Cold Reality: The Cost and Challenge of Compulsory Home Electrification in New York, Empire Center fellow James Hanley looks at the state’s plan to prohibit homeowners from replacing gas and oil furnaces after 2029 and for them to instead install heat pumps. Homeowners, he explains, face both higher equipment costs and potentially high weatherization costs to accommodate heat pumps, which can operate at lower monthly costs but require better insulation. 

Even with extensive state and federal subsidies, Hanley warns, the upfront price-tag of heat pumps and weatherization will likely push homeowners to instead buy low-cost but energy-hungry electric furnaces that will put considerably greater stress on the electric grid—making the state’s overall electrification goals harder to reach. 

“This is the fundamental problem at the heart of New York’s command-and-control attempt to restructure its economy to make what amount to barely detectable reductions in global emissions,” said Hanley. “Albany can ban things, but it can’t control how people replace them.”  

Hanley notes that the impact of this policy will be felt most in rural New York, where the median household income of owner-occupied homes is the lowest, and points out that the state could instead reduce emissions by setting clean fuel standards that encourage the use of biofuels. 

Annotated Executive Summary

I n this section I quote the Executive Summary and offer my comments.

The Scoping Plan recommends that the State pass legislation that prohibits fuel-fired home heating but has not addressed all the consequences:

In 2030, New York may begin a policy of forcing New York families to use electricity for home heating instead of fuels like heating oil, propane and natural gas. Homeowners whose furnaces fail in midwinter will face a choice between spending tens of thousands of dollars on heat pumps while waiting for weeks or more to have their homes weatherized or buying inexpensive but energy-hungry electric furnaces. Their choices have significant implications for household budgets, utility companies providing electricity, and policymakers who need to ensure a sufficient amount of electricity production to meet the public’s needs.

Hanley does a good job explaining some of the nuances to the electrification that are not addressed in the Scoping Plan.  For example, he points out that if a furnace breaks down in the winter, that there are limited options for replacement.  You might be able put in a replacement heat pump quickly but the insulation and weatherization required to make heat pumps work in the coldest weather take longer to install. 

The Climate Act is a political construct.  The goals set were never evaluated with respect to feasibility.  The Climate Action Council did not address the consequences of the schedule proposed:

New York’s 2019 Climate Leadership and Community Protection Act (CLCPA) calls for reducing statewide greenhouse gas emissions by 85 percent by 2050 (from a 1990 baseline). The Climate Action Council has proposed meeting that goal in part by electrifying 85 percent of the state’s buildings. But it also has recommended a prohibition on the replacement of fuel-burning furnaces as of 2030, which would push the mandate closer to 100 percent electrification as units reach their normal end of life.

Hanley breaks down residential building energy production:

Over six million residential units in New York use fuels for heating, with over five million also using them for hot-water heating, and over four million using them for cooking. While most of those homes use natural gas, more than 1.7 million New Yorkers use propane, heating oil or kerosene1 for heat, with over a million using those fuels for hot water as well.

The Scoping Plan did not address these differences.  There are reasons that each fuel is being used and there are ramifications that may make a one size fits all electrification mandate problematic.  The analysis addresses some of the complications of the electrification mandate.  While the Scoping Plan admits that there should be exceptions to the mandate, it is not clear how those would be incorporated.  As Hanley points out, heat pumps have issues:

The state’s compulsory electrification program— forcing consumers to replace end-of-life fuel-fired appliances with electric appliances—recommends that building owners, including homeowners, install heat pumps. Because heat pumps do not warm the air as much as fuel-fired furnaces, heat pump installation involves additional costs for home weatherization. In cold climate regions, air-source heat pump users may also need to pay for a supplemental heat source, and due to the risk of power outages, risk-averse electric heat users may also need to purchase backup power generators.

Cold Reality does a good job in the report explaining how the plan will disproportionately affect the rural poor.  He describes other issues as well:

The costs of heat pump installation and building shell weatherization are high and will place a substantial economic burden on many homeowners, even with state and federal subsidies, as shown by the following numbers:

• The cost of installing a heat pump and weatherizing a home: $14,600 – $46,200;
• Heat pump and weatherization’s share of the median household income of owner-occupied homes in lower-income counties: 20 percent to 70 percent; and
• How long it will take homeowners to recover costs through energy savings: 8 years to 19 years.

The Climate Act Scoping Plan emphasizes the climate justice aspect of implementation by focusing on Disadvantaged Communities.  I worry that emphasis will overlook the rural poor who will be disproportionately impacted by the electrification of heating costs described because rural poor may not be in a Disadvantaged Community.  If there is no hope that the electrification costs can be recovered by energy savings, then this is a serious problem.  Hanley points out that there are ramifications on the implementation strategy too:

State policy will likely drive homeowners to instead buy more energy-intensive electric resistance furnaces that have lower upfront costs but cost more to operate. Even with higher annual energy costs, it will take 18 to 60 years for total costs to equal the cost of a heat pump installation plus home weatherization.

I agree that the consequences of this choice have enormous implications:

Widespread adoption of electric resistance furnaces would further increase electricity demand, challenging utilities as they rebuild the state’s electric grid to deliver higher electric loads and policymakers as they struggle to close a sizable future gap in winter electricity production.

Whether homeowners choose heat pumps or electric resistance heaters, the future of oil and propane distribution firms appears dire. Based on their respective expected operational lives, propane furnaces may be eliminated between 2047 and 2050, while oil furnaces would be eliminated between 2056 and 2063.

One point not mentioned by Hanley is that propane is used more often for mobile homes.  Those residences cannot be insulated enough to enable the use of heat pumps so I expect that this would be another long-term use of propane in addition to those he describes:

Because there are a variety of out-of-home uses of propane, the propane industry will not completely disappear in New York, although it will dwindle and need to consolidate. With fewer alternative uses for heating oil, the heating oil delivery industry may be eliminated entirely.

Hanley correctly points out that the expected reductions in greenhouse gas emissions are inconsequential relative to global emissions.  However his description does not mention that the increase of global greenhouse gas emissions elsewhere means that the reductions will be supplanted by those increases in a matter of days:

The global effect of the costly compulsory electrification will be a reduction in greenhouse gas emissions of less than 5/100 of one percent. In choosing this approach, New York has closed the door on a more affordable means of reducing greenhouse gas emissions, clean fuel standards that promote biodiesel and renewable propane.

In that context, it is insane to not consider the affordable alternatives he describes.

Discussion

Cold Reality does an excellent job explaining issues associated with heat pumps in New York.  I want to make the point that Hanley addressed the major problems but could not address all the issues.  There are other problems that don’t have as much of an impact and are down in the weeds so far that trying to include them would detract from the report.

My post that documented the results of my home energy audit with a knowledgeable and experienced auditor raised some of the other issues.  I do not dispute that heat pump technology can work in New York State.  However, it is not simply a matter of swapping out a fossil-fired furnace for a heat pump because it is not just the furnace that has to be replaced.  Hanley explained that because the temperature of the air from a heat pump is lower than a fuel-fired furnace, the building shell needs to be upgraded to improve insulation and reduce air infiltration.  He did not point out that it may be necessary to change the duct work because a greater volume of air is needed to provide the necessary heat and that a heat exchanger might have to be added too.  Hanley described the trained tradesmen problem but I think it is not just a matter of installation workers it is also a matter of designers.  There simply will not be enough trained and experienced auditor/designers available because of the learning curve.  As a result, I fear many heat pump systems will not be designed properly.  That will exacerbate the load problems described in Cold Reality because the solution will be to add space heaters to stay warm.

Conclusion

There are many components of the Climate Act transition but very few will have as big an impact on individuals as the home heating electrification mandate.  Hanley’s Cold Reality is a great overview of the problems associated with the heat pump “solution” that have not been addressed by the Hochul Administration. He offers a solution to reduce impacts that I think makes sense.

In my opinion, however, there are even more problems than the problems Hanley describes in his conclusion:

New York’s proposed program of compulsory electrification could impose enormous costs on homeowners while making nearly unmeasurable gains in reducing global greenhouse gas emissions. As of 2030, homeowners will be faced with the choice of committing up to 70 percent of their annual incomes toward the purchase of heat pumps and upgrading their home’s shells or buying electric resistance heaters at just 3 percent to 10 percent of that cost.

The low rate of electric heating in many of the state’s more rural and lower-income counties means much of the choice will fall on homeowners who can least afford it.

And those who have unexpected equipment failures in midwinter may not be able to arrange contractors for their necessary shell upgrades in time to ensure comfort for the remainder of the season.

While the state’s Climate Action Council recommends heat pumps because they use less energy, the cost advantage of electric resistance heaters could lead to large numbers of homeowners choosing them.  This would increase the energy demands of the state beyond what has been predicted, challenging utilities as they rebuild the grid to deliver higher electric loads and challenging policymakers to close a predicted, and potentially growing, shortfall in future wintertime electricity production.

I live in the Upstate New York National Grid service territory and recently received a notice that Smart Meters are coming.  Because I am aware of issues associated with this technology, I decided to research what this is all about.  My particular concern is that it could enable involuntary demand response capabilities associated with the New York State’s Climate Leadership & Community Protection Act (Climate Act) net zero transition.

Cutting to the chase: I have decided to let them install the smart meter in my home.  The costs to opt-out of them is greater than the risks that they will be used to potentially control my energy use someday in the future. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant cumulative environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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 develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, utility rate cases, and legislation. 

The Scoping Plan is more of a list of potential strategies than an implementation plan because it does not provide a blueprint of the steps needed to implement the strategies proposed to meet the reduction targets.  The building sector currently has the highest Greenhouse Gas (GHG) emissions.  The strategies proposed to reduce greenhouse gas emissions include electrification, energy efficiency, energy conservation, and demand response shifts.  According to the Department of Energy: “Demand response provides an opportunity for consumers to play a significant role in the operation of the electric grid by reducing or shifting their electricity usage during peak periods in response to time-based rates or other forms of financial incentives”.   The Scoping Plan suggests using this as a resource option for balancing supply and demand.  I have no problem with voluntary demand response programs but given the challenge of balancing supply and demand when electric generation is weather-dependent, I worry that these programs could get to the point that the utility can control my energy use without my permission.

What is Happening? 

National Grid’s Upstate New York Rate Case Settlement Agreement (Cases 20-E-0380 and 20-G-381) included rate increases that “reflect incremental IT-related capital investments” for Advanced Metering Infrastructure (AMI).  The discussion in the Order Authorizing Implementation of Advanced Metering Infrastructure With Modifications that was issued on November 20, 2020 describes the rationale for AMI, aka smart meters (modified to label acronyms):

With Advanced Metering Infrastructure (AMI), National Grid can improve its response to power outages, as the Company will have more accurate and granular information regarding the voltage and current status of customers’ services. AMI can empower customers by providing them with information about their energy usage and allowing them to take action to manage their electric and gas costs. The AMI meter and communication system can be used to enhance the safety of the electric and gas system by allowing National Grid to remotely monitor facilities and receive alerts when abnormal conditions are detected. Moreover, AMI is an important and valuable contribution to enabling the Company to assume the role of the Distributed System Platform (DSP), to increasing use of Distributed Energy Resources (DERs) to support system operation, to increasing the use of measures such as Volt-Var Optimization (VVO) to reduce energy use and emissions, and to facilitating customer access to products and services provided by third-parties.

The first major benefit category is Avoided Operation and Maintenance (O&M) Costs, estimated at $188 million. This includes operational savings from remote customer connects and disconnects, better storm response with the integration of Outage Management Systems (OMS) and AMI, reduced meter reading costs, and reduced meter investigation costs.

The second major benefit category is Avoided Program Costs, estimated at $354 million. This includes avoided costs of replacing automated meter reading (AMR) meters, avoiding additional sensors to support the DSP, and metering for customers eligible for Value of Distributed Energy Resources (VDER) according to the Company’s tariff.

The third major benefit category is Customer Benefits, estimated at $251 million for the time varying pricing (TVP) rate opt-out scenario and $165 million for the TVP rate opt-in scenario. This includes reduced energy from Volt-Var Optimization (VVO); customer response to granular energy usage information communicated via the Company’s website and through high-usage alerts, and to the TVP rate; and reduced demand costs for customers who charge electric vehicles during off-peak periods.

Proponents of the electric grid transition away from centralized power plants burning fossil fuels argue that it is more efficient to use on-site energy production using wind and solar.  The idea to use Distributed Energy Resources (DER) in the electric system has been around for a while but so far, the generators primarily use fossil fuels.  In the future, the theory says DER and the Distributed System Platform (DSP) described will accommodate intermittent wind and solar resources in the so-called “smart grid”.  Volt/VAR optimization (VVO) is another aspect of the smart grid.  It is a process of optimally managing voltage levels and reactive power to achieve more efficient gird operation by reducing system losses, peak demand, or energy consumption or a combination of the three.

National Grid Voluntary Peak Demand Program

Upstate New York National Grid has voluntary programs for energy consumption incentives on high energy demand days in place today.  These programs control the thermostats at participant homes rather than controlling the meter for the house.  The Connected Solutions program description notes that:

Energy use peaks during certain seasons, especially on the hottest and coldest days of the year.  When you cool your home or small business using electricity during summer or keep it warm using natural gas in winter, Connected Solutions will reward you for using less energy during those peak times. 

When you use less energy on peak demand days you help manage the cost of energy, protect the environment and infrastructure, and you help our communities stay safe and comfortable.

In Upstate New York there are programs for the summer and winter.  The summer description states:

On hot summer days, when the grid is stressed, it is important to conserve energy. Reducing energy at these times reduces energy costs and decreases pollution.

National Grid has made it easy for you to conserve energy at these peak times. After you enroll your qualified thermostat, National Grid will automatically send a signal to your thermostat to precool your home or small business before the peak event and increase your thermostat setting during the peak event.

Here is some information on when peak events may occur:

• May-September
• Non-holidays
• There are typically 10 – 15 peak events every summer.

The winter description states:

On extremely cold days, when the demand for natural gas is at its highest in Upstate New York, it is important to conserve energy. Reducing your natural gas use at these times reduces energy costs. By shifting your energy use for a couple of hours during peak demand days you can help lower the stress on our system, save money and ensure our communities are safe and comfortable.

Connected Solutions Gas has made it easy for you to conserve energy during these times and will reward you for your participation. After you enroll a qualified, wi-fi enabled thermostat connected to your boiler or furnace, we will automatically send it a signal to preheat your home or small business before the peak event times and then temporarily decrease the temperature by a couple of degrees for the duration of the event. After the event has passed, your thermostat will automatically go back to your preferred temperature.

Here is some information on when peak events may occur:

• November-March on days when temperatures drop well below average
• 6 a.m. to 10 a.m. or 4 p.m. to 8 p.m.
• There are typically 2 – 5 peak events every winter.

It is possible to opt out of a peak event anytime by changing your thermostat setting for both programs.  However, if you opt out of peak events National Grid may unenroll participants from the program for the following year.

National Grid Smart Meters

Against this backdrop I was interested when National Grid recently sent a bill insert, Smart meters are coming soon, that describes what is coming.  The information provided states:

• MORE CUSTOMER CONTROL: continuous, secure access to your energy data—for more insight into your energy efficiency and usage decisions.  
• FASTER, NEAR REAL-TIME ENERGY READINGS: available within minutes, through your My Account portal.
• FASTER RESPONSE: enhanced outage monitoring and storm response.
• AND MORE FEATURES — still to come

It’s all part of our ongoing commitment to empower customers—while working to build a more reliable, robust and climate-friendly energy grid for the future. Learn about your new smart meter at ngrid.com/smartmeter.

This webpage describes the rollout:

Like any aging appliance, your existing utility meter will need to be replaced soon. We are in the process of replacing current meters with smart meters in many of the regions we serve.

These smart meters incorporate proven, sophisticated technology which will improve service and reliability, while also giving you more control over your energy usage, faster, near real-time energy readings and an overall faster response. Smart meters are part of our ongoing commitment to empower our customers while working to build a more reliable, robust, and climate-friendly energy grid for the future.

One of the things that really isn’t explained clearly is that the smart meters will be installed unless the customer opts out.  There is a link to opt-out of a smart meter buried in the National Grid web page.  However, there are fees if a customer chooses to opt-out.  The enrollment fee is $44.63 for an electric customer, $61.19 for a gas customer or $89.03 for both.  The monthly fee for manual meter reads is $11.64 for electric or gas customers or $17.71 for both.

Concerns

If the only purpose of the smart meters was to automatically read my meters I would not be concerned.  However, I know that the challenge to reduce building sector emissions is so great that I worry that I will be involuntarily affected by the smart meters.

The description of smart meters claims that the smart meters will determine whether an outage is caused by the system or something within a home.  If it is a system outage, then National Grid will be informed quickly. 

The meters will provide hourly usage data.  I think it is inevitable that utility bills will be based on the time of the day rates with higher prices during peak demand times.  I can choose to save money by running my appliances when rates are lower.  As long as I get to choose when I can run my appliances, I can begrudgingly live with that.

It is not clear to me how the planned smart meters installations affect the Distributed System Platform and the Volt/VAR optimization benefits described above.  I do not know if my smart meter will be used to involuntarily control my energy consumption.  All the information provided so far indicates that there is no plan to do that yet.

However, I wondered whether the proposed smart meters had the capability to do that in the future.  I thought I would try to find out if that was the case.  I called National Grid and asked if the meters being installed could be used for involuntary demand response now or could be upgraded to do that later.  Once I got through to a human I was told “I don’t think so”.  I asked if I could talk to the folks doing the installations.  It turns out that National Grid has partnered with Utility Partners of America to do the installations. 

I ended up submitting the question to Utility Partners of America.  I asked “Can National Grid control my energy usage with this new smart meter?”  I received the following response: 

No, the smart meter will not give National Grid access to control your energy usage. We collect the same usage data we have always collected through existing meters just in more frequent intervals. However, National Grid does have Demand Response programs available for customers and while participation in those programs is voluntary, signed consent is required by the customer.

Conclusion

In brief, National Grid is installing smart meters to eliminate manual meter reading and automate outage reporting.  It will also provide more detailed energy use information that will enable them to start time varying pricing which will mean higher costs if you want to run appliances at peak energy use times.  There are other alleged technical advantages associated with the Climate Act transition plan.

My major concern was that they could involuntarily control my energy use.  I accept that this is not part of the current plan.  Everyone denies this could be possible with these meters.  However, I remain unconvinced that someday down the road, that such a program could be implemented. 

I have decided to let them install the smart meter in my home.  The costs to opt-out of them is greater than the risks that they will be used to potentially control my energy use someday in the future. 

The New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  Implementation of the Climate Leadership & Community Protection Act (Climate Act) started soon after the law was passed at the end of 2019.  It was recognized early that “as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid”.  I recently summarized the proceeding and my comments.  This post summarizes the comments by Richard Ellenbogen that I think describe the overarching problems of the Climate Act.

I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition.  I have extensive experience with meteorological aspects of electric generation because I have worked in the sector as a meteorologist for over four decades.  I have devoted a lot of time to the Climate Act and the issues raised in this proceeding 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.  I represent the Environmental Energy Alliance of New York on the New York State Reliability Council Extreme Weather Working Group.  The opinions expressed in this article do not reflect the position of the Alliance, the Reliability Council, the Extreme Weather Working Group, 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 established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines 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 grid 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.  After a year-long review the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.  The zero emissions analysis is part of that effort.

Ellenbogen Background

I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he knows how to protect the environment while running a business.   At the Business Council of New York 2023 Renewable Energy Conference Energy he [BIO] gave the keynote address (presentation and video) –  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems.”  which I summarized here.  His comment submittal includes more background information.

Comments

Ellenbogen’s comments are available on the DPS DMM website.  Many of the points in the Business Council keynote presentation were incorporated into his comments.

His introduction notes:

While Mr. Ellenbogen is in favor of the decarbonization identified in the CLCPA, the way that the policy is structured cannot possibly work and it is going to cost the state hundreds of billions of dollars, while not reducing atmospheric carbon, and worse yet, it precludes methods of reducing carbon emissions that actually will work much more rapidly based upon the physics of how utility systems actually operate.

Issues Raised in the Comments

He goes on to describe five issues related to Climate Act bet-zero transition:

1. There is a lack of available energy to support the Plan
2. Costs to implement the Plan will far exceed other, better solutions

These costs accrue based upon shortages of materials and skilled labor, high energy storage costs, and a lack of financial adequacy

3. Atmospheric Carbon Levels will rise far above what could be achieved using other alternatives
4. Planned timing mandates are unachievable
5. There are major non sequitur issues contained within the CLCPA

He argues that the Scoping Plan does not accurately estimate the energy available from wind and solar and how much energy will be needed when the electrification proposed is in place.  His analyses, indicate that “even if all of the renewables specified in the CLCPA are installed, the state will still be over 100,000 GWh short of what is needed and there will be hundreds of hours of rolling blackouts annually.”   He also notes that renewable facility installation rate is falling behind the Scoping Plan schedule.

Ellenbogen has hands-on experience designing, building and operating a low-carbon energy system for his business.  Based on that background he believes “project costs will far exceed other, better solutions, based upon a shortage of materials, labor, and capital needed to complete Plan implementation”.  This is based on energy storage requirements, transmission upgrades, and the materials and labor needed to resolve those needs.

He points out that GHG emissions will not decrease as quickly as projected because the renewable energy/ carbon free energy resources won’t be available in time.  When other sectors of the economy are electrified that means that the additional loads will be supported by fossil fuel generation.  He points out that the demands for no new fossil fuel infrastructure means that old power plants will be kept on line longer.  He argues that building new, more efficient power plants for the decades long transition is the better solution.

The reason for this proceeding is that there is only one zero-emissions resource that fulfills most of the electric system requirements and nuclear is politically toxic.  In addition, it is unlikely that even if nuclear power were embraced it would be unlikely that the targets of the Climate Act could be met.  His discussion of schedule issues also raise a problem associated with the proposed dispatchable emissions-free resource (DEFR) included in the Scoping Plan.  As envisioned there, these resources will only be used 3% of the time:

That doesn’t work in the real world. Most generating technologies don’t lend themselves well to being dormant 97% of the time. Additionally, based upon the math, the 3% is an extremely low estimate. It would be far more cost effective to build more nuclear generation and fewer renewables. That would remove the intermittency issue and the storage cost issue documented earlier.

Finally, Ellenbogen explains that the conclusions of the Climate Act are based on fantasy.   He notes that the projected solar annual energy production from the listed capacity requires an annual capacity factor of 22% but that the state has a solar capacity factor of 13% when the arrays are new.  As a result, the calculated solar output is overestimated by 72% or 51,000 GWh. Using the correct solar capacity factor results in only 70,768 GWh of solar output in 2050, 51,000 GWh less. Combined with his estimate that the amount of energy needed is going to be 120,000 GWh more than the 2050 Scoping Plan projections is the reason he believes “that we can expect hundreds of hours of rolling blackouts every year if the Climate Act is executed as planned. “

Viable Alternatives in the Comments

Ellenbogen argues that natural gas-fired combined cycle power plants are a viable alternative during the transition.  They can be built relatively quickly and would replace the old more inefficient power plants that have to be kept on-line in the absence of adequate resources.  He makes a persuasive case that the huge electricity load of the proposed Micron chip fabrication plant north of Syracuse should include a combined cycle co-generation plant that would provide both electricity and heat for the facility.  He explains:

With regard to Micron Technologies, one could be built on-site that would eliminate 350 GWh of line loss while also providing Micron easy access to high temperature thermal energy. The Energy on Demand aspect of the generating plants also eliminates the need for trillions of dollars of battery storage. It is not a perfect solution, but it is a far better solution than “ideal” solutions that can’t be executed because of the previously documented issues. As hydrogen technologies are perfected and a sufficient supply of hydrogen is developed, hydrogen injection technologies can help to further reduce the GHG emissions of the plants.

Overview Conclusion

He concludes:

The prior analysis is based upon facts, math, and physics, not opinions or wishful thinking.. The issues don’t require an understanding of calculus. They just require an open mind and a knowledge of arithmetic. People can’t only say, “Follow the science” when it tells them what they want to hear. Any engineer knows that science, math, and reality can screw up the best plans.

Einstein defined “Insanity” as repeating the same thing over and over again and expecting different results. Why is NY State repeating Germany’s failed renewable experiment that hasn’t worked in 33 years and expecting it to work in seven years or seventeen years. The results in NY State are going to be just as bad as they have been in Germany. However, time is now an issue and significant GHG reductions need to be achieved quickly. The CLCPA in New York State will not be any more successful than Germany policy has been in their efforts to combat climate change.

NY State is currently in the CLCPA, mandating a non-functional utility system which will be plagued by greater fossil fuel use, higher carbon emissions, energy failures, and stability issues that will result in deaths, and a mass exodus of people and businesses that will destroy the tax base and with it, the state economy.

Response to Questions

The zero-emissions proceeding request for comments included 14 questions.  He did not respond to specific questions  Instead, I quote his response “Regarding Answers to Some of the 14 Questions”:

“How should zero be defined?” Zero is zero. If they meant otherwise, they should have used the word “low”. Carbon offset projects still have to be distinguished from true zero emission technologies such as solar, wind, and nuclear. If the state wants to offer credits to a process that offsets carbon for accounting purposes, that’s fine but don’t call it zero. It should be in a separate “offset” category.

Regarding Carbon Capture, many of the technologies cool the exhaust to separate the CO2 as a liquid and either use it in other materials or pump it underground in a deep well to sequester it. While that will greatly reduce atmospheric CO2, it will greatly increase energy use. That energy has to be accounted for. Where is it going to come from?

Regarding “Green Hydrogen”, hydrogen electrolysis should not qualify. There is going to be an enormous shortage of electrical energy to support the utility system, even if all of the renewables are magically installed. A recent study done in Australia found that if all of their current proposals to produce green hydrogen by electrolysis were implemented, the total energy required would exceed all of Australia’s generating capacity. The math will be no different in NY State. A better solution would be to generate hydrogen by investing in a thermo-chemical process using the waste heat of the nuclear plants to power or by using the NYSERDA Biomass Power Guide qualifying waste to energy plants to generate the hydrogen.

Pragmatic Environmentalist Conclusion

I highly recommend reading his comments.  Ellenbogen offers alternatives that would be cheaper, will reduce GHG emissions in the short term, and are technologies that will actually “work much more rapidly based upon the physics of how utility systems actually operate.”  Alas he argues that going to zero is not appropriate.  The ideologues on the Climate Action Council who shaped the Scoping Plan demand perfection but do not seem to comprehend that the real world makes that impossible.

I don’t think the ideologues understand the risk to their goals.  The proposed Scoping Plan cannot work as written and will cost enormous amounts of money.  There is no indication that proponents understand the risks to reliable energy inherent in the Scoping Plan and that poor energy policy will cause greater health and economic damage than climate change.  When these problems get to the point that they cannot be denied, I believe it is likely that public backlash will be so strong that there will be no appetite for any of the idealistic dogma in the Scoping Plan energy policy.  Moreover, even the alternatives proposed by Ellenbogen will be off the table for future energy policy. 

Richard Ellenbogen frequently copies me on emails that address various issues associated with New York’s Climate Leadership and Community Protection Act (Climate Act).  I asked his permission to present his analysis describing the incorrect and hidden costs associated with installing induction ranges for residential cooking.

I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk.   Ellenbogen is the President of Allied Converters  that manufactures food packaging.  His facility is about 55,000 square feet and does a lot of manufacturing with heat to seal the bags, all electrically driven.  The facility has solar panels and uses co-generation.  He explains:

In 2008, the average energy cost per square foot for a commercial facility in  Westchester was $1.80.  We were at 33% of that 12 years later and even with the increases, we are at 62% of that 14 years later.  That has been done while having a carbon footprint 30% – 40% lower than the utility system.  The $1.80 per foot  also included commercial office space and our operation is far more energy intensive than an office.  We use energy extremely efficiently and as a result, our bills are much lower than everyone else. 

Induction Cooktops

The impetus for his analysis was an article was in the NY Times entitled How to Buy the Best Induction Cooktop.   Richard’s evaluation addresses the costs in detail.  The following is his text.

Nowhere does it mention the hidden costs of conversion and with one exception, the cooktops all over $1000 before tax.  Also, those are just cooktops with no oven.  Complete cooktops  and ovens can cost $2500 or more.  You have to click on one of the links in the article to find  information about the conversion costs and the link does not go into great detail about those costs.  It just says that you will have to call an electrician.

The apartment building where my daughter lives in New York City was built in 2003, so it is a new building by City standards.  As a reference, I just replaced the gas stove in her apartment last week.  It cost $1150 including tax, delivery, and installation.  It also included an oven.  A gas detector is available from Amazon for about $25 for anyone concerned about methane emissions.

Below are two photos of her breaker panel.  An induction range needs a 2 pole 50 amp circuit breaker.  As you can see from the photos, the capacity of the panel is 125 amps but it is already fully populated with 2 air conditioners and other appliances on the panel.  While breakers could be rearranged to fit a breaker for the induction range, the panel would be operating at or above its capacity.  There is no extra capacity on the panel to support the induction range.  Installation would require new, higher capacity lines from the basement of the building plus a new breaker panel with a capacity of about 200 amps.

That also doesn’t explain where the manpower will come from to install all of these cook tops/induction ranges when there is a shortage of electricians.

You can add about $2000 for the new breaker panel and the new circuit for the stove, plus painting and patching to fix the holes that the electrician will leave behind.  You can also add $300 – $400 for new pots that will work with your range.  Running a new service from the basement to support the larger panel would add an additional $2000 – $4000 per apartment that would have to be covered by the building management and would end up reflected in higher common charges.  This is all to replace a device that is used about 2 hours per day.  In older buildings, the costs would likely be higher.  It doesn’t take long to reach $8000 in costs, or about eight times what just replacing the gas range would cost using far less labor.

At least 60% of the state lives in even older housing stock that would have similar issues.  Con Ed is having difficulty just supporting air conditioning in many older buildings because their electrical services date to the 1940’s – 1950’s or earlier and the electrical services weren’t sized for that, let alone adding hundreds of induction ranges to these buildings.

There are so many other issues of a far larger magnitude that need to be dealt with prior to incurring the expenses of building electrification that will yield relatively little, if any, improvement in GHG emissions.

However, the media doesn’t want to delve deeply into the downsides for fear of angering their readers.  It’s far easier to paint a rosy picture of induction ranges saving the world and keeping Greenland from melting.

And for those that say that gas stoves cause childhood asthma, there is a slide from my upcoming PowerPoint copied below.

Old gas stoves should be replaced, but we don’t need to spend an extra  $72 billion doing it.

Closing Remarks

This is another very good evaluation by Ellenbogen.  His analysis addresses a topic that I did not evaluate but it reinforces my disappointment that the Scoping Plan did not offer adequate documentation to verify their prediction.  Every check on the Integration Analysis numbers that form the basis of the Scoping Plan shows that problems.  I found no suggestion that the wiring issues raised by Ellenbogen have been included in the Scoping Plan.  Comparison of their unit costs of cooking equipment with what is on the market today shows huge differences.  The exclusion of ovens from the cooking costs is biases the estimates low. 

I did have one concern about the analysis and after discussion with him there is another overlooked issue.   I checked the Integration Analysis input assumptions spreadsheet to check Ellenbogen’s estimate of total costs using the data in the following table. 

I multiplied the number of cooking appliances by the documented unit costs and found that the cost to convert all fossil-fired cooking appliances to induction stoves using the 2023 unit cost is $1.9 billion and increases to $3.2 billion if electric resistance stoves have to be converted too.  The Integration Analysis unit costs are bogus because they don’t include ovens and are laughably low compared to today’s prices.  Assuming more realistic $2500 for a induction cooktop and oven, $735 for electric resistance, and $1,175 for natural gas range and oven, the cost difference to replace the gas and LPG equipment with the induction alternative is $6.1 billion and increases to $12 billion if the electric resistance stoves have to be converted too.  That does not address the hidden cost of the electric service upgrades.  Ellenbogen estimates that cost is around $8,000.  I think that is high overall so I assumed that all the natural gas and LPG homes would have to get upgraded electric service for the cooking equipment at $4,000.  That kicks the total conversion costs to $23.8 billion.  If the electric resistance stoves have to get upgraded to more efficient induction equipment and no electric service upgrades are required that brings the total to $29.7 billion.  That is less than his estimate but still a huge number compared to any estimate using the Integration Analysis. 

Residential Cooking Stocks and Costs in Integration Analysis

IA-Tech-Supplement-Annex-1-Input-Assumptions Tabs Bldg_Res Stock and Bldg_Res Device Cost

I sent my version of this analysis to Ellenbogen for review and comment.  I was particularly interested in his thoughts about my numbers.  He responded that he had talked to his electrical contractor about the prices.  The contractor confirmed that these cost prices are valid for Westchester County and Long Island but are low for New York City.  Ellenbogen made the point to me that addressing the cost differential is necessary because New York City is 42% of the population of the state and Westchester and Long Island add another 23%.  Our work shows that in order to credibly calculate the electric service upgrades necessary for induction cooktops the Integration Analysis should have determined what was necessary for the three categories of residential housing (single family, small multi-family, and large multi-family) and included regional variations in labor costs across the state. 

Incredibly there is no sign that electric upgrade costs were included at all.  I believe that the Scoping Plan residential cooking costs that incorporate the necessary electric service upgrades are short between $30 and $72 billion.  That is a significant fraction of the alleged benefits of between $115 and $130 billion.