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 275 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 Leadership and Community Protection Act (Climate Act) established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for 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 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 revised during 2022. The Final Scoping Plan was approved on December 19, 2022. Unfortunately, the revisions only addressed the language of the draft plan and not the substance of the numbers used from the Integration Analysis.
The Post Standard published three letters to the editors related to the Knauss article. Two of the articles expressed concern about the dangers of heat pumps and the resulting lack of heat during periods when electricity blackouts occur. Hanah Ehrenreich argued that we should know better than to question the Scoping Plan.
Recent letters to the editor by Roger Caiazza and David Seeley (”Dangers and possibilities of NY’s all-electric future,” Jan. 4, 2023) argue electrification as a substitution for gas heat would intensify dangers, with the Buffalo storm as the example. If they had read Tim Knauss’ well-informed and straightforward reporting on New York’s implementation strategy for the 2019 Climate Leadership and Community Protection Act, they would know better.
Two years have been spent in a detailed implementation development process including scientists, representatives of the fossil fuel industry and utility companies, labor leaders, environmentalists, and many months of public input.
The description of the Scoping Plan as a detailed implementation development process is naïve. The Scoping Plan has been described as a “true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.” I suspect that because all these experts worked for two years and there was public input, then the public perception is that means the Scoping Plan included a feasibility analysis. The fact is that the plan did not determine whether all the aspects could work as proposed to maintain current standards of reliability, prevent significant risks to affordability, and would not cause significant adverse environmental impacts. Also, as I said in my letter, the state plan does not address “what if” questions.
Ehrenreich goes on to say:
Buffalo residents — old and young — died in their natural gas-heated homes. Gas heat does not operate without electricity. Those gas-heated homes that lost power were 30 degrees indoors. Meanwhile, homes in Buffalo that maintained electricity still had heat, which saved lives.
I have a couple of problems with this paragraph. The first point is that while it is true that gas heat does not operate without electricity, gas stoves can be lighted with a match providing some heat and hot food which is impossible in an all-electric home. More importantly, a fossil fueled generator can be used to provide the power necessary for gas furnaces to operate. One of the “what if” questions so far unanswered is what happens to all the people who have invested in emergency generators. Even if the State allows them in the future, where is the fuel going to come from when all other uses are outlawed? The second point is the line “homes in Buffalo that maintained electricity still had heat, which saved lives”. Home in Buffalo that had electricity could run their gas furnaces and that saved lives too. People who died in homes with gas furnaces would have died in electric homes too.
There could be another interpretation of this paragraph. My letter to the editor made the point that at some point there will always be insufficient energy for a heat pump to create heat inside a home. I think that Ehrenreich might have interpreted that to mean that I was saying that they don’t work at all. The technology has improved so that an advanced heat pump can provide heat to a lower temperature but if the temperature is below 15o F no heat pump will work well.
Ehrenreich states:
Ductless mini-split heat pumps in my 1920 home provide consistent heat (air conditioning in the summer) without the astronomical cost of retrofitting the original furnace and vents. A National Grid comparison ranked my home as high efficiency, with fall 2022 as overall lowest electricity costs.
The point that I tried to make is that the impression that replacing an existing fossil-fired furnace with a heat pump is all that needs to be done for all the weather conditions that we can expect in Upstate New York is not likely to be true. In addition to properly sizing the heat pumps and making sure the right type is purchased, there are issues with the building shell, ventilation, and the distribution system within the house that have to be addressed for a successful conversion. It might work most of the time but if it does not work all the times that a gas furnace does then there will inevitably be a crisis.
Ehrenreich says:
Meanwhile, gas heat dependency is forcing friends in the United Kingdom and Germany to cook with wood and dress indoors as if they were going skiing.
The same energy crisis that is causing problems with gas heat dependency are also affecting electricity prices which have the same effects. The gas dependency issue is ultimately a lack of supply because the United Kingdom and Germany have failed to develop their own sources of fossil fuels. Oh wait, that is exactly what New York is doing with the ban on natural gas development and I maintain that ultimately this will lead to problems that could have been avoided.
Ehrenreich concludes:
The climate is in crisis and the stunted natural gas industry is dragging homes and families into a state of emergency. New York state has stepped into the national forefront by taking essential legislative action. We need to do everything possible to welcome and speed this implementation.
New York’s greenhouse emissions are less than one half of one percent of global emissions and global emissions have been increasing by more than one half of one percent per year. The fact that anything we do to reduce emissions will be offset in a year does not mean that we should not do something but it does mean we should take the time to do it right. Folks like Ehrenreich are convinced that we have to act immediately because they have been brainwashed by the incessant propaganda from activists and the media. A Critical Examination of the Six Pillars of Climate Change Despair does a good job explaining why the rationale that there is a crisis is wrong.
Conclusion
I despair that so many people have such entrenched opinions about the problem of climate change and the alleged simple and inexpensive solution that they have closed their minds to reality. Anyone who claims to have an open mind should consider the following. Steven Koonin’s book What Climate Science Tells Us, What It Doesn’t, and Why It Matters does an excellent job critiquing the science behind the concerns about climate change but it is pretty technical so this video is a good overview. Frankly I am more concerned that New York is going down a path that requires dependency upon renewable energy because I am convinced that current renewable technology won’t work.
In 2023 the State is going to be developing regulations and proposing regulations to implement the outline of the net-zero transition described in the Scoping Plan. I encourage all New Yorkers to get involved and demand a feasibility analysis to determine whether the arbitrary greenhouse gas emissions targets in the Climate Act can be met reliably, affordably, and with acceptable environmental impacts. Before passing any legislation or endorsing a regulatory approach for any component of the Climate Act, the Hochul Administration must be held accountable for feasibility analyses and explanations how New Yorkers will survive when there is an ice storm after everything is converted to electricity. Anything less is a dangerous abrogation of the public’s right to safe and affordable energy.
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 established 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 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 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 and approved on December 19, 2022.
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 is that installing a heat pump is easy, cost-effective, and will provide a satisfactory level of comfort. The article notes that heat pumps are the most economical option to replace gas and other fossil fuels.
As has been the case for every component of the Plan that I have evaluated, there is more nuance and issues than the Climate Action Council admits. My concerns about home electrification have prompted me to submit comments on the Draft Scoping Plan, write a number of articles on home electrification (building shells, narrative, and costs), and even get interviewed about heating electrification conversions.
The New York State Energy Research & Development Authority (NYSEDA) is responsible for convincing homeowners to retrofit. Given the performance of modern fossil-fired furnaces I think that is an uphill battle. That difficulty is recognized by the state. For example, Table 11 of the Buildings Chapter in the Final Scoping Plan includes the theme “Expand New York’s commitment to market development, innovation, and leading-by-example in state projects contains strategy “B9: Scale up public awareness and consumer education”. In my opinion, public awareness and consumer education from NYSERDA about heat pumps is propaganda because it only shows the benefits and barely, if at all, mentions the downsides and caveats. Even the Scoping Plan recognizes that there are caveats for heat pump success: heat pumps must be properly chosen, appropriately sized, paired with an energy efficient building envelope or building shell, and installation must consider the appropriate minimum temperature. This post will address those caveats relative to this article.
New York State All Electric Home Article.
The article does a good job explaining why heat pumps will likely be mandated by the State. It correctly points out that now that the Scoping Plan is complete it is up to the governor, state agencies and legislators to implement the council’s recommendations. One of my concerns about the article is that it does not consider the possibility that the Scoping Plan could be flawed. For example, the Plan claims that 1 million to 2 million heat pumps will be installed in New York homes by 2030. However, that assumes that there is widespread consumer appetite to switch to all-electric homes. The article includes a description of a homeowner who has installed a heat pump. He is quoted as saying “His main goal was not to save money. He was out to fight climate change.” I investigated installing a heat pump for my home and the energy advisor said that most of the people who are installing them now have the same motive. The Scoping Plan hasn’t considered the fact that while many people say that they want to do something about climate change the number of people willing to spend significant money or can afford to do something is much smaller.
The article asks if “pricey electric heat pumps really keep homes warm in our frigid winters.” The article follows the party line when it states that “A new breed of “cold climate” air-source heat pump is a valid, energy-efficient heating option in Upstate New York.” I agree that heat pumps work but only if all four caveats noted in the Scoping Plan are considered.
The first caveat is that the heat pump must be properly chosen. If the heat pump is one of the new breed of cold climate systems it can meet that requirement. In a recent post I noted that in a recent presentation to the Climate Action Council it was explained that the Northeast Energy Efficiency Partnerships (NEEP) maintains a specification and product list that identifies specific air source heat pumps that work during extreme cold weather. If the heating, ventilation, and air conditioning (HVAC) contractor determines the appropriate extreme cold weather limits, then the furnace should be able to provide sufficient heat.
However, there are two complicating issues for choosing the proper heat pump. In the first place determining the appropriate cold weather constraint is not as straight-forward as the Scoping Plan suggests. At a recent Climate Action Council meeting there was a discussion of maps of worst-case cold temperatures that are used for this purpose but no recognition that there are multiple maps. Furthermore, temperatures are affected by local terrain conditions creating colder temperatures than shown on any state-wide map. The second issue is a design consideration. Heat pumps are more efficient than typical furnaces because they move energy from outside air into the home instead of creating it through combustion. However at some point even the most effective heat pump is not going to get enough energy out of extremely cold air to create enough heat to warm a house. Supporters argue that heat pumps are used successfully in the Scandinavian countries but the reason is that those homes have very effective building shells.
Based on my research and what I have seen, the building shell caveat has not received enough attention in the Scoping Plan, Integration Analysis or the NYSERDA marketing campaigns for heat pumps. Last summer I published a long article describing building shell issues. The Scoping Plan does not include a description of the building shell assumptions sufficient to differentiate between the reference, basic, and deep shell categories used in the Integration Analysis. I believe that the deep shell building envelope is necessary in order to ensure that New York homes can work without supplemental resistance heating capabilities. Unfortunately, the Scoping Plan does not provide sufficient information to determine what has to be included in order to meet that level.
The last caveat to discuss notes that the heat pump must be appropriately sized. The subtlety is that the entire system, including the ducts, has to be sized correctly. In the building shell post I documented my conversation with the energy advisor who described many of the issues related to improperly sizing the system. Heat pumps do not provide treated air that is as warm as a combustion furnace, so a big issue is that the ductwork may have to be made larger to provide sufficient heat. Tearing out the existing ductwork and installing larger ducts must be a disruptive project. In my case, this requirement led to his recommendation that it would be more cost-effective to install several ductless air-source heat pumps than to replace the existing central heating system.
The article discusses costs. The research I have seen agrees with the article that over the lifetime of the equipment that retrofit conversions will be cost effective for homes heated with oil, propane, or electric resistance heat but that is not true for natural gas. I have not seen analyses that incorporate the costs of building shell improvements but I my anecdotal discussion with the energy advisor he said that in my case those upgrades would never reduce energy use enough to pay for them.
The article references HeatSmart CNY, a Syracuse community organization, for its costs for installation of air source heat pumps. While I have my doubts that an organization whose sole reason to exist is to push heat pumps using NYSERDA funding could be considered an unbiased source of information the numbers provided appear reasonable. Based on their experience the “average cost of installation for a cold climate air-source heat pump has been about $20,000 to $25,000”. It is interesting that those costs are higher than the costs used in the Scoping Plan consistent with my findings that most of the cost numbers in the Plan are biased low. One of the arguments why the Climate Action Council claimed they could not provide costs to consumers was because rebates, tax credits and other subsidies availability isn’t known. HeatSmart CNY claimed that the homeowner typically pays more like $15,000 to $16,000 out of pocket when they are applied. The article also notes that additional rebates are expected for low- and middle-income homeowners as the result of the past year’s new Federal spending bills.
Earlier I mentioned that the Plan claims that 1 million to 2 million heat pumps will be installed in New York homes by 2030. However, HeatSmart CNY has only helped about 150 Central New York homeowners replace existing heating systems with heat pumps in the past four years. That suggests that there is going to have to be an enormous uptick in adoption rates for electric heating systems.
There is another cost issue that is never brought up in the advertising. The article mentions evolving technology being developed by the U.S. Department of Energy that includes a ”competition under way for manufacturers to develop heat pumps that will operate efficiently at temperatures as low as minus 15 degrees Fahrenheit” and “For now, many heat pumps in cold climates are installed with backup systems (using electric resistance heat or other sources) for extremely cold temperatures.” The Scoping Plan goal is to eliminate emissions from backup heat systems so their preferred backup alternative is electric resistance heat. The problem is that electric resistance heat is very inefficient and needs a lot of energy to operate. In order to provide that energy during periods of extremely cold temperatures when everybody who has all-electric homes and electric vehicles needs the energy the most, the distribution network and house service for many homes will have to be upgraded or the system will overload and blackout. The direct costs to upgrade home service and the indirect costs to upgrade the distribution network are a real hidden cost.
The article describes the experience of a homeowner who had a heat pump installed about 18 months ago. In addition to the heat pump, “he beefed up his insulation, installed a separate heat pump for hot water, and added a mechanical ventilation system to circulate fresh air.” The homeowner estimates the whole project cost $30,000 to $40,000 after rebates. Based on my work I think that is a more accurate reflection of the conversion costs. The article notes that there are efforts to subsidize low- and middle-income homeowners to make conversions less expensive but the fact remains that these conversions are costly.
Conclusion
This is a good article and covers many issues associated with residential home heating. However, despite its length and coverage it still did not address all the downsides of the Hochul Administration’s planned mandates to electrify homes. The Scoping Plan is only a framework. It does not begin to cover the “what if” questions like will any New York actions possibly affect climate change or what happens when there is an ice storm when everything is electrified. Finally, it does not include a detailed estimate of consumer costs.
New York’s Greenhouse Gas emissions are less than one half one percent of global emissions and since 1990 global those emissions have increased by more than one half a percent per year. While the fact that our emission reductions will get displaced by global emission increases in less than a year may not mean that New York should not do something, it does mean that we can step back and look at what can be done to ensure the State’s plan does not do more harm than good. The State’s arguments that we must act in haste are not supportable.
I have two concerns about doing more harm than good both related to the observation that “Death rates in winter months have been eight to 12 percent higher than in non-winter months”. The U.S. Environmental Protection Agency adds that “even moderately cold days can increase the risk of death for many people.” Home heating is obviously crucial to reducing those risks. My family survived two prolonged electricity outages and many more short outages in the 40 plus years we have lived in my home but never had any outage of our natural gas supply. When everybody has electrified everything what happens when there is an ice storm that causes an extended blackout in the winter? The other concern is whether all New Yorkers really afford all the costs for all-electric homes? How do we make sure that those least able to afford the investments necessary to convert to all-electric homes are not disproportionately dis-advantaged? Over 58% of current housing units are heated with natural gas and retrofitting those homes is not cost-effective. Will the State provide detailed cost estimates before they propose regulations to coerce us to convert?
The article cites the American Council for an Energy-Efficient Economy as saying that if the goal is to eliminate site emissions from households, natural gas will have to be phased out. My obsession to address New York’s net-zero transition boils down to fighting for my personal choice. I think that when all the benefits, costs, and tradeoffs are considered that natural gas is a better choice than electrification for me and my home. Anyone who agrees with me should let your legislators know of your concerns and demand answers to the inconvenient questions not addressed by the Scoping Plan framework when regulations are proposed.
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.
New York’s Climate Leadership and Community Protection Act (Climate Act) has been the primary focus of this blog since 2019. I am from Upstate New York so I really have not been following New York City’s equivalent regulation Local Law 97. This article looks at what it would take to meet the requirement that law’s requirement that “most buildings over 25,000 square feet will be required to meet new energy efficiency and greenhouse gas emissions limits by 2024, with stricter limits coming into effect in 2030”.
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 extensively on 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 this supposed cure will be worse than the disease. Moreover, many of the implementation requirements are going to increase costs tremendously. 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.
Background
Both the Climate Act and Local Law 97 are intended to meet a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. Since 2020 the Climate Action Council has been working to develop plans to implement the Climate Act. Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and greenhouse gas (GHG) emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”. Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021 for public comment. The next step is to finalize a scoping plan by the end of the year. Incredibly the proposed transition plan does not include sufficient feasibility analysis to determine whether it will be affordable, reliable, or what the cumulative environmental impacts will be on the state.
I have intended to write an article since I read an article describing “cutting-edge” climate technology for New York City public housing. That article describes the first awards of the Clean Heat for All Challenge that I described in an earlier post. The New York City Housing Authority (NYCHA), New York Power Authority (NYPA) and New York State Energy Research and Development Authority (NYSERDA) launched the Clean Heat for All Challenge as “an industry competition directed at heating and cooling equipment manufacturers to develop a new electrification product that can better serve the needs of existing multifamily buildings and hasten the transition to fossil-free heating sources. While this challenge is laudable the fact is that the Climate Action Council presumes it will be successful and has not established standards for affordability and reliability. If a reliable system doubles the cost of housing is that acceptable? If an affordable system risks frequent and severe blackouts is that acceptable? New York’s approach is to cross their fingers and hope that these implementation schemes will work.
Integration Analysis Residential Heating Costs
Because GHG emissions from buildings is the largest remaining sector in the State, the Integration Analysis proposes to replace all fossil-fired generation with electric options. As part of my comments on the Draft Scoping Plan I consolidated all the residential heating information in the Integration Analysis in a single spreadsheet. The Integration Analysis supporting documentation included device costs for Single-Family, Small Multi-Family, and Large Multi-Family residences. The Bldg Device Cost tab lists all the costs. A complete table with current building shell, air conditioning, hot water, and heating costs for Large Multi-Family residences is available. The following table consolidates device costs for three choices of building shells, air source heat pumps, backup electric resistance heat, and electric heat pump storage that I believe represents the costs to replace heating and hot water from the steam boiler systems used in many New York City Large Muti-Family apartment buildings. There is not enough documentation for me to definitively state that these represent the Integration Analysis best estimate of likely expected costs so I made the following assumptions. Anecdotally my son’s Brooklyn apartment had air source heat pumps that were inadequate in the winter because the building shell had not been upgraded so I think a basic shell upgrade is appropriate. I think the costs should include a basic shell upgrade ($26,259), an air source heat pump ($26,873), electric resistance heating because the basic shell is insufficient in the coldest weather (($1,140) and an electric heat pump water heater ($3,267) to provide hot water for a grand total of $57,539.
NYCHA Woodside
Environmental Justice advocates have repeatedly complained that disadvantaged communities have problems heating their homes. The poster child of New York City Housing Authority (NYCHA) developments with heating problems is the Woodside Development in Queens. After Hurricane Ida damaged the heating boilers in August 2021, Queens lawmakers toured the facility after resident complaints about problems with heat and hot water in January 2022. The problems are still not resolved because in early October 2022 residents still were having problems.
According to MYNYCHA “Woodside Houses has twenty, 6-story buildings and was completed December 30, 1949. The Heating Action Plan states that there are 20 buildings with 1,357 apartments for 2,842 residents. The heating system has six boilers that provide heat and hot water through a two-pipe steam system. The plan’s “major challenges” states:
This plant needs to allow all six boilers to individually switch to fuel oil during a gas service disruption. The current setup only allows staff to switch all boilers to either gas or oil. These are old models of the Preferred brand burners which cause difficulty in obtaining parts during an emergency. The boilers at this location have outlived their life expectancies.
The “cutting-edge” climate technology article interviewed Woodside residents in its article about window heat pumps. The article stated:
In an effort to help public housing residents stay cool in the summer and warm in the winter without resorting to extreme and even dangerous measures, New York announced the winners of its Clean Heat for All Challenge on Tuesday. It awarded $70 million to Gradient and Midea America, a startup and an established HVAC company, respectively. The duo will use that funding to manufacture 30,000 window heat pump units over seven years.
While the technology is relatively new and unproven at scale, proponents of the window heat pump say it could address a number of problems that plague New York’s public housing, which one in 16 New Yorkers call home. Many of those buildings feature outdated and unreliable heating systems as well as poor insulation. A large number of residents also lack access to air conditioning due to the cost of buying window units and the fees for professional installation and added energy use required by the New York City Housing Authority.
The challenge calls upon manufacturers to develop a packaged cold climate heat pump that can be installed through an existing window opening to provide heating and cooling on a room-by-room basis. The envisioned product would enable rapid, low-cost electrification of multifamily buildings by reducing or eliminating many of the cost drivers inherent to existing heat pump technologies when used in resident occupied apartments. These include costly electrical upgrades, long refrigerant pipe runs, drilling through walls and floors and other construction aspects which result in high project costs, and significant disruption to residents.
In my post on the Clean Heat for All Challenge I described another NYCHA electrification project where they are testing a Variable Flow Refrigerant heat pump system that I showed was very expensive likely due to the disadvantages of existing heat pumps described in the previous paragraph. Of the 30,000 window heat pumps NYCHA plans to purchase in the coming years, 10,000 will come from Gradient and 20,000 from Midea. If the project is a success, it could provide a more financially viable alternative. However, there are very few cost details available.
The Draft Scoping Plan does not do a very good job explaining that many of the control technology options used in the Integration Analysis are on the cutting edge of technology. In many cases, the required technologies have not been applied at scale so it is possible that there will be unforeseen issues that either increase costs or threaten the viability of the technology. Gradient is a San Francisco based startup with a clever window sited heat pump. Although Midea is an established HVAC company the heat pump offerings on its web site are sparse. The only Midea America heat pump option that I found that might be appropriate is the Thermal Arctic Series ATW Heat Pump, MHA-V16W/D2RN8-B, HB-A160/CGN8-B, HBT-A160/240CD30GN8-B. The description states:
Discover the real peace of mind for you right being at home. The eco-friendly, low-noise M Thermal Arctic Series Air-to-Water Heat Pump integrates air heating, cooling, floor heating and domestic hot water into one system, which is specially designed for satisfying all your demands. With the Built-in hydraulic kit and integrated design, the Mono type M Thermal is highly friendly for household installation. High efficiency and wide operating range allows proper selections under numerous utilization conditions according to the actual needs. Intelligent control and flexible maintenance bring convenience both to users and service providers.
The NYCHA Woodside boilers provide heat and hot water. The Midea option appears to address both needs but it is not clear if the Gradient unit does. In order to provide hot water plumbing to the water system will have to be installed and that raises questions about the applicability of any window unit.
There is another aspect of the heating application that was glossed over in the Draft Scoping Plan and rarely gets mentioned by heat pump advocates. For example, consider the following picture from the Gradient website. In order for heat pump technology to maintain comfortable temperatures when temperatures drop below 20o F the building shell has to be upgraded or resistance heating has to be used. The efficiency of heat pumps is a great benefit but the inefficiency of resistance heating is a big disadvantage that will likely require upgrades to the distribution service to the housing complex. In this picture the window is going to have to be replaced with a more energy efficient type and the wall itself would have to be insulated in order for a heat pump to provide all the heat necessary in that room.
The press releases do not address total transition conversion costs. Assuming that the NYCHA housing does not have insulated walls then there is a major problem. The only ways to provide additional insulation is to add rigid foam insulation over the existing wall or frame a wall next to the existing wall. In a high rise the only practical way to do this is to add those options on the inside. As noted previously I believe that in order for a comfortable solution the building shell has to be upgraded to a basic shell. The unit costs for the window heat pumps are cheaper than the Integration Analysis device costs but it is not clear how many window heat pumps per apartment are needed, whether building shell upgrades will be included in the transition, if backup resistance heat is included and what will provide hot water.
Private Condominium Example
Nearly half of the residences in New York City are in high rise multifamily buildings and on the order of 30% of those are in NYCHA projects. Writing at the Manhattan Contrarian website Jane Menton described the impact of Local Law 97 on her condominium that is representative of the rest. In her article she describes an email sent to the condominium board that said:
“I just wanted to bring this topic to your attention… The Climate Mobilization Act of 2019 will have a big impact on our building. Our emissions must be cut by 60% in the next 10 years or so. If we fail, the fines are in the range of $150k a year. We will be required to make hundreds of thousands of dollars in investments to upgrade our systems.”
She went on to describe the details for her building:
My colleague’s email was accompanied by the following chart, created by this website, called the NYC LL97 Carbon Emissions Calculator. This site has been endorsed by the City for buildings to use to calculate how much they are supposed to reduce their carbon emissions and how much they will owe in fines if they fail to install “zero-emissions” heating systems by the set deadlines. Here is the chart that my colleague came up with for our building:
According to the chart, about 75% of our carbon emissions result from our natural gas heat, represented in green in the circles in the lower right portion of the chart. The City’s statute mandates a series of lowering thresholds for building emission per square foot of space. By 2035, supposedly we must reduce our emissions by 60%, or face fines well in excess of $100,000 per year. In order to reduce our emissions by 60% we would have no option but to convert our building away from its current gas heat system – which is quite reliable, only a few years old, and in fine working condition – to an electric heating system.
Menton’s board has not estimated the costs to electrify their heating system. She explains:
Assuming that they decide to or are forced to go along with this, how much will it cost the unfortunate co-op owners? We haven’t yet had an estimate done for our building, but here are a few words from Warren Schreiber, board president of another Queens co-op, the Bay Terrace Gardens Co-op Section 1, and co-president of the Presidents Co-op & Condo Council (PCCC):
“Converting to (electric) heat pumps will cost [the co-op] $2.5 to $3 million, which does not include finance charges. This expense will result in a 25-30% monthly maintenance increase. Shareholders who have lived here for 20, 30, 40 and 50 years will have to leave Bay Terrace Gardens to find more affordable housing.”
Sadly, I would not be surprised that the heat pump conversion price shown does not include the costs for upgrading the building shell, providing hot water, and backup heat. I do not know how Local Law 97 addresses the inability of heat pumps to provide sufficient heat at temperatures below 20o F. Given that the costs will likely double I cannot imagine a scenario where building owners will bother to upgrade building shells. Most likely it won’t be considered until electrified buildings all over New York City start tripping their breakers or, worse, the combined load of all the electrified buildings causes sub-stations to trip off line plunging sections of New York City into blackouts. Importantly this also means that the Integration Analysis expectations for New York City peak wintertime loads that assume building shell upgrades underestimate likely future loads.
Discussion
I have written over 250 articles about the Climate Act and the implementation plans. In my opinion the biggest single shortcoming of the whole boondoggle is the lack of a feasibility plan addressing affordability and reliability feasibility. The Integration Analysis depends on technology that has not been deployed at the scale necessary nor in differing applications necessary for the residential heating electrification. Fortunately, in this sector the heat pump technology proposed for electrification has a long commercial history. The issue is how effective they will be at low temperatures when there simply isn’t enough energy in the air to keep residences warm in large multifamily buildings without substantive building shell upgrades. While there are potential solutions the costs and implementation issues are speculative. The Draft Scoping Plan provides undocumented device costs and the total costs relative to an arbitrary reference case but no breakdown of likely implementation costs per sector.
The specifics on affordability and reliability should give planners concern.The Integration Analysis all-in device costs including the “Basic” building shell upgrades for large multifamily residences total $57,539 per residence. The Integration Analysis states that there are 1,667,493 high rise multifamily residences in New York City alone. On the face of it that works out to nearly $96 billion for the net-zero transition. That is just affordability feasability. When 1.7 million New Yorkers have to turn on their backup resistance heaters it will create a peak load substantially higher than the current peak load. I believe that will require upgrades to the electric distribution system which if unaddressed will lead to reliability issues. In addition to this cost, it introduces an unprecedented stress to the electric grid. While I hope that the electric system planners will anticipate all the potential problems and upgrade the grid accordingly, the inclusion of a large percentage of generating resources that are intermittent and unable to be dispatched on demand makes me very pessimistic that there will not be learning curve blackouts.
Conclusion
In every instance where I have evaluated a component of the New York energy system and the challenge of a net-zero transition I have found that the problems are more complicated and uncertain than presumed in the Integration Analysis and the Draft Scoping Plan. As a result, I think the costs are underestimated and the potential risks to reliability a significant risk. The challenge of meeting Local Law 97 is no different. It is very easy to promulgate an aspirational target but clearly the politicians involved have no clue about the scale of the challenge. If they did, they would not be so anxious to jump into these laws. I have shown that New York’s total greenhouse gas emissions are less than one half of one percent of total global emissions and that since 1990 global emissions have increased on average more than one half of one percent per year. It is not clear what the point of these costs and these risks are when anything the state does is subsumed by what others are doing in a year.
This article describes the Clean Heat for All Challenge and the disconnect between the plan and reality. New York City Housing Authority (NYCHA), New York Power Authority (NYPA) and New York State Energy Research and Development Authority (NYSERDA) launched the Clean Heat for All Challenge as “an industry competition directed at heating and cooling equipment manufacturers to develop a new electrification product that can better serve the needs of existing multifamily buildings and hasten the transition to fossil-free heating sources”. Sounds wonderful until you look at the details and differences with New York’s net-zero transition plan.
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 New York’s net-zero transition and the implementation strategies needed for it because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that this supposed cure will be worse than the disease. Moreover, many of the implementation requirements are going to increase costs tremendously. 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.
Background
The impetus for the need clean heat is driven by the multifamily buildings electrification transition required for New York’s Climate Leadership and Community Protection Act (Climate Act) and New York City’s Local Law 97. Both the Climate Act and Local Law 97 are intended to meet a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council has been working to develop plans to implement the Climate Act. Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”. Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021 for public comment. The multifamily electrification documentation for the Integration Analysis was used in this post.
Clean Heat for All Challenge
The press release for announcing this initiative was titled “NYCHA, NYPA and NYSERDA Announce Global Innovation Challenge to Decarbonize NYCHA Buildings Using New Heat Pump Electrification Technologies”. Because GHG emissions from buildings is the largest remaining sector in the State, the Integration Analysis proposes to replace all fossil-fired generation with electric heat pump options. The press release describes the goals of the challenge:
The challenge calls upon manufacturers to develop a packaged cold climate heat pump that can be installed through an existing window opening to provide heating and cooling on a room-by-room basis. The envisioned product would enable rapid, low-cost electrification of multifamily buildings by reducing or eliminating many of the cost drivers inherent to existing heat pump technologies when used in resident occupied apartments. These include costly electrical upgrades, long refrigerant pipe runs, drilling through walls and floors and other construction aspects which result in high project costs, and significant disruption to residents.
The Clean Heat for All Challenge directly supports the goals of New York State’s Climate Leadership and Community Protection Act (Climate Act) and the New York City Climate Mobilization Act, which both call for greenhouse gas emissions from buildings to be reduced by 40 percent by the year 2030. The partnership between the New York City Housing Authority, New York Power Authority, and New York State Energy Research and Development Authority and will test innovative products and proposals for cost-effective heating and cooling solutions for NYCHA building portfolio, which includes 2,198 residential dwelling buildings. Additionally, NYCHA, NYPA, and NYSERDA have also engaged with the Consortium of Energy Efficiency (CEE) to engage manufacturers and encourage broad industry participation in the Clean Heat for All Challenge.
The RFP issued by NYPA identifies a list of product specifications that manufacturers will be challenged to meet. To incentivize participation, NYCHA will commit to purchasing the first 24,000 units from the awarded vendor(s) that will be installed at six developments currently slated for heating plant replacement over the next five years. NYSERDA is supporting the effort by providing additional funding from the Regional Greenhouse Gas Initiative operating plan, which calls for the electrification of heating in New York City public housing to improve energy performance, decrease emissions, and improve resident comfort. NYSERDA will provide assistance drafting the product specifications and performing commissioning as well as measurement and verification for the demonstration units. NYCHA will invest $250 million, in addition to the NYSERDA grant, to purchase and install the new equipment as well as provide additional improvements to the building envelopes and hot water systems.
830 Amsterdam Avenue Example
The Clean Air for All Challenge press release described another partnership to reduce GHG emissions from a New York City high rise complex. I will come back to the Challenge in a subsequent post but for now will discuss the 830 Amsterdam Ave Pilot Project:
NYCHA and NYPA are also partnering to replace the aging gas-and-oil-fueled heating and hot water systems at 830 Amsterdam Ave, a 20-story high-rise in Manhattan, with a high-efficient electric Variable Flow Refrigerant (VRF) heat pump system. The $28 million design-build electrification project will eliminate the use of on-site fossil fuel for heating and hot water while also providing central heating and cooling to 100 percent of apartments, replacing the old, inefficient window air conditioning units that have come to define many New York City-based facades.
This new and more efficient heating and hot water system will reduce local greenhouse gas emissions by more than 590 metric tons, the equivalent of removing approximately 130 cars from the road. The heat pump system, which would be the first of its kind at a public housing facility in New York State, will operate entirely on the grid without the need of a fossil fuel source. Once complete, residents will be able to individually control the temperature in each room of their apartment, a significant improvement over the current system, which does not provide any individual apartment temperature control.
According to MYNYCHA 830 Amsterdam Ave. is a 20-story building completed on August 31, 1965. The building has 159 apartments and 346 residents. According to the Heating Action Plan there are two boilers that can burn fuel oil #2 or natural gas. The boilers are 23 years old and no major challenges are listed.
Despite manufacturer claims about benefits using a Variable Flow Refrigerant heat pump system for this kind of structure, it is generally untested technology so this project can be considered a field test. It appears that the system checks off all the building’s needs and it will meet all the energy needs of the building without the need of a fossil fuel source. However, the “design-build electrification project” has a projected cost of $28 million and will only reduce emissions by 590 metric tons. That works out to an astounding $47,458 per ton reduced or $176,100 per residence. This is far above New York’s estimate of societal costs of carbon ($172 per ton in 2050).
The reality is that I don’t think this is an affordable electrification option. NYCHA has 267 developments with a total of nearly 162,000 apartments for about 340,000 people. If this technology were used for all those apartments the cost would be $28.5 billion. Using Integration Analysis data. I estimate that there are 2,050,000 large multifamily residences in New York. If this technology were used to electrify those homes the expected cost would be over $360 billion. Even of the costs could be reduced by an order of magnitude costs are still over $36 billion for just this residential electrification sub-sector.
Integration Analysis Ramifications
There are some issues related to the Integration Analysis. There are differences in the treatment of this building sector. The total costs for all the devices for any option in the Integration Analysis are far lower than the cost per apartment. In order for heat pump technology to maintain comfortable temperatures when temperatures drop below 20o F the building shell has to be upgraded or resistance heating has to be used. The efficiency of heat pumps is a great benefit but the inefficiency of resistance heating is a big disadvantage. The device costs for the “Basic” building shell upgrades for large multifamily residences in the Integration Analysis are double ($28,000) the cost as the heat pumps themselves ($14,000). It is not clear if this “design-build electrification project” includes building shell upgrades.
These differences should be reconciled. However, the response to Draft Scoping Plan comments has only described general themes of comments related to the Draft Scoping Plan document itself. The comment response focus is entirely on the narrative in the text and what needs to be changed for the Final Scoping Plan. There is no suggestion that there are any clarification or methodology issues related to the Integration Analysis that need to be addressed by the Climate Action Council.
This example illustrates just one issue for a single component. The assumptions used to determine the device costs for heat pumps for the large multifamily building sector are inconsistent with this project. NYCHA and NYPA determined that the appropriate electrification solution for this large multifamily building was a whole building variable flow refrigerant heat pump system. Unfortunately, the costs of this approach are much higher than assumed in the Integration Analysis. Did the Integration Analysis consider the fact that the existing boiler systems provide heat and hot water? Is this the norm or an outlier for electrification in this sub-sector? My point is that there are issues related to the Integration Analysis that could affect the State’s contention that the costs of inaction outweigh the costs of action. None of them have been addressed in the response to comments.
Conclusion
I am working on another post related to the Clean Heat for All Challenge and noticed the description of the 830 Amsterdam Ave project. As has been the case for every detail associated with New York’s plans for the transition to net-zero my review has found that implementation will be more complicated and likely more expensive than the description in the Draft Scoping Plan. In this instance the 830 Amsterdam Ave NYCHA and NYPA electrification prototype project is extraordinarily expensive relative to the residences served ($176,100 per residence) and the New York societal value of carbon ($47,458 per ton reduced vs. societal benefits of $172 per ton in 2050).
In addition, there are differences between these projections and the Integration Analysis cost estimates that should be addressed. Unfortunately, the Climate Action Council has shown no inclination to mention much less address any issues with the Integration Analysis that underpins the Draft Scoping Plan. As a result, the fundamental assertion that the costs of inaction are greater than the costs of implementing the Climate Act transition are not supportable.
The totally ignored safety aspect of this and all the Draft Scoping Plan electrification plans also should be considered. At this time 830 Amsterdam has a boiler system that can burn #2 fuel oil or natural gas and every apartment owner can install an electric space heater. That is triple redundancy for heating the apartments. The implementation plan is to convert completely to electric and make the safety of the residents dependent upon electric heat. No where does the Scoping Plan address this inevitable “what if” impact. The benefits of the Climate Act are mostly imaginary but the costs will be real.
For over two years I have been reviewing New York’s Climate Leadership and Community Protection Act (Climate Act) primarily with respect to those aspects where I have a professional or personal interest in the impacts to me. One of the topics that I have spent a lot of time on is residential electrification with an emphasis on home heating. This article addresses the building shell requirements necessary to include when home heating is electrified.
Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level. I have written extensively on implementation of New York’s Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it 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 “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 material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.
Last April Jim Shultz authored a Niagara Gazette commentary titled: Is New York state coming after our furnaces? that addressed a rumor that the Climate Act would ban gas furnaces. I mention the article because he eloquently described the Draft Scoping Plan: “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.” Nowhere is this more evident than in the documentation associated with residential electrification building shell requirements.
If you are interested in background information, in an article describing my interview with Susan Arbetter at Capital Tonight I 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. I will focus on building shell requirements in the rest of this article.
Draft Scoping Plan Building Shells
The Draft Scoping Plan does not include a description of the building shell assumptions sufficient to differentiate between the reference, basic, and deep shell categories used in the Integration Analysis. The primary reference for Draft Scoping Plan information related to building shells is Appendix G, Integration Analysis Technical Supplement Section I chapter 3.3 Sectoral Results – Buildings. The following paragraph is the entire narrative description of building shells.
Building shell improvements (such as improved insulation, window treatments, or deep home retrofits) are modeled as reducing service demand for HVAC devices. Improvements to buildings incur costs but improve home and office comfort in addition to reducing energy bills. Two bundles of building shell improvements have been included: a basic shell upgrade and a deep shell upgrade. Basic and deep shell upgrades include a variety of measures focused on reducing energy use and increasing occupant comfort; these measures include, for example, varying levels of roof and wall insulation improvements, window treatments such as double or triple paned windows and infiltration improvements. Space heating demands are reduced by 27-44% with the basic shell package and 57-90% with the deep shell package, depending on building type. Air conditioning demands are reduced 14-27% with the basic shell package and 9-57% with the deep shell package. The total impact of building shell improvements on total HVAC service demand in buildings is a function of the market penetration of each package and distribution of building types. Building shell improvements include both retrofits and new construction, although all new construction in residential and commercial is assumed to be code-compliant and therefore has lower HVAC service demands relative to the existing building stock. E3 calculated the stock rollover of building shells with a 20-year lifetime to reflect improvements in new construction and opportunities for home retrofits.
In addition to the narrative description of building shells there is descriptive information in the supporting spreadsheets. The Annex 1 Inputs Workbook spreadsheet, Tab: Bldg_Res Device Cost lists device costs for three categories of residential households: large multi-family, small multi-family and single family. Costs are listed for the three types of building shell upgrades and for air source heat pumps, electric resistance backup heat, and ground source heat pumps. I used this information to estimate total residential heating conversion costs for my comments on the Draft Scoping Plan.
In the Annex 2 Key-Drivers spreadsheet there are tabs with building shell metrics. Scenarios 2-4 note that in 2020 there were a total of 8,301,996 residential buildings with 48,551 basic shell residences, 37,699 deep shell residences, and 8,215,747 reference shell residences. There is no difference in the projected building shells for the three mitigation scenarios. For scenario 2 (tab S2_Building Shells) in 2050, the integration analysis projects 8,684,001 residences, with 5,714,918 basic shell residences, 2,285,000 deep shell residences and only 684,080 reference shell residences. The following table lists the projected number of different types of building shells and the annual deployment rate.
A couple of points about this table. Note that the number of building shells in the Reference Case differs from the mitigation scenarios in 2020. Obviously, there should not be a difference. I have no idea which set of numbers is correct. The second point is that the mitigation scenario deployment rates are unrealistic between 2030 and 2040. The total of the basic and deep shell conversions works out to over 1,250 building shell upgrades per day.
Practical Application
So much for the theory. I live in a single-family residence heated with an efficient natural gas furnace. In my opinion one of the disadvantages of heat pump technology is that the output heat is relatively low compared to a combustion source furnace. The temperature at the register for a heat pump system is around 90oF whereas in my house the temperature is around 120oF. My concern is that there are some cold rooms in my house even when the furnace is providing hot air despite my best attempts to adequately insulate and reduce air infiltration. The worst problem is in the bedroom we added over the garage. In order to determine what I would need to do to install an air source heat pump that would provide comfortable heat year-round I really needed an energy audit.
National Grid recently announced a Home Energy Savings Program in cooperation with the New York State Energy Research & Development Authority (NYSERDA) that included an assessment of energy use in homes that was open to customers in my county. Figuring I had nothing to lose I requested an audit. When I scheduled the home assessment, I said I was particularly interested in what I would have to do to install a heat pump.
I believe that National Grid has a contract with ICF to manage the Home Energy Savings Program. ICF arranges for local heating, cooling and air quality contractors to provide the assessments themselves. I believe that National Grid and NYSERDA pay for the audit but I got the impression that the auditor could make a commission if equipment was sold. The auditor assigned to do my assessment had a certification from the Building Performance Institute and knew his stuff. Interestingly the fact that he was unfamiliar with the basic and deep shell terminology used in the Draft Scoping Plan suggests that the Plan’s authors were not certified by the Building Performance Institute.
Audit Results
The auditor and an intern working for the company spent two hours evaluating my house from top to bottom. We talked about my concerns and needs and then they checked the outside of the home and the main floors, basement and attic interiors. Because my primary concern was home heating, they concentrated on heat loads. As has been the case for every aspect of the Climate Act I have evaluated closely, reality as explained by experts is different than the situation portrayed in the Integration Analysis.
Heat loads can be calculated two ways. According to the auditor “About 90-95% of the industry is still in the stone age and sizes systems based primarily off square footage of the home… not actual heat loss or heat gain through insulation, windows, building material, volume of home, area of building envelope/shell areas, etc.” The preferred alternative is to do an Air Conditioning Contractors of America “Manual J Calculation” or “Heat Load/Heat Gain Calculation”. He explained that “This historically has been done manually, and since the computer age came about there are now Manual J software programs which are used to model homes and run the calculations for you based off different input data gathered from a home during an energy audit”.
The auditor has found that about 90% of the homes he analyzes have drastically oversized heating equipment which he attributes to the older and less accurate heating load calcuations. As a result, there are the following consequences: rapid cycling, reduced efficiency and system lifespan, and reduced comfort and adequate distribution because of the fan always cycling. He said that sizing is even more important for condensing furnaces, heat pumps, and air-conditioners. He has seen condensing furnaces (i.e. 92% efficient or better) with cracked heat exchangers after only 5 years because of these problems.
He also explained that air conditioning systems work by removing moisture, so if they are oversized and rapidly cycle, they will not be removing enough moisture from the air at the correct rate at which the air is cooled. Most people who complain of hot rooms in the home are told they need a bigger air conditioning unit. This is counterintuitive and the wrong way to do it. A bigger system means more airflow is needed, and if the ductwork sizing is not adjusted accordingly, the evaporation coil will freeze on the furnace and the system will shut down until it defrosts. Another scenario is that with rapid cycles you end up with cold air but it is still humid… giving that clammy cold feel. Or, the problem doesn’t change at all and the room still stays too hot because it is related to the amount of air getting to that room through a duct. The duct size is the limiting factor because only large systems (100,000btu or higher) have larger blower motors that can move sufficient air.
With regards to heat pumps, it is particularly important that the heat loads are calculated correctly. If the heat pump is oversized you end up with the efficiency of basically resistant electric strip heat (baseboard electric heat). He said that New York’s push for heat pumps is unsophisticated because the way the grants are designed it forces contractors to oversize the heat pumps. Apparently, some heat pump brands might be okay if they are oversized. He explained that:
Some efficiency will be lost if the system is oversized, however they can still run efficiently relative to oil, propane, natural gas, and don’t always end up running at the efficiency of basic strip electric resistant heat. The most important thing with heat pumps is “turn down ratio”, aka what is the lowest heat output it can produce. As long as the lowest heat output on a heat pump unit is still higher than the particular demand of a home on any day during any hour of the winter, it will still operate properly and efficiently. Will some efficiency be lost still? Yes, but not nearly as bad as if the turn down ratio is higher than the lowest heat requirement of the home as noted above. A lot of installers don’t get this unfortunately. Neither does New York State. But we can still win battles against it all day-to-day through conversation.
There are other ACCA manuals: Manual S covers heating and cooling sizing and selection, Manual T is used to determine air distribution within the building, and Manual D supplements the other manuals to determine appropriate heating and cooling duct design. The obvious point is that all this information is necessary to properly design a replacement building shell heating, ventilation, and air conditioning system. If it is done wrong there will be serious problems.
Building Shell Definitions
In response to my question about the building shell the auditor could not respond. He asked me and all I could do is point to the sparse Draft Scoping Plan documentation. We agree that the documentation is insufficient for contractors to specify improvements necessary to meet the Plan definitions. This section contains my best guess but there is an inconsistency with the Integration Analysis projections. In a post in November 2020 I noted that you could see the variation in energy efficiency in my neighborhood by looking at early morning frost patterns. Based on my crude analysis only 10% of the homes in my mid-60’s housing development appear to have large reduction potential, 50% could use improvements compared to the remaining 40% of homes that appeared to have well-insulated homes. If the reference shell refers to a home with minimal insulation, then my best guess is that the reference shell would only be 10% of the existing stock in my neighborhood.
My November 2020 post also included the following overview slide of the residential housing sector profile of New York prepared by the New York State Energy Research and Development Authority (NYSERDA). It was included in the Energy Efficiency and Housing panel presentation on October 16, 2020. Note that “at least 22% of residences have under-insulated exterior walls and roof”. This is another possible definition of the reference shell but that is inconsistent with the Integration Analysis 2020 housing stock estimates.
The auditor made the point that the industry does not use the Deep and Basic shell terminology defined in the Integration Analysis and Draft Scoping Plan. Instead, there are industry standards of R-Value (R-49 for attic flats, for example). However, that approach over simplifies the actual energy losses. He explained that spray foam vs. attic flat cellulose/fiberglass batt R-Values are not an “apples to apples” comparison because the foam seals air infiltration too.
In our discussion he explained that one of the factors which differentiate “deep shell” work vs. “basic shell” work could be hitting the building airflow standard (BAS). He said that NYSERDA requires their contractors to hit BAS for all retrofit jobs that are getting heat pump funding through low income NYSERDA grants. He explained that this this is a problem because:
I have seen maybe two or three retrofitted homes in 10 years that have hit BAS when all industry standard R-Values in walls, basements, crawl spaces, attics, windows etc. are achieved. However, there is some “gray” when calculating BAS, and it comes down to what you consider “conditioned space”. If a basement is not heated with supply grills/supply ducts dedicated to the basement, by definition the basement is not considered “conditioned space” and therefore the volume of the basement is not included in the BAS (i.e. the BAS value for the entire home is lower, making it much harder to achieve on retrofit projects). However, since there is by definition heat loss through the metal in ductwork (up to 10,000-15,000btu on average I have found which is defined in Manual J calculations as “duct loss”) then would this not latently be heating basements and crawl spaces? This is what I have assumed when calculating my heat loads and BAS calculations. I include the basement, insulated or not, and crawl spaces (only when insulated for crawl spaces due to vents, etc.) as conditioned space because they are being latently heated. This makes the most sense to me. In my experience I have seen most retrofitted homes meet BAS when including the basement as conditioned space.
There is another complication. When running Manual J’s, I negate out the “duct loss” factor since in a basement the latent heat being “lost” is going directly into the basement and above grade walls anyway. This 10,000-15,000btu “duct loss” is another “oversizing” issue when running Manual J’s. Ultimately this means that out of the maybe 5% of companies out there running Manual J’s instead of sizing by house SQ FT. very few of that 5% are removing “duct loss” in their Manual J’s according to where the ducts actually are. If they run through a vented crawl space or the run outside (or a non-air sealed/non spray foamed mobile home underbelly), I would consider that true “duct loss”. A basement or unvented crawl space under a home is providing heat to the house. If that is not done correctly the result is that the system will be over-sized.
Also note that there is a reference to air leakage with respect to the Passive House standard in the NYSERDA slide. My best guess is that “deep” building shell improvements are equivalent to the international standard for passive buildings. It includes the following measures:
Efficient heat generation (which in this case means heat pumps.
There is an inconsistency in the building shell deployment table with respect to the 2020 distribution of building shell types concerning the relative distribution. The Integration Analysis claims that about half a percent of the existing building stock meets the deep shell criteria. If my guess that the Passive House criteria represent a deep shell, I think that would be consistent. The problem arises with the reference shell. Both my crude analysis or the NYSERDA 22% are under insulated criteria for the reference shell are far less than the Integration Analysis presumption that 99% of the residences in New York have reference shells in 2020.
The definition problem is most acute between the reference and basic shells. Apparently, the basic shell is something intermediate between meeting all the passive house criteria and being under insulated. Ideally what the energy contractors of the state and the authors of the Draft Scoping Plan need to do would be to define what constitutes the standards for each level of building shells based on the passive house measures.
There are some ramifications to the existing lack of specificity. The Integration Analysis assumes energy and emission reductions based on the conversion from reference to basic and deep shells. It appears that the analysis is not accounting for the large number of residences that have enough building shell upgrades beyond the reference shell that they should be considered basic shells. Ignoring this means that the projected improvements in the Integration Analysis are far greater than can be reasonably expected.
Ventilation
Several months ago, I contacted the writer of a letter to the editor because he raised important points about building ventilation. He is an expert on ventilation analysis and energy efficiency and I asked him about the passive house resource ventilation requirement reference. I asked what the reference to passive house ventilation with highly efficient heat recovery would entail. He said that it referred to using an Energy Recovery Ventilator (ERV).
He explained that it is much easier to incorporate into an existing HVAC system than it sounds. They are not free, but “using one pays dividends in many cases as for health and human performance”. Although he has dealt mostly with commercial units he mentioned that Panasonic has been advertising a new residential unit, the Intelli-balance 200 ERV that retails for around $2700.
The concept is simple: Air is exhausted and as it goes through a heat exchanger in the ERV. About 70% of the energy is transferred to the incoming air for either heating or cooling mode. There are two fans (sometimes only one motor runs them both), filters to protect the heat exchanger, and the heat exchanger.
He said that “these amazing units were not available 40 years ago, or they were all metal and very expensive”. He offered a few other tidbits:
ERVs use a small amount of electricity for a residence.
ERVs have one intake, one exhaust, one air supply and one return that gets exhausted.
ERVs are relatively quiet when properly installed.
ERVs recover about 70% of the energy from the exhaust air.
ERVs can be integrated into a home furnace in the winter because the ERV pre-warms the air significantly before it enters the mixing box where the full air flow goes into the furnace. For example, 100 cfm of ERV air in mixes with 900 cfm of return air so the mix is nearly the same as ordinary return air. This way the furnace heat exchanger is not being fed very cold air which can be harmful to a furnace not designed to heat air that is very cold.
He also explained that the ERV forces exchange of inflow and exhaust. The ERV can adjust the air flow exchange so that a bathroom or kitchen exhaust brings in a little more air than you exhaust. You do not want to create a negative pressure in the house especially where there are gas burning appliances. It is possible to draw air away from the cooking, water heating or space heating if they do not have forced draft combustion as also do some furnaces. This is a concern when infiltration is minimized to the standards suggested in the Integration Analysis. Furthermore, if you bring in a slightly more ERV air than is exhausted the house is then slightly pressurized so there are few to no drafts.
Finally, he made the point that these building systems cannot be evaluated by just looking at one piece. All the air into the house or commercial building needs to be accounted for. All the appliances have to work together to control the air flows and pressures of the building. It is not complicated, but does need attention. The final heating ventilation and air conditioning recommendation he made is the need for residential humidifiers in our cold dry climate in the winter. Dr Stephanie Taylor MD has shown that when space humidity is too dry it can increase the risk of colds, flu, and other respiratory ailments.
My Audit Results
The auditor explained what he thought would be needed for shell upgrades for a system that would make air source heat pumps a viable alternative for my home. My furnace is over-sized and the duct work is under-sized for the existing system. As noted above one of the big issues with the whole house heat pumps is that you need to change the ductwork to enable more air flow so I would need to replace a lot of the existing system. My house would need to get more insulation and sealing at the sill of the basement wall. I have installed a ceiling in most of the basement and that would have to be ripped out. It may be that those costs are included in the Integration Analysis projections but due to the lack of documentation we don’t know for sure.
Relative to the added bedroom over our garage and he said those were notorious for heating and cooling problems. In order to fix that he recommended a ductless heat pump at an approximate cost of $5300 but there is a National Grid grant of $500 so the cost would be $4800. He did mention that there is a wait time for these systems and whole house heat pump systems are simply not available at this time.
I did not request a quote for a whole house system. Nonetheless he gave me some suggestions. Given the changes needed to the duct work the whole house system would be more expensive that the ductless systems. His initial thought was that we would need four ductless heat pumps to do the whole house but it is not clear to me how that would work. On the main floor a system at each end of the house would provide heat for that floor. If there are two systems on the upper floor how is heat supposed to get into the other two bedrooms – sleep with the doors open? The estimate of four system also does not include heat for the basement.
He admitted that converting to a air source heat pump could not save money compared to using natural gas and noted that given the state of my house upgrading insulation, windows and air infiltration would not ever pay back the investment either. He said most of his clients that install heat pumps do it for environmental reasons.
Conclusion
I do not doubt 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 and the potential for the conversion to be done improperly is high particularly given the tremendous rate of conversions envisioned in the Integration Analysis. Clearly it is not just the heating system but the building shell needs revisions too. Based on my discussions with these experts the air infiltration, inflow, and exhaust requirements are much higher priorities than I realized. The Climate Action Council needs to be sure that the Final Scoping Plan adequately defines the building shell criteria so that experts in the field understand what the State claims is necessary for the different building shell types. This is also crucial so that the projected energy savings and emission reductions are achieved.
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. I was interviewed for a segment on the home heating electrification component of the Climate Act on Spectrum Cable’s Capital Tonight program hosted by Susan Arbetter. This post provides documentation for the information I provided in the interview.
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. This blog emphasizes that pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues. 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 Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Draft Scoping Plan that defines how to “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.
Earlier this year I watched an episode of Spectrum Cable’s Capital Tonight program where Susan Arbetter was interviewing someone about the costs associated with the home heating electrification component of the Climate Act. I got the impression she was not getting the specifics that she wanted so I followed up with an email suggesting that I might be able to help her understand what is in the Draft Scoping Plan. She called me the next day and we agreed that most New Yorkers have no clue what is coming at them. I offered to help provide her with information based on my evaluation of the Climate Act’s Draft Scoping Plan and this interview was the result.
In order to educate the public, she posed some questions beforehand that enabled me to track down the answers. The interview did not follow the scripted questions very closely. The numbers provided in this interview are all derived from the Draft Scoping Plan and Integration Analysis spreadsheets as documented here.
What does the scoping plan say about the building sector?
The Plan estimates that the buildings sector is the largest source of greenhouse gas emissions at this time. Buildings and transportation account for over 54% of total emissions. Digging deeper it turns out that space heating is nearly 20% of the total and is the largest sector exceeding even electric generating emissions. The Plan proposes to electrify building sector space heating to eliminate those emissions.
What options are proposed as an alternative to oil and gas heat?
The preferred electrification alternative is heat pumps. Heat pumps are more efficient than combustion heaters because they move energy around rather than create it. A refrigerator is a type of heat pump. It extracts energy or heat out of the refrigerator cooling the inside. Heat pumps work in reverse extracting energy outside the home and bringing it in to warm the inside.
There are two kinds of heat pumps. Air source heat pumps extract energy out of the atmosphere and ground source heat pumps extract energy out of the ground. Air source heat pumps are simpler to install so are less costly. Ground source heat pumps have to install a heat exchanging ground loop underground which is more complicated and may not be possible due to site constraints. The Scoping Plan modeling projects that about 75% of the heat pumps installed will be air source.
I keep hearing that heat pumps may not be good in the winter. What’s your take?
The problem with heat pumps is that they can only heat your home if there is energy to transfer. This is not an issue with ground source heat pumps because if the underground heat exchanger is installed properly the is always sufficient energy. During the coldest periods of the winter there isn’t sufficient energy in the atmosphere to heat your house. The Scoping Plan includes a supplemental resistance heating unit to address that.
There is another aspect of this that doesn’t get much attention. Refrigerators work so well in large part because there are insulated well and sealed so well that there is little air infiltration. When you hear about homes in Norway and Alaska that use heat pumps, they have upgraded building shells. Building shell refers to the insulation, air infiltration, and window treatments needed to minimize energy use within the building. The Draft Scoping Plan describes two bundles of building shell improvements: basic and deep (Appendix G, Section I page 34). There is only a brief discussion of the two types so it is not clear just what is expected of homeowners. The Scoping Plan projects that 64% of homes will install basic shells, 27% will have deep shells and 7% will have reference shells. Reference shells are for homes that cannot be upgraded without great cost and effort.
How much?
In my opinion the Climate Action Council should describe all the control measures, provide references for their expected control strategies, and list the estimated costs projected emission reductions. In the absence of that information, I estimated costs based on my evaluation of the Integration Analysis spreadsheets. The device costs listed for single family homes are $14,678 for an air source heat pump and another $1,140 for electric resistance backup. Ground source heat pump cost is $34,082. For a basic shell upgrade the Plan device cost is $6,409 and a deep shell is $45,136. Table “Furnace Costs” lists the information needed to estimate individual retrofit costs.
I estimate the costs to retrofit heat pumps to existing residential furnaces in 2018 would total $96.9 billion if they were all converted to air source heat pumps and $202,6 billion if they were all converted to ground source heat pumps. The Draft Scoping Plan assumes 75% air source and 25% ground source and that totals $123.3 billion.
The Draft Scoping Plan mitigation scenarios assume that in 2050 64% of the residences will have basic shells, 27% will have deep shells and 7% will have reference shells. The total cost to implement those residential upgrades will be $115 billion.
The Draft Scoping Plan estimates that from 2022 to 2050 the state will have to spend each year $4.25 billion to replace existing furnaces with heat pumps and $3.97 billion to upgrade building shells for a total of $8.22 billion.
Is there anything else we should know?
The implementation timeline is still evolving. Also note, that additional legislation will be needed to mandate that when your existing furnace reaches its end of life at some future date, then you will have to install a heat pump. I imagine that building codes will change so you will also have to upgrade your building shell at some point too.
If you are concerned about this then you should go to Climate.ny.gov for more information. There also is a link to provide comments. I encourage everyone to comment because whatever happens will have major impacts in the not-too distant future. I also suggest that you contact your legislators to let them know how you feel.
One final note is that no one is claiming that converting a home using natural gas heating to heat pumps will actually save the homeowner money. Consequently, 5.8 million residences will be paying a hidden tax. Furthermore, there is a safety concern. The reliability of the gas system is much higher than that of the electric system particularly in the aftermath of heavy snow or ice storms. It is not clear what is supposed to happen when everything is electrified and there is a major outage.
Documentation
The numbers provided are documented in a spreadsheet that extracts data from the Integration Analysis spreadsheet then consolidates and summarizes it. There are five tables. “Emissions” lists the total greenhouse gas emissions by sectors. “2018 Stocks” consolidates the current heating stocks used in the Draft Scoping Plan. “Bldg_Shell Costs” lists the types of building shells projected for the different Plan analysis scenarios and estimates state-wide costs for those upgrades. The “Furnace Costs” table projects state-wide costs to retrofit heat pumps to existing furnaces. For individual homeowner costs I put together a table that can be used to estimate the cost to replace all the furnace types included in the Draft Scoping Plan. For example, if a homeowner wants an estimate of the retrofit cost to replace a distillate boiler with an air source heat pump using a basic building shell, read down column D. The heating electrification cost is the sum of the heat pump, the electric backup, and building upgrade is $22,227. The cost of a replacement distillate boiler ($9,260) is subtracted from that total to get $12,967 as the retrofit cost.
Conclusion
Ms. Arbetter was upfront with her audience that I am skeptical of the Climate Act. I responded to her questions using only information from the Draft Scoping Plan text, appendices and the Integration Analysis spreadsheets. Therefore, my personal opinion should not taint the interview responses.
I am convinced that very few people are aware of the Climate Act, fewer understand the implications, and only a handful have dug into the Draft Scoping Plan in enough detail to provide meaningful comments. Given that I have written over 190 posts about various aspects of the Climate Act on this blog I am one of that handful. Based on my work I am convinced that it is very likely that the Climate Act will do more harm than good due to increased costs, reliability risks, and environmental impacts.
In my personal conversations with people about this particular aspect of the Climate Act the typical response when I tell them that someday they will have to replace their gas, propane, or oil-fired furnace with an electric heat pump is incredulity. Frequently, the response is “What will I do when the power goes out?” I can only tell them it is going to be the law so you have to speak up now. Hopefully the information provided in this interview will spur people to comment.
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. I recently read a Niagara Gazette commentary by Jim Shultz titled: Is New York state coming after our furnaces?. While I agreed with much of what he wrote I did send him an email explaining my concerns with certain aspects of his commentary. I reproduce it below and include my comments after it.
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 climate change 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.
I received a post card the other day from state senator Robert Ortt warning me, in the midst of a cold winter, that I might be made even colder in years to come under a new state action plan on climate change. The card warned that starting in 2030 we would no longer be able to get new gas furnaces, stoves, or clothes dryers, and that gasoline-powered cars would no longer be for sale in New York starting in 2035. The senator wrote, “Well intended as it might be, this Plan could mean even higher energy and consumer costs for you.”
The plan Mr. Ortt is referring to comes with a classically bureaucratic name: The New York State Climate Action Council Draft Scoping Plan. I skimmed through its pages over the weekend, all 331 of them. The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it. Here’s an example: “Regardless, any transition must be carefully planned, detailed, and clearly communicated to ensure that expectations are aligned across stakeholders.”
What does that even mean?
Most of those 331 pages are dedicated to telling us why the state needs to move swiftly away from the fossil fuels that cause climate change, a premise that I agree with. Far fewer pages actually say what specific actions the plan would recommend to state lawmakers. You couldn’t make it less accessible to average citizens if you tried. Finding the specific policies that Ortt is referring to was no easy task.
On gas furnaces, the report says (on page 129): “2030: Adopt zero emission standards that prohibit gas/oil replacements (at end of useful life) of heating and cooling and hot water equipment for single-family homes and low-rise residential buildings with up to 49 housing units.”
What does this mean (and not mean) in concrete terms?
It does not mean that in January 2030 you will no longer be able to use a gas furnace in your home or that you will be required to buy a new electric one when the gas unit you have works just fine. What it does mean is that after 2030, when your gas furnace does need to be replaced (this could be in 2040 or later if your furnace is relatively new), you will need to make the transition to an electric one. The plan includes financial incentives to help pay for the change.
State environmental planners warn that because gas is a major contributor to climate change it is going to get phased out eventually. It is a waste, they say, for New York to keep sinking more money into the gas infrastructure that would be needed to keep servicing gas appliances 20 or 30 years down the road. It would be like investing in Blockbuster Video after the entire world migrated to Netflix. Ortt got the phase-out target date for new gas clothes dryers and stoves wrong by five years. It’s actually 2035.
On the matter of gasoline automobile sales, the plan takes a very deep dive into bureaucratic gobbledygook to get to the answer to that (on page 103). The New York plan is essentially: Adopt California’s new plan to transition to zero emission cars. But when you look at the actual California plan that New York would copy, it does not say: It will be illegal to buy a gasoline-automobile from 2035 onward. What it says is: “It shall be a goal of the State that 100 percent of in-state sales of new passenger cars and trucks will be zero-emission by 2035.”
To be clear, a goal and a prohibition on the sale of gasoline cars are not the same thing. I might have a goal to lose five pounds by summer, but if I come up short that doesn’t mean I stop eating. We ought to have ambitious goals that would let us drive to our jobs without making climate change an even worse crisis for our children to deal with. But the transition is big and it is complicated, so the path has to be practical as well.
If you are part of that small minority in the United States that doesn’t believe climate change is real (or don’t care about it because you expect to be dead by the time things get really bad) then none of this make any sense. But if you do believe in the science of climate change and do worry about the future we are handing our children, then making the transition away from fossil fuels is really important, but also not a simple thing.
It’s easy to toss out one-line warnings on a post card and make people feel like state bureaucrats are coming for our furnaces. It is harder to bring forward the facts in a more complete way, free of all the bureaucratic jargon. What we need to do, as citizens, is look closer at what is actually being proposed, call out what doesn’t make sense for our communities, and offer up smarter alternatives. This is the homework of democracy.
If Senator Ortt is sincere in his desire to help us make our voices heard, a more effective thing to do would be to bring some of the state officials who helped put the plan together here to Lockport, to present that plan to the community — in plain language. These issues are important. They should not be buried under indecipherable gibberish or just turned into political fodder. What we need from our state leaders is real information, and an informed and thoughtful discussion about the way forward.
Jim Shultz is the founder and executive director of the Democracy Center and a father and grandfather in Lockport. He can be emailed at jimshultzthewriter@gmail.com.
My Response
I am writing in response to your commentary in the Niagara Gazette titled “Is New York State coming after our furnaces?”. I wanted to point out that I agree with Ortt’s conclusion: “Well intended as it might be, this Plan could mean even higher energy and consumer costs for you.”
I have been studying the Climate Leadership and Community Protection Act (Climate Act) since April 2019 and written over 185 posts on topics related to the Act and implementation of the Act at my blog Pragmatic Environmentalist of New York. I believe that it is very likely that implementation of the technology necessary to meet the targets of the Act will adversely affect energy sector affordability and risk current reliability standards. Unfortunately, most New Yorkers are unaware of it and only a handful understand the implications. Many of the articles I have published are overly technical for the general public. In order to address the need for a concise resource of the potential impacts of the Climate Act for laypeople I have developed the Citizens Guide to the Climate Act.
Given that you only skimmed the Draft Scoping Plan you did a good job summarizing the furnaces and vehicle mandates. However, your comment that “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it” massively underestimates the degree to which the Scoping Plan hides some critical information. My concern is that the problem and the solution have both been over-simplified. Every issue I have looked at it gets more complicated as you dig into it. I prepared an overview of the Scoping Plan as it relates to affordability and reliability that addresses some of the nuances that are not immediately obvious relative to the points you made.
I agree with your characterization that “after 2030, when your gas furnace does need to be replaced (this could be in 2040 or later if your furnace is relatively new), you will need to make the transition to an electric one”. However, the heating transition to electric will include an upgrade to building codes for building shells. There is a table showing heating retrofit costs in the overview post that shows that adds costs of between $6,409 and $45,136. I believe that when you try to sell your home it has to be up to code so wouldn’t you be required to retrofit your furnace and upgrade the shell before you can sell?
The Scoping Plan does not even attempt to claim that the electrification retrofit will save money. All the benefits listed are societal benefits that cannot be used to offset consumer costs. You explain that you worry about the impacts of climate change. The avoided GHG emission impacts on climate change societal benefit attempts to quantify the impacts of our emissions on climate change. The overview post shows that the Scoping Plan cheats to maximize that benefit by counting benefits multiple times. When that error is corrected the costs are greater than the benefits. It does not make sense to me to implement these measures if they aren’t cost-effective. It makes more sense to invest in R&D to come up with cheaper, more reliable zero-emissions alternative technology. Until that technology is available it is unlikely that the developing countries will forgo the advantages of electrification.
With respect to automobile electrification, don’t forget the hidden costs to set up the infrastructure for charging. It is bad enough to install something at home but who is going to pay for the chargers for those who park on the street or in parking lots.
While I understand that you want to do something about climate change, the only conclusion that I can draw from my evaluation of the Climate Act is that it will cause more harm than good. Please take a look at my Citizens Guide and let me know if you have any questions.
Response from Shultz
Thank you for your detailed note. The point of my brief article was that these issues, as you note, are complex, and I think citizens are poorly served by quick politician proclamations on the one hand and hundreds of pages of bureaucratic babble on the other. I will pass along your note and links to others who are looking at this more deeply than I am. I would certainly encourage you to be in touch with reporters covering the issue in Albany.
Pragmatic Environmentalist of New York 
