Roger Kayaza
New York City Local Law 97 (LL97) states, “Beginning in 2024, most buildings over 25,000 square feet must meet new energy efficiency and greenhouse gas emissions limits, with tighter limits set to take effect in 2030.” Rich Rich Ellenbogen explained that Local Law 97 data underestimated grid emissions by 39% to 47% and used incorrect emissions data to calculate penalties and serve as a basis for grid efficiency. This article is based on a series of emails from Ellenbogen.
Ellenbogen is president [BIO] Allied Converters frequently sends me emails addressing various issues related to the Climate Leadership and Community Protection Act (Climate Act). I've also published other articles by Ellenbogen, including a description of his energy keynote address at the New York Business Council's 2023 Renewable Energy Conference, titled: “On-demand energy is the lifeblood of business and entrepreneurship in the state – video here: Why New York The state must rethink its energy plans and ten recommendations to help solve the problem”. He is an engineer who truly cares about the environment and an early adopter of renewable technologies in his home and business twenty years ago in the 1990s.
Local Law 97
LL97 aims to reduce emissions from the city's largest buildings by 40% by 2030 and achieve net zero emissions by 2050. drama. Last July, I published an article here describing the assessment by Ellenbogen, Francis Menton, and myself that the supporting documentation for LL97 was woefully inadequate to provide any support for LL97 to New York City (NYC) residents in affected buildings. ensure. This means New York City’s winter heating is at huge risk. In this article, Ellenbogen documents the specific circumstances in which their numbers were wrong.
question
In this section, I will document criticism of Ellenbogen and reformat it from an email into a blog post.
LL97 uses the wrong metric to calculate carbon emissions. Contrary to what they claim, it increases the energy required to operate the building. 91% of the city's electricity is generated by fossil fuels. For the foreseeable future, all electric heat will be run from the least efficient fossil fuel power plants, with an efficiency of about 33%. After approximately 7% line loss, delivery efficiency to the building is 30%. Some remote power generation will use fuel oil, which has a greenhouse gas footprint that is 50% higher than natural gas and has higher emissions of nitrogen oxides, sulfur oxides and PM2.5. Even if the heat pump is 280% efficient, the overall efficiency is still 84%, which is at least 5% to 10% – 95% lower than just installing a new high-efficiency on-site gas-fired unit (net efficiency in the 90% range). Do they think long-range carbon emissions from buildings far away from New York won’t affect climate change?
Local Law 97 data underestimate grid emissions by 39% to 47%. By making the electricity system appear “greener,” they gave the entire law a false basis.
If you look at the chart below on page 36 (link) you will see in line 1 that they use 0.000288962 tCO2e per kWh (metric tons/kWh). Note that the file in the link cannot be downloaded, making it difficult to question its content. This value equals 0.288962 tCO2e per megawatt hour (MWh), which can be converted (0.288962 x 2203 pounds per metric ton) to 636.5 pounds per MWh, which is used as the basis for utility system emissions in LL97.
Source: §28-320.3.1.1 Energy Consumption Greenhouse Gas Coefficient
However, if you look at the table below from the US EPA, you'll see highlighted in yellow that the actual emissions for New York City and Westchester range from 886.6 pounds per megawatt hour to 973 pounds per megawatt hour. As a result, actual utility emissions are 39 to 47 percent higher than the emissions the city uses to calculate its policy values and associated penalties.
Source: EPA Summary: eGRID 2022 Summary Table, Abbreviation Table 1
Numbers used for future emissions are also an issue. The 636.5 lbs/MWh used in the LL97 document drops to 319 lbs/MWh from 2030 to 2034 (converted from the 0.000145 value listed in the excerpt below), which is half the 2024 value. It is known that all renewable energy installation numbers are being delayed, but there is no explanation of how they hope to achieve this. They start with numbers that are in their favor, are off by more than 40%, and then things get worse.
Source: 1 RCNY §103-14, Chapter 100 Subchapter C Building Maintenance, page 12.
The numbers used in the document to calculate regional steam emissions relative to gas emissions are similarly fanciful. New York City has a vast steam system with more than 100 miles of pipes carrying steam from central plants to buildings in Manhattan. An unacknowledged problem in LL97 is that there are substantial energy losses in the steam system. Due to the age and size of the system, they dump hot water at the end of the loop, the pipes leak (as exemplified by the iconic steam gush from the manhole), and they have miles of high-temperature steam pipes that consume energy before delivery, This can cause significant losses. Nonetheless, LL97's calculations indicate that district steam has a 15% lower greenhouse gas footprint than onsite gas combustion, which is 90% – 95% efficient. LL97 uses the following building emission assumptions taken from §28-320.3.1.1 Energy Consumption Greenhouse Gas Coefficients on page 36:
2) Natural gas 0.00005311 tons of carbon dioxide equivalent per kilowatt hour or 399 pounds of carbon dioxide equivalent per megawatt hour
5) Steam 0.00004493 tCO2e/KWh or 338 lb. CO2e/MWh
They are doing everything they can to make natural gas look bad.
Source: §28-320.3.1.1 Energy Consumption Greenhouse Gas Coefficient
Even more comical is the provision in Section 28-320.6.3, also reproduced below, regarding misrepresentations related to misreporting of emissions from buildings. What they mean is that the city can blatantly lie about their policies, but if you do they will fine you up to $500,000 and go to jail for 30 days.
Source: §28-320.3.1.1 Energy Consumption Greenhouse Gas Coefficient
in conclusion
Basically, whoever wrote the document was just pulling numbers out of thin air. This is completely fabricated. When you can easily find such blatant errors in the main part of a file, then anything contained within it cannot be trusted. Everything is distorted to justify someone's worldview and policy aspirations. Because of these erroneous numbers, New York City buildings will be saddled with technology that fails to generate emissions savings, resulting in higher operating costs in addition to huge upfront capital installation costs.
For those of us who have been analyzing this issue and understanding the numbers, it has been obvious for years that the entire policy in LL97 and the Climate Leadership and Community Protection Act was a fabrication. The numbers just prove it.
Roger Caiazza blogs about energy and environmental issues in New York at the Pragmatic Environmentalist of New York. This represents his opinion and not that of his previous employer or any other organization with which he is associated.
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