For decades, activists in New York and our surrounding region have loudly opposed the construction of new gas pipelines and the process of fracking that feeds them. But climate advocates long accepted gas because it displaced more-polluting fuels – coal in power plants and heating oil in buildings. Today it is simply not feasible to reduce pollution 50% by 2030 and reach net zero emissions by 2050, as scientists and even the federal government say we must, if we don’t significantly accelerate our transition away from gas.
That transition may take 30 years, but it has started in earnest in New York State and New York City, both of which are banning gas in new buildings. The moves haven’t made national headlines, but they should. They signal a major transformation towards electrification and the end of the road for gas in buildings.
Power
In New York, the power sector’s transition to zero carbon electricity is well mapped. The Climate Leadership and Community Protection Act (CLCPA) sets out specific benchmarks, including 100% zero-carbon electricity by 2040, 70% renewable electricity by 2030 and individual requirements for offshore wind, distributed solar, and energy storage.
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The Public Service Commission (PSC) has updated the state’s Clean Energy Standard, creating an enforceable mandate to meet targets, the New York State Energy Research & Development Authority (NYSERDA) has entered into contracts for utility-scale solar, land-based wind, and offshore wind to secure those resources, and the state overhauled the siting process for both renewables and transmission in order to expedite deployment. While there may still be a role for gas (with carbon capture) or substitute gaseous fuels (renewable natural gas or hydrogen) in this sector, the Department of Environmental Conservation has determined that new fossil gas plants are inconsistent with CLCPA mandates and rejected two longstanding proposals to replace or repower existing power plants.
Transportation
The transition to a clean transportation sector is also well understood. While there are a few modes of transport that are harder-to-electrify, such as heavy trucks, shipping and airplanes, the industry is largely shifting to electric vehicles. Automakers have set end dates for the manufacture of vehicles with internal combustion engines as early as 2035.
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New York is ending sales of internal combustion light duty vehicles in the same timeframe, has adopted the Advanced Clean Truck rule mandating the sale of zero-emission trucks, committed to electrifying city bus fleets, the state light duty vehicle fleet and school buses, and launched the “Make-Ready” program to build out the needed charging infrastructure.
Buildings
The buildings sector is a different story. Neither the real estate industry nor the utilities have set end dates for fossil fuels in buildings. The CLCPA included an energy savings mandate, but did not provide any other direction on how to decarbonize buildings, which are now the state’s largest source of GHGs, representing 32% of statewide emissions.
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The uncertain course for building decarbonization led, in part, to the two 2019 moratoria on new gas connections, which prevented families and businesses in parts of New York City from turning the gas back on after renovating property, causing major complications – the opposite of a just and orderly transition. Utilities argued that they could not add gas connections without approval of new pipelines to increase supply.
At that time, there was a broad understanding among policymakers and the general public – in New York and beyond – around the shift to renewable electricity and electric vehicles, but few had heard about electric heat pumps or induction cooking. In 2019, decisionmakers hadn’t gotten the memo that if they didn’t want pipelines, and if they wanted to avoid catastrophic climate impacts, they would need to adopt policies that would drive electrification of building heating systems and transition off of gas.
Well, they’ve read that memo now. Fast forward two years and it’s New York City and New York State that are adopting not just moratoria, but permanent bans on new gas hook-ups, this time with sufficient time to ensure that clean, efficient electric technologies will be there when we need them without increasing the energy burden for low-and-moderate-income New Yorkers.
In December, thanks to the leadership of Council Members Jim Gennaro (who shepherded the bill to passage, making critical improvements along the way) and Alicka Ampry-Samuel (the original sponsor), the City enacted “Gas Free NYC,” which will effectively ban gas in new construction – for small buildings, starting in 2024, and for all new buildings by 2027.
Governor Kathy Hochul promised to follow suit in her State of the State, committing to require new buildings to be fully electric by 2027. She also committed to electrify (or make electrification-ready) two million homes, including more than 800,000 low-to-moderate-income households, all of which serve to operationalize NYSERDA’s Carbon Neutral Buildings Roadmap and the Climate Action Council’s Draft Scoping Plan. Notably, the Governor also pledged to level the playing field for clean energy and eliminate the law that requires utilities to provide gas service to new customers upon request. The law also requires utilities to socialize the cost of expanding service, forcing all customers to pay for new gas infrastructure regardless of whether it is needed, even if it is diametrically opposed to the clean energy economy mandated by other state laws.
These policies primarily implicate new construction, but make no mistake, they mark only the first set of “end dates” for fossil fuels in buildings.
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Here is a look at Gas Free NYC and the elements that make it so transformative. Stay tuned for a similar look at emerging state policies.
What it does:
Sets a limit on carbon dioxide emissions that effectively prohibits the combustion of gas (or other fossil fuels) in new buildings, starting with low-rise buildings in 2024 and covering all buildings by 2027. Urban Green Council provides an excellent summary of the law here.
Why it matters:
Demand for Gas Will Now Decrease, Ending Any Justification for New Pipelines
Utilities justified the gas moratoria by claiming they could not meet projected demand growth without a new pipeline to provide additional supply. Since new appliances, equipment, replacement windows and weatherization investments steadily improve energy efficiency in existing buildings, those buildings are steadily reducing their consumption of gas. All projected demand growth is from new construction, and from new customers converting from home heating oil and propane to gas. Gas Free NYC takes most of that justification off the table. While conversions from oil and propane to gas are still possible, new policies from the state, which (unlike the City) has jurisdiction to ban new gas hook-ups altogether, could completely eliminate any justification for new pipelines.
Renewable Electricity
Renewable Electricity Is now the clear path for building decarbonization, not renewable natural gas or green hydrogen.
The NYC gas ban is structured as an emissions standard because the City does not have the legal authority to ban new gas connections directly. The original version of the bill set that standard at 50 kg/MMBtu, only slightly below that of gas (53kg/MMBtu), making it possible to comply by blending a small amount of renewable natural gas (RNG) into the gas distribution system – a loophole big enough to drive a gas pipeline through. Council Member Gennaro lowered the standard to 25kg/MMBtu in the final version, preserving the integrity of the law.
RNG is methane captured from landfills, wastewater management facilities or agricultural waste, in contrast to conventional fossil gas which is extracted from underground. Because the captured methane would otherwise be flared or emitted into the atmosphere, and because methane is such a potent greenhouse gas (80 times worse than carbon dioxide), replacing conventional gas with RNG, which can be injected directly into the gas distribution system, can have a substantial climate benefit.
So why isn’t RNG a great solution for buildings?
Putting aside environmental and public health concerns about some potential RNG feedstocks, such as forest crops, there are several reasons:
There is not enough RNG to meaningfully displace gas. According to an ICF analysis commissioned by NYSERDA, the maximum RNG potentially available to New York is less than 7% of current gas demand, and would cost $11 to $50/MMBtus, substantially above the price of conventional gas. Even the gas industry’s own analysis puts the total RNG potential figure at between 12% - 28% of current gas use.
We need to deploy RNG in hard-to-electrify applications. According to NYSERDA’s Pathway’s analysis, the least cost decarbonization path for buildings is overwhelmingly a shift to electricity; RNG plays a de minimus role. NYSERDA’s model deploys the limited RNG resource to harder-to-electrify applications in all sectors of the economy.
RNG is a bridge to nowhere. Some have argued that RNG is a stop-gap measure that can reduce building emissions now, and later be replaced and supplemented with plentiful green hydrogen. Putting aside the cost and commercial viability of green hydrogen, it is unlikely that the existing gas distribution system can support a blend of more than 5-15% hydrogen without “hydrogen embrittlement,” which weakens pipe, increasing leakage and safety risks. Extensive use of green hydrogen will likely require the construction of new pipeline infrastructure and all new equipment for hydrogen combustion, it doesn’t mitigate the problem that any new conventional gas infrastructure will become a stranded asset.
What about Green Hydrogen? “Green” hydrogen is hydrogen manufactured from renewable electricity, as opposed to “blue” and “grey” hydrogen, which are made from conventional gas. It is premature to say whether New York will have “excess” renewable electricity from which to generate green hydrogen; indeed industry players frequently state that it will take herculean efforts just to meet New York’s renewable electricity mandates, much less exceed them. We can’t have both too much and not enough renewable electricity. As with RNG, NYSERDA’s modeling directs green hydrogen to hard-to-electrify applications, not buildings. On the cost front, in addition to the cost of constructing entirely new infrastructure (pipelines and equipment), green hydrogen would have to be about $2/g to be cost-competitive with today’s gas prices. While some project that green hydrogen will be available at that price by 2050, today the cost is 150% to 300% higher; the technology is not yet commercial and at the very beginning of its cost curve.
Electrifying Buildings Now Will Reduce Pollution; No Need to Wait for More Renewables
As noted above, the CLCPA requires the state to transition to 70% renewables and 100% carbon free electricity, and the CES provides the legally enforceable mechanism to ensure utilities meet these targets. New York still has many gas-fired power plants in operation – they generate 30% of the state’s electricity. But because modern electric heating equipment is so efficient, and because New York relies overwhelmingly on low- or zero-carbon sources of electricity (nuclear, hydropower and renewables), the emissions associated with efficient electric heat are lower than gas today. An excellent analysis from Urban Green illustrates this fact in detail.
Heat pumps installed in New York will reduce emissions now. In contrast, any gas infrastructure installed today is likely to become a stranded asset, since such investments are usually paid off over a period of 80 years, and the CLCPA will render almost all fossil fuel assets obsolete in fewer than 30 years. Every new building with fossil fuel infrastructure is a building that will require a retrofit within 30 years.
Utilities Can Be Part of the Solution; Con Edison Breaks Ahead of the Pack
With the notable exceptions of Con Edison (who supported Gas Free NYC and whose most recent gas rate plan does not propose system expansion) and Pacific Gas & Electric, utilities have been touting an “all of the above” strategy for building decarbonization, in hopes that they can continue to make full use of their gas distribution systems by decarbonizing the fuel that runs through them, rather than transitioning to electric heat. Even combined electric and gas utilities, whose gas customers will leave the gas system only to become larger electric customers, essentially allowing them to eat their own lunch, have been unwilling to face the prospect of decommissioning large portions of the gas distribution system and the risk that their shareholders will have to cover the cost of stranded assets – the portion of the system that retires before it’s been entirely paid for.
This is a short-sighted view. Electrification is where the building industry is going. Even under the rosiest scenarios for RNG and green hydrogen, much of today’s gas distribution system will be retired (or possibly repurposed for such uses as running fiber optic cable). Utilities can and should be major players in the decarbonization of the building sector, but the longer they adhere to the status quo the less welcome they will be in the clean energy marketplace.