The Regional Plan Association (RPA) respectfully submits this testimony in support of the New York Assembly’s efforts to advance building electrification.

RPA is an independent non-profit civic organization that develops and promotes ideas to improve the economic health, environmental resiliency, and quality of life of the New York metropolitan area. RPA conducts research on the environment, land use, and good governance, and advises cities, communities, and public agencies.

New York’s landmark Climate Leadership and Community Protection Act (CLCPA) set a new standard for state decarbonization policy. To meet its ambitious goals, the state must follow up with implementation policies that will create a just and orderly transition to clean energy in each sector of the economy. As NYSERDA’s Pathways Analysis and Carbon Neutral Buildings Roadmap make clear, for the buildings sector that means adopting policies that will drive investment in energy efficiency and electrification.

Three bills are pending that together can deliver an equitable and least-cost transition to efficient electrification: the Advanced Building Codes and Appliance Standards Act, the All-Electric Buildings Act, and the Gas Transition and Affordable Energy Act. In addition to decarbonizing the sector, efficiency and electrification will bring enormous health and economic benefits to New York. Energy efficiency already creates over 120,000 clean energy jobs in the state; findings by the Just Transition Working Group and a new analysis from Environmental Entrepreneurs (E2) show that building electrification could bring that figure to 400,000 jobs.

The sooner New York advances these policies the cheaper the clean energy transition will be. Every day the existing regulatory framework drives investment in gas equipment and infrastructure that will become a stranded asset.

These policies will also dispel the false notion that so-called renewable natural gas (RNG) or green hydrogen have a meaningful role to play in building decarbonization. This is true for 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 is at the very beginning of its cost curve.

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.