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Don’t raise the N.Y. HEAT Act: It threatens the safety of all New Yorkers

The New York Home Energy Affordable Transition Act, or NY HEAT, is before the Legislature now. However, until questions regarding its feasibility, affordability, and reliability are answered, the HEAT Act should be allowed to lay dormant.

The Climate Leadership & Community Protection Act (NYS’s climate law) mandates that the electric grid be 100% zero emissions by 2040, and the law’s scoping plan projects that by 2040 more than 60% of the capacity and more than 69% of the energy will come from wind and solar.

This total transformation of New York’s energy production and use is being undertaken in spite of the fact that no jurisdiction anywhere in the world has yet succeeded in raising the percentage of the supply of electricity to its grid from wind and solar — beyond about 50% of total supply — on a consistent basis.

The reason for these limits is because both wind and solar are intermittent and therefore unreliable. As a result of these realities, the state Public Service Commission is considering what new technologies must be developed to address those coldest and hottest periods where there will be insufficient generation from existing wind, solar, and energy storage technologies.

Unfortunately, there is no commercially available technology that can be deployed in sufficient quantities today for this reliability requirement. As a consequence of these facts on the ground (and in the air), it is prudent for New York’s decisionmakers to determine the technological feasibility of the zero emissions transition before passing NY HEAT.

The Empire Center’s recent Green Guardrails describes why the Climate Law implementation plan is flawed. It notes that “The process that has played out in the five years since the law’s passage has been marred by a lack of transparency, with state officials failing to issue legally required cost estimates and crucial studies designed to guide state energy policy.” Before the state passes NY HEAT, a full, transparent accounting of all the costs, benefits, and emission reductions for the proposed control strategies is necessary.

It is premature — and unquestionably dangerous — to mandate the additional electrification requirements of NY HEAT. The mandate to deploy massive amounts of wind, solar, and energy storage resources, and simultaneously upgrade and expand the distribution and transmission systems, means that an enormous quantity of transformers, wires, and generating equipment will be required.

There already is a shortage of transformers which will inevitably get worse and spread to other infrastructure components. Even if the hardware is available, there is insufficient labor to execute the plan. There is also a shortage of both electricians and plumbers, and there are not enough people to train even if they could develop the training programs. Without these new resources, current reliability standards of the electric grid cannot be maintained.

NY HEAT removes the “obligation to serve,” a regulation that requires utilities to offer natural gas to any customer who requests it; and the bill also enables the network to be decommissioned in favor of neighborhood-scale electrification. In addition, it will codify a goal of protecting residential customers from paying more than 6% of their household income for energy bills.

When NY HEAT eliminates the obligation to serve, and enables the decommissioning of existing gas systems, it eliminates consumer choice and does not acknowledge — as the state’s scoping plan to implement the Climate Law does — that not all homes will be able to electrify home heating safely and affordably.

A political mandate to decommission a gas network is a drastic step that should only be undertaken until the full ramifications of New York’s total energy transformation is understood. Otherwise, we risk jeopardizing the safety of all New Yorkers.

Lastly, the HEAT bill’s proposal to limit energy bills to no more than 6% of a household’s income is an inadequate energy poverty safeguard. It does not cover household costs: to replace existing home heating equipment with the preferred heat pump alternatives; to upgrade building shells to eliminate or minimize the time that backup heating systems will be needed; to pay for backup heating systems if needed; or to pay for the upgrades to the electric service for the household to cover the increased electric load when the entire household is electrified.

The shortcomings of the HEAT bill are to some extent a product of its authors’ faulty assumptions, but they are exacerbated by the even more unrealistic and unachievable goals built into the larger Climate Law. Until these issues are properly addressed, we should set aside the HEAT bill because it will simply make a bad situation worse.

Caiazza is a retired air pollution meteorologist. Ellenbogen is a former Bell Labs engineer who runs a decarbonized manufacturing business in Westchester.


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