Roger Caiazza

New York City Local Law 97 (LL97) mandates that “most buildings over 25,000 square feet are required to meet new energy efficiency and greenhouse gas emissions limits as of 2024, with stricter limits coming into effect in 2030.”  Rich Ellenbogen explains that the numbers underpinning Local Law 97 underestimate electric grid emissions by between 39% and 47% and uses incorrect emissions numbers to calculate the penalties and as a basis for electric grid efficiency.  The basis of this article is a series of emails from Ellenbogen. 

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”.  He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

Local Law 97

The goal of LL97 is to reduce the emissions produced by the city’s largest buildings 40 percent by 2030 and net zero by 2050.  Like New York’s Climate Leadership and Community Protection Act (Climate Act) this is political theater without regard to practicality.  Last July I published an article here that described an evaluation by Ellenbogen, Francis Menton, and myself that the supporting documentation for LL97 falls far short of what is needed to provide New York City (NYC) residents in affected buildings with any assurance that the LL97 mandates can be met at the same time the Climate Act is transforming the electric energy system with massive deployments of wind, solar, and energy storage and unproven generating resources.  This means extraordinary risks for keeping the heat on in the winter in NYC.  Ellenbogen documents specific instances where their numbers are wrong in this post.

Problems

In this section I am going to document Ellenbogen’s criticisms re-formatted from an email to a blog post.

LL97 uses false metrics to calculate carbon emissions.  Contrary to what they claim, it increases the amount of energy required to run a building.   The city’s electricity is 91% fossil fuel generated.  For the foreseeable future, all electric heat will operate from the least efficient fossil fuel plants operating with about a 33% efficiency.   After about a 7% line loss, that is 30% efficient delivered to the building.   Some of the remote generation will be oil fired with a 50% higher GHG footprint than natural gas and higher NOx, SOx, and PM2.5 emissions.   Even if the heat pumps are 280% efficient, that leaves a holistic efficiency of 84%, which is at least 5% – 10% lower than just installing a new high efficiency onsite gas combustion that will operate with a net efficiency of between 90% – 95%.  Do they think that remote carbon emissions away from NYC buildings won’t affect climate change?  

The numbers underpinning Local Law 97 are underestimating electric grid emissions by between 39% and 47%.  By making the electric utility system look “greener” they are providing a false basis for the entire law.

If you look at the image below, taken from page 36 (link), you will see in clause 1 that they are using 0.000288962 tCO2e per KWh (metric tons/Kwh).  Note that the document at the link cannot be downloaded which makes it very difficult for people to challenge the contents.  That 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 that is used as the basis for utility system emissions in LL97.

Source: §28-320.3.1.1 Greenhouse gas coefficient of energy consumption

However, if you look at the table below from the US EPA, highlighted in yellow are the actual emissions that are between 886.6 pounds per MWH and 973 pounds per MWh in NY City and Westchester. So the actual utility emissions are between 39% and 47% higher than what the city is using to calculate their policy values and the associated penalties.

Source: EPA Summary Data: eGRID 2022 Summary Tables, abbreviated Table 1

The numbers used for future emissions are also a problem.  The 636.5 pounds per MWh used in the LL97 document drops to 319 pounds/MWh in 2030 – 2034  (converted from 0.000145 value listed in the excerpt below) which is half of the 2024 value.  There is no explanation of how they expect to achieve that when it is common knowledge that all of the renewable installation numbers are being pushed back.  They are starting from numbers that err in their favor by over 40% and it just gets worse from there.

Source: 1 RCNY §103-14, CHAPTER 100 Subchapter C Maintenance of Building, page 12.

The numbers used to calculate the district steam emissions relative to the gas emissions in the document are just as big of a fantasy.  New York City has an extensive steam system with over 100 miles of pipe that bring steam from central plants to buildings in Manhattan. The unacknowledged problem in LL97 is that there are extensive energy losses in the steam system. Because of the age and size of the system they are dumping the hot water at the end of the loop, the pipes leak (as exemplified by the iconic steam puffs coming out of manholes), and they have miles of high temperature steam lines dissipating energy before it ever gets delivered so there are significant losses.  Nevertheless, LL97 calculations claim district steam with a 15% lower GHG footprint than 90% – 95% efficient on-site gas combustion.  LL97 uses the following assumptions for building emissions  taken from §28-320.3.1.1 Greenhouse gas coefficient of energy consumption  page 36:

2) Gas      0.00005311 tCO2e per KWh or 399 lb. CO2e per MWh

5) Steam   0.00004493 tCO2e per KWh or 338 lb. CO2e per MWh

They are doing everything in their power to make gas look bad.

Source: §28-320.3.1.1 Greenhouse gas coefficient of energy consumption

Even more comical is the clause in section 28-320.6.3 which is also copied below regarding false statements which is meant to pertain to buildings misreporting their emissions.   What they are saying is that it is okay for the city to outright lie on their policies but they will fine you up to $500,000 and put you in jail for 30 days if you do it.

Source: §28-320.3.1.1 Greenhouse gas coefficient of energy consumption

Conclusion

Basically, whoever wrote this document is just pulling numbers out of thin air.  It is a total fabrication. When you can easily find such flagrant errors in major parts of the document, nothing that is contained in it can be trusted.  Everything has been skewed to justify someone’s worldview and policy desires.  Because of these false numbers, buildings in NY City are going be saddled with technologies that don’t produce emission savings and will simultaneously result in far higher operating costs, besides having huge upfront capital installation costs.

For those of us who have been analyzing this and understand the numbers, it has been apparent for years that the entire policies, both in LL97 and the Climate Leadership & Community Protection Act were fabrications.  These numbers just prove it.

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other organization with which he has been associated.

By Jo Nova

Finally, twenty years too late, Australian leaders are talking about the galactic cost of making a spare energy grid that might, maybe, hopefully one day reduce world temperatures by one thousandth of a degree. Sadly they are still not talking about why that’s a pointless quest, why CO2 feeds the poor, warmth is good, humans emissions are irrelevant, or how science has become a turgid swamp patrolled by dead sacred cows. But it’s a start!

It’s a trifecta: Our car-crash energy bills, the revolution of common sense in the US, and the appearance of our own election on the horizon have set off the Air-raid sirens to wake a sleeping nation.

It’s only half a trillion dollars

The Minister for Energy says the cost of renewables by 2050 will be $122 billion (AUD). Not convinced, the Opposition commissioned a study that estimates it’s more like $650 billion. But what’s a half a trillion dollars when you have hope, faith, and a fantasy to make storms a bit nicer? It’s a horror show. The Labor Government wants every family of four to spend something like $100,000 on their wind and solar vision over the next 25 years. There goes the house deposit, the uni fees, the family holidays. There goes our lifestyle.

Australian energy is twice the price

Things are so bad here in Renewable Crash Test Dummy World, that the CEO of Glencore said Australian energy costs twice as much in the US, Canada, China and India. Glencore, is the largest coal miner in Australia, the fifth largest miner in the world, and employs about 140,000 people.  Gary Nagle went on to tell the Daily Telegraph  that Australia has a bad attitude:

He argued that the negative attitude to coal in Australia was increasingly out of step with other parts of the world.

“Many stakeholders globally are now taking a more pragmatic view about coal,” Mr Nagle said.

It’s such a first world problem. Imagine being the world’s largest coal export nation every other year, and spending billions to undermine one of your two largest industries? How did we get here, standing on a plank, sawing the ship off?

Tricked by “free energy” scam

The electricity-fashion-queens chased a vision of fairy-energy so they could win cat-walk parades at the UN, but lose in every other race that matters. The wind and sun appear to be free, but cost us the Earth to collect, and the Universe to store.

All the politicians had to do was get scientists and engineers to debate in public and they would have realized that they can’t keep electricity in a shoe-box, or post it from the Simpson Desert to Sydney harbor. Instead, they employed the yes-men who agreed with the vision, and sacked or silenced 1,000 engineers who could have told them it was stupid.

That, and they all watched the ABC:

Robert Gottleibsen, The Australian

Since Federation, Australian ministers on both sides of the parliament have made major mistakes and misleading statements. But nothing in our history matches the looming renewable energy conversion financial disaster.

The Bowen calculations are based on “net present value”, or NPV, which involves calculating the final cost and adjusting it back to the current dollars. But commercial infrastructure projections work on what will actually be outlaid. Frontier have now done those outlay calculations to 2050 for the governments and now the public.

And of course, by 2050 all the windmills and sacred glass panels will be due to expire and we will need to find a very big hole to bury them in, and start again with the fire-hose from the bank account spraying direct to China.

The only hope, as Gottleibsen says, is if the protests from farmers and country towns have glued up the plans enough that we can pull the pin before we sink any more into it.

It only makes sense if imaginary “carbon credits” had some value:

So, the state and federal governments devised a system which I would call “rigging the books”. But they would justify it by saying carbon savings had a value which must be counted in the project.

And so, a transmission network hypothetically costing $100m would be given a carbon credit, which would reduce its “cost” substantially and justify investment. Frontier calculates that some $80bn of the $650bn came from these carbon credits.

And this half a trillion doesn’t include half the country (the Western half and the Northern Territory). That price can only rise.

Despite the blockbuster costs, Frontier Economics have almost certainly underestimated the true cost of converting Australia into a third-world nation. Not only are frozen peas harder to afford, but so is every kind of factory, machine, storage or computation. Like a de facto law of physics — expensive electricity repels jobs, industries, money and smart people.

From CLIMATE DEPOT\

By Marc Morano

https://www.politico.eu/article/argentina-mulls-paris-climate-agreement-exit-with-trump

Argentina mulls Paris climate agreement exit with Trump –

President Javier Milei met with Trump overnight as both countries explore leaving the landmark 2015 accord.

BAKU, Azerbaijan — Argentina is weighing an exit from the Paris Agreement, joining the U.S. President-elect Donald Trump in reconsidering the global climate deal.

“We’re reevaluating our strategy on all matters related to climate change,” the country’s foreign minister, Gerardo Werthein, told The New York Times, adding that the country had fundamental doubts about what is driving climate change. The Washington Post also reported the news, citing an unnamed government official.

Argentina withdrew its delegation this week from the COP29 climate talks in Baku, Azerbaijan, just days into the two-week summit. Werthein told the Times no final decision had been made about the 2015 Paris accord, but noted Argentina was reconsidering participating in a deal that “has a lot of elements.”

“We decided to withdraw our delegation and reevaluate our position, nothing more,” Werthein said. “I think it’s a sovereign right.”

The Argentinian embassy in Baku did not respond to a request for comment.

Argentinian President Javier Milei has described climate change and the international effort to contain it as a “socialist lie.”

On Thursday, he met with Trump at the incoming president’s Mar-a-Lago club in Florida. Milei was the first head of state Trump received in person since winning the Nov. 5 election.

During his campaign, Trump said he would withdraw the United States from the Paris deal. The U.S. left briefly during Trump’s first term. But no other countries followed.