Plans to Ban Natural Gas in NY

Everyone knows it's not smart to put all your eggs in one basket. You risk complete loss if something goes wrong with that basket. But that is exactly what New York State is planning to do with building electrification through its proposed ban on natural gas.

Recently, the Energy Efficiency and Housing Advisory Panel published "Preliminary Draft Proposal Recommendations Under Consideration" which lists several plans to ban future natural gas use in buildings (Fig. 1). No gas space heating or water heating in new construction. No gas space heating or water heating end-of-life replacements in existing buildings. No gas replacements for cooking or clothes drying appliances.  That's no gas allowed at all.

Figure 1. Page 13 of the Preliminary Draft Proposal Recommendations Under Consideration (1). Highlights added.

The Energy Efficiency and Housing Advisory Panel is a subcommittee of the Climate Action Council empowered by the ambitious New York Climate Leadership and Community Protection Act of 2019. The proposed gas bans are phased-in over the next 5 to 15 years in order to meet the Act's climate goals.

This command and control policy won't achieve the goals without serious unintended consequences. Consumers will rush to purchase and install gas technologies before the new bans take effect, undermining the purpose of the ban. Concurrent policies to increase the share of renewable wind and solar energy are being implemented, making electricity more expensive in NY. Importantly, relying solely on electricity for space heating puts NY residents in drafty buildings at risk from freezing during a blackout.

Such a shift in the way New Yorkers operate all their aging buildings in this short timeframe is improbable. Current technology being pushed comes in the form of all-electric ground-source heat pumps and cold climate air-source heat pumps. While these technologies are capable of providing comfortable interior environments in the context of holistic building design under normal operating conditions, they are expensive to install and maintain.

During the recent public comment period for the gas ban proposal, serious doubts were put forth regarding the functionality of alternative technologies in a variety of circumstances. Simply replacing gas burning furnaces and appliances with all-electric options may not work as intended. In the absence of super-insulated and tightly sealed building envelopes, heat pumps lose heat transfer efficiency in cold temperatures and need to run continuously. Their compressor oil needs to be heated by electric resistance to avoid mechanical failure. At extremely low temperatures, electric resistance backup heat is required, which is the least efficient and most expensive to operate. These factors put a greater load on the electric grid when it's needed most, increasing the risk of catastrophic failure and expense of operation. Heat pumps may not be able to keep up in some extreme conditions, such as a polar vortex, which climate models increasingly forecast.

A better policy approach is to continue to provide market incentives to encourage those who want and can afford all efficient technologies, including gas combined heat and power systems and climate-negative biofuels, to install them more easily. Funding research and development for future innovative solutions, such as better performing refrigerants, should be increased in an effort to make our buildings and energy systems better. 

~ Mark Bremer, Green Explored contributor

(1) Energy Efficiency and Housing: Public Engagement Session presentation, February 4, 2021. https://climate.ny.gov/-/media/CLCPA/Files/2021-02-04-EEH-Public-Engagement-Session.pdf