Ensuring Energy Efficiency Standards Support Beneficial Electrification

In 2015, New York set ambitious goals as part of the State Energy Plan to grow renewable energy, support energy efficiency and reduce greenhouse gas emissions.

On February 28, 2018, the New York Public Service Commission (“Commission”) instituted a proceeding to “consider issues related to energy efficiency targets and policy.” The Commission also noted that the Department of Public Service had been directed by Governor Cuomo to “engage stakeholders and to propose a comprehensive energy efficiency initiative by Earth Day, April 22, 2018.”

As the electric grid becomes cleaner through the growth of renewable energy, we can significantly reduce our greenhouse gas emissions by converting more of our appliances, vehicles, and heating and cooling to run on electricity rather than on-site burning of fossil fuels. This conversion is known as “environmentally beneficial electrification” or “strategic electrification” (“beneficial electrification”).

In the spirit of providing stakeholder feedback to inform the proposal scheduled for Earth Day, Renewable Heat Now submitted comments and recommendations related to the role that beneficial electrification can and should have in a comprehensive energy efficiency framework.

Read them here:  RHN Comments on NYS Energy Efficiency and Beneficial Electrification

Experts have analyzed the state and regional greenhouse gas reduction goals and concluded that it is impossible to meet them without widespread efficient electrification of our building heating and cooling needs. Heating and cooling in buildings represent 32% of New York State’s combustion-related greenhouse gas (GHG) emissions, and small, incremental efficiency improvements will not be enough.

Source: NYSERDA Renewable Heating and Cooling Policy Framework

To reduce greenhouse gases at the rate and scale necessary to meet the 2030 goals, New York must spur the widespread adoption of efficient geothermal and cold-climate air source heat pumps, which run on relatively small amounts of electricity to capture renewable heat from the ground and air. State policies must reflect the scale and urgency of the work necessary to make these conversions. In 2017, Jerry Acton of Physicians, Scientists, and Engineers (PSE) for Healthy Energy estimated that at least 126,000 fossil fuel heating systems will need to be replaced by heat pumps each year in order to meet a 40% reduction in greenhouse gases in the heating sector by 2030.

NYSERDA has taken steps to address this need by developing its Renewable Heating and Cooling Framework, consumer and installer incentives for heat pumps, and the Clean Heating and Cooling Communities program. These programs will assist building owners in converting to air-source and ground-source heat pumps for warming and cooling their homes. Additionally, the recently approved National Grid rate case includes a small program to further incentivize heat pump adoption.

But far more needs to be done. The energy efficiency framework for the state is one appropriate policy area through which the Commission can and should support the beneficial electrification necessary to meet our climate goals. The energy efficiency gains that heat pumps provide can and must be counted as the state sets targets, identifies responsible entities for meeting those targets, and develops programs for energy efficiency.

To meet NY’s goals, we need to account for all fuel uses in the state and aim for an overall goal of reducing them. Ultimately, electric utilities are key to this transition, as the ultimate source of energy to power almost everything will be electricity delivered through the an increasingly renewable grid. Therefore, we think enforceable utility targets for driving efficiency in all sectors and for all fuels are an appropriate and important plank of any comprehensive efficiency framework.

New York’s forthcoming Energy Efficiency initiative at a minimum should be structured so as not to discourage beneficial electrification. In developing the Earth Day proposal, we encourage the Department of Public Service to go beyond this minimum and put New York squarely on the leading edge of efficiency policy nationwide by establishing an efficiency policy that accounts for energy use and greenhouse gas emissions from all fuel sources, including those that are not currently metered, such as gasoline, heating oil, and propane.