The mathematics behind New York Metropolis's Municipal Legislation 97 doesn't add up – does it?
Roger Caiazza
New York City Local Law 97 (LL97) requires “most buildings over 25,000 square feet to meet new energy efficiency and greenhouse gas emissions limits beginning in 2024, with stricter limits taking effect in 2030.” Rich Ellenbogen explains the numbers , which underlies Local Law 97, underestimates electricity grid emissions by 39% to 47% and uses incorrect emissions figures to calculate penalties and as a basis for use the efficiency of the power grid. The basis of this article is a series of emails from Ellenbogen.
Ellenbogen is the president [BIO] Allied Converters and frequently copies me in emails dealing with various topics related to the Climate Leadership and Community Protection 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 entitled: “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 offer ten suggestions to solve the problems.” He comes to the table as an engineer who truly cares about the environment and as one of the early adopters of renewable technologies, reaching the 1990s, both in his home and in his business two decades ago.
Local Law 97
LL97's goal is to reduce emissions from the city's largest buildings by 40 percent by 2030 and to net zero by 2050. Like New York's Climate Leadership and Community Protection Act (Climate Act), this is political theater with no regard for practicality. Last July, I published an article here describing an assessment by Ellenbogen, Francis Menton, and myself that the supporting documentation for LL97 is far from sufficient to provide reassurance to New York City (NYC) residents in affected buildings indicate that the LL97 mandates can be met while the climate law transforms the electrical energy system through the massive use of wind, solar and energy storage as well as untested generation resources. This poses extraordinary risks to sustaining winter heat in NYC. In this article, Ellenbogen documents specific cases in which her numbers are incorrect.
problems
In this section, I will document Ellenbogen's criticism, reformatted from an email into a blog post.
LL97 uses incorrect measurements to calculate CO2 emissions. Contrary to their claims, this increases the energy required to operate a building. 91% of the city's electricity is generated from fossil fuels. In the foreseeable future, all electric heat will be generated by the least efficient fossil fuel power plants, which have an efficiency of around 33%. After a line loss of around 7%, this equates to 30% efficiency being delivered to the building. Some remote power generation is oil-fired, which has a 50% higher greenhouse gas footprint than natural gas and higher NOx, SOx and PM2.5 emissions. Even if the heat pumps are 280% efficient, that leaves an overall efficiency of 84%, which is at least 5% to 10% less than just installing a new high-efficiency gas burner on site that operates at a net efficiency of between 90%. – 95%. Do they believe that remote carbon emissions outside of New York City buildings will have no impact on climate change?
The figures underlying Local Law 97 underestimate electricity grid emissions by 39% to 47%. By making the power system look “greener,” they provide a false basis for the entire law.
If you look at the image below from page 36 (link), you can see in section 1 that they use 0.000288962 tCO2e per KWh (metric tons/Kwh). Note that the document at the link cannot be downloaded, making it very difficult for others to dispute its contents. This value is equivalent to 0.288962 tCO2e per megawatt-hour (MWh), which can be converted to 636.5 pounds per MWh (0.288962 x 2203 pounds per metric ton), which 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, the actual emissions are highlighted in yellow, which range from 886.6 pounds per MWH to 973 pounds per MWh in NY City and Westchester. So actual utility emissions are between 39% and 47% higher than what the city uses to calculate its policy levels and associated penalties.
Source: EPA summary data: eGRID 2022 summary tables, abbreviated table 1
The figures used for future emissions are also problematic. The 636.5 pounds per MWh used in the LL97 document drops to 319 pounds/MWh in 2030-2034 (converted from the 0.000145 value shown in the excerpt below), which is half the 2024 value. There is no explanation as to how they plan to achieve this when it is well known that the number of renewable energy installations is being reduced. They're going with numbers that are more than 40% off in their favor, and it just gets worse from there.
Source: 1 RCNY §103-14, CHAPTER 100 Subchapter C Maintenance of Buildings, page 12.
The numbers used in the document to calculate the county's vapor emissions relative to gas emissions are also a fantasy. New York City has an extensive steam system with over 100 miles of pipes carrying steam from central power plants to buildings in Manhattan. The unconfirmed problem in LL97 is that there is significant energy loss in the steam system. Due to the age and size of the system, they drain the hot water at the end of the circuit, the pipes are leaky (as evidenced by the iconic bursts of steam from the manholes), and there are miles of high temperature steam pipes that use up energy before it's even delivered, so it significant losses occur. Nevertheless, LL97 calculations estimate that district steam has a 15% lower greenhouse gas footprint than 90-95% efficient on-site gas combustion. LL97 uses the following assumptions for building emissions 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 pounds CO2e per MWh
They do everything in their power to make the gas look bad.
Source: §28-320.3.1.1 Greenhouse gas coefficient of energy consumption
Even stranger is the clause in Section 28-320.6.3, also copied below, which refers to misstatements intended to refer to buildings misreporting their emissions. What they're saying is that it's okay for the city to completely lie about its policies, but they will fine you up to $500,000 and put you in jail for 30 days if you do .
Source: §28-320.3.1.1 Greenhouse gas coefficient of energy consumption
Diploma
Basically the author of this document just pulled numbers out of thin air. It's a total invention. If you can easily find such obvious errors in large parts of the document, nothing contained in it can be trusted. Everything has been distorted to justify a person's worldview and political desires. Because of these false numbers, buildings in New York City are being equipped with technologies that provide no emissions savings while incurring far higher operating costs, in addition to huge upfront capital costs.
For those of us who have analyzed this and understand the numbers, it has been obvious for years that the entire policies, both in LL97 and the Climate Leadership & Community Protection Act, were fabricated. These numbers simply prove it.
Roger Caiazza blogs about New York energy and environmental issues at Pragmatic Environmentalist of New York. This represents his opinion and not the opinion of any of his former employers or any other organization with which he is associated.
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