NY Times Coverage of Building Electrification Should Spur Scrutiny Of NJ Gov. Murphy’s Energy Master Plan
Murphy Energy Plan Vague – Postpones New Building Codes Until 2030
We are in a climate emergency and face existential risks. You don’t ask how much the fire engine costs when the house is burning down. The IPCC scientists recently warned we have about a decade to make deep reductions.
Calling it a “Movement”, the NY Times ran an important story today on proliferating efforts by local governments to adopt new building codes to mandate electrification of buildings as a key climate strategy to decarbonize the economy, see:
They say that the NY Times sets the agenda, so let’s hope that NJ media follows the lead of the Gray Lady and does some in depth substantive reporting on the building sector policies of the highly touted NJ Gov. Murphy Energy Master Plan (EMP).
In this post, we’ll guide reporters and readers to where to find the skeletons.
The Murphy Board of Public Utility’s Integrated Energy Plan (IEP) is the technical (quantitative, modeled) basis for the BPU’s Energy Master Plan (EMP).
So, in order to tease out the substantive reality behind the rhetorical facade, we must engage in a careful dance between the IEP’s quantitative modeled future energy and emissions “scenarios” and the policy rhetoric of the Energy Master Plan (EMP). These IEP “scenarios” reveal major weaknesses in what are often vague and non-committal policy statements in the EMP.
The first place to look – which provides smoking gun data that exposes the language and spin of the EMP – may be found a document known as the “Integrated Energy Plan” (IEP) (Nov. 2019 webinar summary). Here’s Gov. Murphy’s Office on the role about the IEP:
- The Integrated Energy Plan (IEP) will identify the most economically beneficial and least-cost pathways to achieve state goals
- The modeling analysis will help to prioritize the timing, pace, and scale of achieving our objectives
The “final scenarios” of the IEP on page 14 are revealing (you may need to hit the link to the document, because the print below is very small):
Look at the “least cost” plan (the 3rd column from the left) – which is the preferred plan and basis for the Murphy EMP – and down to the third row, “Building Electrification”.
You will note the following key goals and timetables:
- Building retrofits – 90% by 2050 – rapid adoption in 2030
- Delivered Fuels – Transition to electric starting in 2030
Did you get that?
If you didn’t get it, here’s more specific language from the EMP, that specifically cross -walks the IEP modeled scenarios with the EMP policies:
.. the [IEP] scenarios assumed that buildings BEGAN to be retrofitted and electrified aggressively STARTING in 2030, so that 90% of building water and space heating was powered by electricity in 2050.” Murphy Energy Master Plan, @ p.159
So let’s repeat: While the NY Times writes about cities across the country who have already adopted building codes to mandate electrification, the Murphy Energy Master Plan is assuming that those building codes will not be adopted and implemented and will have no impact on greenhouse gas emissions for over a decade, until after 2030.
Cliche: too little, too late.
Now let’s compare the IEP’s modeled “scenarios” regarding building electrification with the relevant data and policy text of the EMP.
According to the EMP, buildings are a major source of greenhouse gas emissions:
The building sector accounts for a combined 62% of the state’s total end-use energy consumption. Given this, the building sector should be largely decarbonized and electrified by 2050 with an early focus on new construction and the electrification of oil- and propane- fueled buildings. (@ page 12)
Here are the relevant goals and strategies from the EMP –
As you consider them, ask “who, what, when and how” on each of these EMP goals and strategies.
Be sure to keep the 2030 and 2050 numeric goals and timetables of the IEP on electrification of buildings in mind that I just highlighted above.
First note that the EMP does not specify or make time bound commitments to adopting enforceable regulatory building codes that are highlighted in the NY Times story.
Then note that the EMP uses evasive and “flexible” weasel words – which lack quantification and deadlines and specific administrative implementation tools and bureaucratic responsibilities – terms like “strengthen”, “advocate for”, “establish”, “mechanisms” (which are distinguished from “regulations”), “start”, “develop”:
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3.3 Strengthen building and energy codes and appliance standards
3.3.1 Advocate for net zero carbon buildings in new construction in the upcoming 2024 International Code Council code change hearings
3.3.3 Establish mechanisms to increase building effciency (sic) in existing buildings
4.1 Start the transition for new construction to be net zero carbon
Goal 4.1.4: Study and develop mechanisms and regulations to support net zero carbon new construction.
4.1.5 Develop electric vehicle-ready and demand response-ready building codes for new multi-unit dwellings and commercial construction
OK, now lets close with equally troubling text of the building electrification policies from the EMP. Since we’ve already mentioned the lack of specific language and the contrast with the numeric assumptions of the IEP, I’ll highlight a few points of criticism:
A major flaw is that they are based on “cost effectiveness”.
“Cost effectiveness” ignores and is NOT based on climate science. Period. Full stop.
We are in a climate emergency and face existential risks. You don’t ask how much the fire engine costs when the house is burning down. The IPCC scientists recently warned we have about a decade to make deep reductions.
Here’s some relevant text from the EMP regarding cost effectiveness:
Goal 4.1.4: Study and develop mechanism
State regulations enable the New Jersey Department of Community Affairs (NJDCA) to establish energy codes that are more aggressive than those set in the International Energy Conservation Code (IECC). However, to enable NJDCA to adopt codes above the national standards, an institution of higher education must be able to establish expected payback within a seven-year period for the desired energy conservation measures to justify the increased capital costs.lxiii The state should study various zero carbon construction methodologies, evaluate payback time periods, and implement into construction codes those that meet the seven-year payback requirement.
Several national studies from leading authorities such as Lawrence Berkeley National Laboratory and Rocky Mountain Institute have shown that building electrification in new construction can be cost effective, even compared to natural gas.
First of all, those NJ State regulations that the EMP relies on as an excuse for delay could be changed immediately by Gov. Murphy via an Executive Order declaring an emergency, which would authorize DCA to conduct expedited emergency rule making.
These new DCA rules could eliminate or reduce the role of a “study”, which serves as a barrier to stricter NJ standards (e.g. downplay the role of costs, mandate that the costs address climate impacts and the social cost of carbon, extend the payback period, set a 0% interest rate to reflect intergenerational equity, demand adherence to scientific recommendations on deep emission cuts and timetable for action, account for uncertainty, et al). DCA could even abandon the need for a study and adopt the best technology available, irrespective of cost and payback periods.
Here’s a Trifecta of weasel words and cost effectiveness:
Based on results of [Rutgers] analysis .. NJDCA should CONSIDER adopting new regulations GUIDING developers to clean energy technologies that have been shown to be COST EFFECTIVE, establishing a pathway for NJ to electrify the building sector” (p. 165)
Second – aside from the fact that “guiding developers” is not “regulating” them via building codes and retrofit requirements – the cost of natural gas is an arbitrary and flawed baseline for comparing alternatives and/or deriving cost effectiveness, as natural gas prices fail to include “external costs”, including climate impacts and risks. As I’ve written, this is a HUGE market failure.
This failure to incorporate climate science and remedy the economics of market failure is a structural and fatal flaw of the IEP and EMP, as is the failure to reflect the aggressive timetables and radical emissions reductions that are called for by the current best available science and the warnings of climate scientists.
Third, the concept of “cost-effectiveness” is highly manipulable and inherently flawed. The concept raises major technical, ethical and justice concerns, from the commodification and monetization of human life and ecosystems, to an overwhelming and misleading focus on costs, to an inability to quantify benefits, to the discounting of future events and harms to future generations, and to the distribution of economic burdens and benefits.
Fourth, note that this cost effectiveness study will be conducted by Rutgers and there is no mention of any public process for deriving this critical determination or assuring transparency and peer review:
NJBPU, in partnership with NJDCA, has contracted with Rutgers University to develop 10-year energy price projections and seven-year cost recovery projections for a number of building electrification techniques and electricity generation techniques, including the installation of electrified heat pumps, electrified water heaters, rooftop solar panels, and solar thermal water heaters.
Based on the results of the analysis, expected in late 2020, NJDCA should consider adopting new regulations guiding developers to the clean energy technologies that have been shown to be cost effective, thus establishing a pathway for New Jersey to electrify the building sector and decrease reliance on fossil fuels for thermal and appliance use.
Note all the weasel words and lack of any deadline: “should consider adopting new regulations”.
And just whose costs are involved in “cost recovery”?
The failure to involve the public in this critical “cost effectiveness” determination is a fatal flaw, but so is effectively delegating this critical policy determination to Rutgers.
Regarding Rutgers, consider that most recently – on the same day that the EMP was publicly released by Governor Murphy – Frank Felder from Rutgers published an egregiously biased and ill-informed cowardly hit piece on the EMP.
NJ Spotlight did the same thing the day that the EIP – prepared by Rocky Mountain Institute – was released, when they wrote:
Those [EIP] projections do not include impact to ratepayers — the subject of another ongoing study by the Rutgers Energy Institute, according to Samantha Levine, a spokesperson for BPU. That has been a big bone of contention among critics of the master plan — that it fails to detail what these policies will do to electric and gas bills.
“There are concerns over what is still left out,’’ said Ray Cantor, a vice president of the New Jersey Business & Industry Association, who listened in on a webinar Friday that detailed the modeling results. He mentioned the potential impacts to ratepayers; costs of various programs that were left out; and various assumptions made by the consultants, including a very high reliance on New Jersey solar energy to provide the power needed to replace fossil fuels.
Ray Cantor of NJ BIA (formerly Deputy Commissioner of the ideologically anti-regulatory Christie DEP) has no scientific or economic training. He knows nothing about energy economics or climate. His opinion is not only not qualified, but it is based on solely on “listening in” to a webinar. Citing him as a credible critic to RMI’s work is journalistic malpractice.
So its no accident that NJ Spotlight is biased and sandbagging.
The timing of the publication and the content of the Felder Op-Ed were obviously designed to undermine the EMP.
While Felder completely ignored climate science, the primary thrust of Felder’s arguments was to echo the bullshit high cost arguments of the corporate business community.
It is terrifying to think that Mr. Felder represents the “academic” and “objective” standards that guide Rutgers.
If he has any role in any energy policy research, then that work is tainted by not only bias, but by gross ignorance.
I hope this post provides more than enough guidance for the intrepid journalists out there to compare the reality to the rhetoric of Gov. Murphy and his “Green Cannibal” sycophants.
We’ll be doing additional posts on the EMP as well as the Governor’s Executive Order and the DEP Commissioner’s Administrative Order.
So, stay tuned.