For years, policy makers and gas utilities have claimed that oil-to-gas conversions help New York City meet the CO₂e emission reduction goals established by Local Law 66–2014. While that claim may have once been defensible, the City’s GHG inventory now clearly shows that by 2017, emissions from natural gas had already risen to a level 144% greater than the law’s 2050 limit for all emissions from all sources. Our task over the next 30 years is thus to reduce natural gas use, not to expand it. Certainly, we should eliminate the last remaining uses of fossil-based heating fuels (oil, propane and even some coal). However, this should be done by converting to heat pumps, not natural gas. We should be pursuing Beneficial Electrification, not gas expansion.
NYC Local Law 66–2014 established two greenhouse gas reduction limits for New York City. These limits were expressed as percentage reductions from the 2005 city-wide, all-source, annual emissions, which, as measured by the Inventory of New York City Greenhouse Gas Emissions were 61,062,452 tCO2e (tCO2e = tons of CO2 equivalent). Given those 2005 baseline emissions, the maximum legally allowed limits on emissions are:
- 30x30: 30% reduction by 2030 to, at most, 42,743,716 tCO2e/year
- 80x50: 80% reduction by 2050 to, at most, 12,212,490 tCO2e/year
During 2017, the most recent year covered by the City’s GHG Inventory, emissions from natural gas use in buildings (i.e. stationary sources, not including electrical power plants) were 17,639,988 tCO2e or 41% of the citywide, all-sources 2030 limit and 144% of the 2050 limit. Given that natural gas use in buildings continued to grow after 2017, it is certain that the 2019 Inventory, once published, will show even higher emissions from natural gas use.
Since 2005, we’ve made steady progress towards meeting both the 2030 and the 2050 goals. By 2017, citywide emissions from all sources had already been reduced almost 17%, a bit over half of the 30x30 goal, and emissions from buildings alone had been reduced even more, by 21%. However, while we’re making progress on achieving the City’s goal and while there remains much that we can do, we will not meet the 2050 goal as long as natural gas use in buildings remains greater than the maximum amount permitted by that goal.
Emissions from buildings fell from 69.4% of the City’s emissions in 2005 to 65.9% in 2017. That reduction in building’s emissions was the result of a 53% reduction in emissions from heating oil, a 45% reduction in emissions from electricity use, and a 58% reduction in emissions from steam. Unfortunately, as shown in the graph above, during the same period, emissions from natural gas in buildings grew 35% and wiped out most of the benefit of progress in reducing emissions from oil, electricity and steam. New York City will not meet its 2050 goals if emissions from natural gas in buildings continue to rise.
In future years, we will undoubtedly continue to reduce most, if not all, of the emissions from oil and steam. (A simple linear extrapolation shows that if we continue on our current path, emissions from oil and steam will end shortly before 2030 but emissions from natural gas will exceed 250% of the 2050 goal.) Also, by 2040, we will have eliminated essentially all the emissions from electricity use. This is because the Climate Leadership and Community Protection Act, which became New York State law last week, requires 100% emissions-free electricity in New York State by 2040. We will also see continued reductions in emissions from transportation and other sources.
But, given that emissions from natural gas use in buildings are already at 144% of the City’s 2050 all-source limit, we will still fail to meet the legal emissions limits if we don’t end gas expansion now and work toward reducing the use of natural gas by at least 31% of its use in 2017. Of course, if we have any remaining emissions sources in the City in 2050, other than natural gas in buildings, we will need to have reduced natural gas use by even more than 31% to stay below the law’s limits. (It is, I think, fair to assume that natural gas will not be the only emissions source. If nothing else, in thirty years, we’ll probably still have at least a few “antique” internal combustion engine vehicles driving around…)
While the City’s GHG Inventory and simple math makes it profoundly obvious that natural gas use in NYC buildings must be substantially reduced, the two utilities that provide gas to NYC have been doing their best to ignore the harsh reality that growth of their gas sales must end and, in fact, the beginning of the end of the natural gas utility business is here already. Refusing to accept reality, both utilities, ConEd and National Grid’s Brooklyn Gas (KEDNY), have rate cases before the Public Service Commission in which they argue for permission to continue gas expansion in New York City in spite of Local Law 66–2014’s requirements. (ConEd’s rate case is 19-G-0066. KEDNY’s is 19-G-0309) These utilities are also working hard to support William’s appeal of New York State’s and New Jersey’s denial of permits for the NESE pipeline. Their hope is that the NESE pipeline will allow them access to a much greater supply of natural gas so that they can continue to increase sales and avoid imposing on New York City the kind of gas moratorium that ConEd recently declared in southern Westchester County. These proposals should be denied. It is time now to declare a moratorium on gas expansion in New York City. Nothing else will allow us to stay within the reasonable and necessary limits established by Local Law 66–2014.
Gas use in New York City already produces more emissions that will be allowed for the entire City after 2050. Thus, we must end gas expansion now and begin the process of dramatically reducing gas use in the City. We have thirty years before 2050. Those years should be spent encouraging the adoption of Beneficial Electrification, such as heat pumps, rather than building more gas pipelines and increasing the use of gas. The PSC should reject or modify any rate case proposals that assume that there remains an opportunity to grow gas use in New York City.