New York City enacted Introduction No. 2317-A in December 2021, and the new law prohibits fuels that release more than 25 kg of CO2 per million BTU in space heating and hot water systems. This requirement applies to new construction and major renovations. Since natural gas and heating oil are both above the limit, they have essentially been banned. This means that building owners will need electric heating systems as soon as the law comes into force.
Internal. No. 2317-A is also known as Local Law 154 of 2021 , and the date it applies to new construction depends on its height. Buildings with fewer than seven stories must meet LL 154 if filed after December 31, 2023, and buildings with seven stories or more must comply if filed after July 1, 2027.
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However, is electric heating really cleaner than gas heating? This is true when using clean sources like solar and wind energy, but not when a grid depends on fossil fuel generation. In other words, electrification only reduces emissions from the building sector if energy companies transition to cleaner sources. Otherwise, emissions will simply be transferred from buildings to power plants.
How does New York State generate electricity?
According to the U.S. Energy Information Administration , the three main sources of energy in New York State are natural gas, nuclear power, and hydroelectricity. These sources generate 90% of the electricity used in the state, while the remaining 10% comes from non-hydro renewable energy, such as solar and wind energy. Nuclear and hydroelectric plants do not emit emissions during their operation, but the same cannot be said about gas turbines.
- Natural gas is used in 5 of the 10 largest plants in the state.
- Natural gas generated 40% of the electricity used by New York in 2020.
However, New York is among the most energy efficient states relative to its population. Per capita energy consumption is the third lowest in the US, and only California and Rhode Island are more efficient. New York has an ambitious Clean Energy Standard targeting 70% renewable energy by 2030 and 100% carbon-free energy by 2040.
On a local level, New York City is taking aggressive action to reduce its emissions. The Bigger and Greener Buildings Plan (GGBP) was created more than a decade ago, in 2009, and included four laws:
- LL84/2009: Energy and water benchmarking for buildings
- LL85/2009: First version of the New York Energy Conservation Code
- LL87/2009: Mandatory energy audits and retro-commissioning of buildings
- LL88/2009: Mandatory metering and lighting upgrades
More recently, New York introduced energy classes for buildings with LL33/2018, and emission limits for buildings over 25,000 square feet with LL97/2019. The latest addition to the list of climate-related laws is LL154/2021, which bans natural gas and higher-emitting fuels in new construction.
Ensuring electric heating systems have low emissions
New York's grid electricity has an emission factor of 0.000288962 metric tons of CO2 equivalent per kilowatt-hour. This means that an electric heating system using only grid energy will produce almost 289 kg of CO2 equivalent for every 1,000 kWh consumed. However, this can be compensated for by using electric heat pumps instead of resistance heaters.
A resistance heater provides one unit of heat per unit of electricity consumed. Using the example above, 1,000 kWh of electricity would be converted into 1,000 kWh of heat, which is equivalent to 3,412 kBTU. However, if an air source heat pump provides 2.5 units of heat per unit of electricity, it can provide 3,412 kBTU with just 400 kWh of electricity. In this case, energy consumption and associated emissions were reduced by 60%. Using the emissions factor above, the following results are obtained:
- The resistance heater releases 288.96 kg of CO2-eq while providing 3,412 kBTU of heat.
- The heat pump releases only 115.58 kg of CO2-eq while providing the same heat output.
Of course, if 100% of the electricity came from a clean source, both the resistance heater and the heat pump in the example above would have zero emissions. However, you can still save 60% of your heat pump operating costs. Even if you generate your own electricity on site, electric heat pumps use available capacity more efficiently.
To summarize, electric heating can be cleaner than natural gas heating, but only when the power is generated with a zero- or low-emissions energy source. Most electrical grids have a combination of sources and the emissions factor will depend on the percentage of energy coming from fossil fuels. In this case, electric heat pumps can help compensate thanks to their lower kWh consumption.
