Mention of a ban on gas stoves recently caused a national uproar.   Closer to home the New York State Climate Leadership & Community Protection Act(CLCPA) implementation plan calls for zero-emission equipment, including stoves, in new and existing buildings.  When pressed about New York’s plans Governor Hochul said “”I know it’s a concern because a lot of people are misrepresenting what this is all about.”  I think the misrepresentation is on the part of the Hochul Administration,

I submitted comments on the Climate Act implementation plan and have written over 275 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Climate Act established a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric gride with zero-emissions generating resources by 2040.  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to write a Draft Scoping Plan that was revised in 2022 and the Final Scoping Plan  was approved on  December 19, 2022.

There are multiple aspects of a ban on gas stoves that I have wanted to address.  Fortunately, most of the points I wanted to make have already been made so this post is more of an overview of other work than original effort on my part.

Childhood Asthma and Gas Stoves

The initial reason for the recent uproar about gas stoves was a study published in an open-source journal called Population Attributable Fraction of Gas Stoves and Childhood Asthma in the United States (Gruenwald et al., 2022).  The sound bite takeaway from the study was that gas stoves are responsible for 12.7% of childhood asthma in the US.  I don’t have a lot of faith in any study that claims an air pollution association with asthma rates but was not relishing trying to develop an analysis.

Blair King writing on his blog did a masterful job eviscerating the claims in the paper.  In brief, the study was based upon a 2013 paper that used old data from the 1980’s and 1990’s.  The analysis was done using a 70-year-old statistical tool called PAF which is widely used in epidemiological studies.  However, the tool breaks down when multiple risk factors (confounding variables) are present.  For asthma, there are no fewer than seven risk factors so the analytical tool becomes useless.  I recommend reading his article but the conclusion nails the issue:

To conclude, I can only restate that the Gruenwald et al paper seems to have some clear challenges that would typically preclude it from consideration in a policy-making process.

• Its underlying data is of low statistical power.
• Its conclusion is directly contradicted by more recent studies with significantly greater statistical power. and
• It relies on a statistical tool that is considered invalid in situations with confounding variables yet it is being used to analyze an association that is absolutely rife with confounding variables.

Put simply, this is not the study I would rely on to make a major policy change that will affect millions of people and will cost billions to implement. As to its conclusion: are 12.7% of childhood asthma cases in the US attributable to cooking with natural gas? Based on the points above, that conclusion is almost certainly not the case.

This isn’t the first time that a study that is weak science is used as an argument for sweeping policy changes.  What did surprise me is how quickly the story raced through the media.  Robert Bryce explained how that happened in his post The billionaires behind the gas bans.  I highly recommend that you read the whole thing but I present some highlights below.

He explained that he started looking into a new organization called the Climate Imperative Foundation in late 2021 when he read a story that the new group has a planned budget of $180 million annually over five years for a total of $900 million.  When he investigated the source of the money, he discovered that two of the  most recognizable names on the six-person board are Silicon Valley venture capitalist John Doerr and Laurene Powell Jobs, the widow of late Apple CEO Steve Jobs. Forbes magazine estimates that Doerr has a net worth of $12.7 billion. Forbes puts Jobs’ net worth at $17.7 billion. Unsurprisingly, Bryce found that most of the money is coming from Doerr and Jobs.

His article explains why the emergence of the Climate Imperative Foundation is important:

First, it shows that the effort to “electrify everything” and ban the use of natural gas in homes and businesses – and that includes gas stoves — is part of a years-long, lavishly funded campaign that is being bankrolled by some of the world’s richest people.

Second, despite numerous claims about how nefarious actors are blocking the much-hyped “energy transition,” the size of Climate Imperative’s budget provides more evidence that the NGO-corporate-industrial-climate complex has far more money than the pro-hydrocarbon and pro-nuclear groups. Indeed, the anti-hydrocarbon NGOs (most of which are also stridently anti-nuclear) have loads of money, media backing, and momentum. As can be seen in the graphic below, the five biggest anti-hydrocarbon NGOs are now collecting about $1.5 billion per year from their donors. (All data is from Guidestar.) That sum is roughly three times more than the amount being collected by the top five non-profit associations that are either pro-hydrocarbon or pro-nuclear.

Third, banning the direct use of natural gas in homes and businesses may be worse for the climate. You read that right. Burning gas directly allows consumers to use about 90% of the energy contained in the fuel. Using gas indirectly — by converting it into electricity and then using that juice to power a heat pump, stove, or water heater — wastes more than half of the energy in the fuel. That point was made by Glenn Ducat, in his excellent new book, Blue Oasis No More: Why We’re Not Going to “Beat” Global Warming and What We Need To Do About It. Ducat is a Ph.D. nuclear engineer who worked at Argonne National Lab, as well as at two electric utilities. He explains “Burning natural gas by residential commercial and industrial customers is at least twice as efficient and emits about half as much CO2 as processes that use electricity produced from fossil fuels. Converting process-heat applications to electricity before the electricity grid is completely carbon-free will increase CO2 emissions.” (Emphasis in the original.)

In the interest of full disclosure, I note that the New York plan is to eventually use electricity from zero-emissions sources.  However, there are life-cycle energy use issues with wind, solar and energy storage that mean the Climate Act transition does not reduces CO2 as much as it claims because of the efficiency of burning  natural gas directly for heating, cooking and hot water.

Bryce documents how the efforts to demonize gas stoves has rolled out since 2020.  One of the authors of the 12.7% asthma paper is employed by the Rocky Mountain Institute (RMI) which has published other articles that make the same claims.  He provides other evidence that this paper doesn’t stand up to scrutiny.

He went on to investigate where RMI gets their funding.

Some of it is coming from Amazon billionaire Jeff Bezos. In 2020, the Bezos Earth Fund gave RMI $10 million, which the group said will be used to “reduce GHG emissions from homes, commercial structures, and other buildings, enabling RMI to increase its current work with a coalition of partners in key states. The project will focus on making all U.S. buildings carbon-free by 2040 by advocating for all-electric new construction…”

Bezos also has provided $100 million grant to the National Resources Defense Council.  The Sierra Club is getting funds from Michael Bloomberg’s Bloomberg Philanthropies, including $500 million to the Beyond Carbon project.  His article clearly shows that the narrative that the fossil and nuclear industries are providing massive money to funding disinformation while the noble NGOs struggle to find enough money to counter their claims is false.

Bryce makes two final points:

The first is the hypocrisy of billionaires funding efforts to slash hydrocarbon use while they are consuming staggering amounts of hydrocarbons. According to a 2020 article in Vanity Fair, Michael Bloomberg owns eight houses in New York state alone, and “he also reportedly owns several properties in London, Florida, Colorado, and Bermuda.” Thus, Bloomberg may own a dozen houses. How many of those houses have gas stoves? I’ll make a wild guess and bet that it’s more than one. Oh, and according to Vanity Fair, while he was mayor of New York, Bloomberg “was known to spend weekends” at his house in Bermuda, “traveling back and forth on private jets.” And what is fueling those private jets? I’m guessing here, but it’s probably not organic quinoa.

The final bit of hypocrisy at work here is the regressive nature of the gas bans. Indeed, it’s clear that banning natural gas will mean higher costs for consumers. Last March, in the Federal Register, the Department of Energy published its annual estimate for residential energy costs. It found that on a per-BTU basis, electricity costs about 3.5 times more than natural gas. It also found that gas was, by far, the cheapest form of in-home energy, costing less than half as much as fuels like kerosene, propane, and heating oil.

That means that efforts to ban natural gas are, in practice, an energy tax on the poor and the middle class. During a recent interview, Jennifer Hernandez, a California-based lawyer who represents The 200, a coalition of Latino groups that has sued the state over its climate policies, told me that “Natural gas is the last source of in-home affordable energy. And these climate extremists can’t stand it.”

The Scoping Plan and All-Electric Homes

Governor Hochul has been pushing back on the notion that her Administration is coming after residential gas stoves.  The final thing I wanted to address was the Scoping Plan strategies for buildings particularly as they relate to electric appliances.  Table 11 (page 183) from the Scoping Plan Chapter on Buildings explicitly says adopt standards for zero-emission equipment.  Clearly that precludes gas stoves at some point.

James Hanley from the Empire Center wrote a great explanation of the truths of the Scoping Plan and the gas stove ban.  I reproduce his post in its entirety below:

Governor Hochul is pushing back against the fear that she’s coming after homeowners’ gas stoves. She insists that she’s not, and that she’d “like to deal in the truth here because a lot of that isn’t getting out.”

Fair enough, so let’s deal with that truth.

First, it’s true that Hochul didn’t recommend a gas stove ban in her 2023 State of the State address. While she did say she wants to “prohibit the sale of any new fossil fuel heating equipment by no later than 2030 for smaller buildings, and no later than 2035 for larger buildings,” she made no mention of prohibiting the sale of other fossil fuel appliances – stoves, hot water heaters, and clothes dryers.

But the Governor’s silence on those appliances doesn’t settle the issue, and any suggestion that it does violates her urging that we “deal in the truth.”

The truth is that the Climate Action Council’s Scoping Plan explicitly recommends banning sales of fossil-fuel fired hot water heaters in 2030 and fossil-fuel fired clothes dryers and stoves in 2035.

The truth is that this Scoping Plan is the roadmap that the state legislature and all state agencies are supposed to follow to implement the Climate Leadership and Community Protection Act (CLCPA).

The truth is that the Governor or her successor(s) could follow up this year’s recommendations for action in future years, or the legislature could on its own.

The truth is that the Department of Environmental Conservation is supposed to make rules implementing the CLCPA and could begin the regulatory rule-making process to ban these appliances without the Governor’s direct prompting.

And the truth is that advocates of eliminating all fossil-fuel equipment from New York’s economy are not going to give up in despair just because the Governor didn’t – at least not yet – advocate every recommendation from the Scoping Plan.

There’s another, less visible truth, as well. The goal of anti-fossil fuel activists is to continually reduce the use of natural gas until the pipeline distribution system becomes economically unsustainable. The Scoping Plan has a whole chapter discussing the “strategic downsizing” of the gas system. And while the goal of making it economically unsustainable is not made explicit, it is the foreseeable result of this downsizing strategy.

The more homes that are forced or incentivized to switch to all-electric, the fewer gas customers there are left to cover the cost of maintaining this large distribution system. That will put cost pressure on those remaining gas customers, forcing more of them to switch to electricity. That puts further cost pressure on the remaining customers, and so on, until maintaining the system is no longer financially sustainable.

With this long-range strategy, no explicit ban is even necessary.

This will not affect propane stoves and appliances, of course, because they are not fed by a pipeline system. So they may get at least a temporary reprieve. But they are clearly targeted by the Scoping Plan and anti-fossil fuel activists as well.

In brief, while it’s true that Hochul did not propose a ban on replacement fossil fuel-powered appliances in this year’s State of the State address, there is plenty of time between now and 2035 for her, a successor, or the DEC to act in conformity to the recommendations set out in the state’s CLCPA Scoping Plan. Even if they don’t act to enact an explicit ban, the Scoping Plan lays out of goal of diminishing the infrastructure for gas delivery.

So don’t believe those who are now naysaying the idea of a gas appliance ban. Gas and propane users will need to organize effectively to make their voices heard if they are to prevent a forced transition to electric appliances.

For the record the Scoping Plan Chapter on Buildings on page 190 states the following for residential applications:

These zero-emission standards across a range of equipment types should apply starting in the years noted below.

2030: Adopt zero-emission standards that prohibit replacements (at end of useful life) of residential-sized equipment used for the combustion of fossil fuels for heating and cooling and hot water. The standards beginning in 2030 should regulate equipment sized to typically serve single-family homes and low-rise residential buildings with up to 49 housing units.

2035: Adopt zero-emission standards that prohibit replacements (at end of useful life) of fossil fuel appliances for cooking and clothes drying.

Discussion

It has been said of the Scoping Plan that “The plan is a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it.”   I have spent most of last year trying to interpret what is important and can confirm that statement.

It is a political document intended to push the agenda of the Hochul Administration which is apparently to pander to the emotional needs of the constituency that believes that there is a climate crisis and an easy and painless solution.  There are enormous ignored tradeoffs associated with the complete transformation of the energy system that has been built up over one hundred years to one with zero-emissions in the 27 years to 2050.  Nothing is as simple as portrayed in the Plan or the politician’s descriptions of what is going to happen.

The biggest problem with the Scoping Plan is that it does not address any of the many “what if?” questions.  Consider the electrification of home cooking appliances in this regard.  I believe that the overarching what if question related to all-electric homes is what if there is an ice storm.  During an extended wintertime blackout, a gas or propane stove can be used for cooking and for limited heating.  An all-electric home without electricity has nothing. Those differences could mean a life or death situation.

Richard Ellenbogen mentioned some transition issues in a letter:

Additionally, if you ban the sale of gas ranges, what happens if your existing gas range breaks.  Do you have to rewire your home to install a new stove and then buy all new pots to work with an inductive cook top?  What are you supposed to do for cooking while you wait a month for an electrician to install a service that can cost thousands of dollars depending on the existing service?  I have a breaker panel within thirty feet of the stove in my house and my house has an existing 400 amp service which is far larger than most will.  Even if I had to switch ranges, it would cost at least $2000 for the electrical work, excluding patching and painting of the holes needed to run the cable, just to run the service.  That is beyond the cost of the range.  Inductive cook tops, which are safer and use less energy, are three times the cost of a gas range, independent of the $400 set of pots and pans that will work with it.   If the existing service and breaker panels were inadequate, you can add $6000 to that figure, at least.  What if you live in a high-rise apartment and the board or building management doesn’t have the funds to rewire the entire building when your stove breaks?  The gas range in my daughter’s apartment needed replacing.  We had a new one installed for $750, delivered.  Not that we could have installed an electric range anyway because the electrical service wasn’t there, but an equivalent inductive range started at $2000 and went up from there.  $2400 with pots and pans.  That was two years ago.

Finally, the effect of the billionaire funding sources should not be ignored.  Anyone associated in any way with the fossil fuel industry is portrayed as a shill such that their work should be disregarded as propaganda.  Because funding sources are a legitimate concern, I maintain that it is important to understand the source of anyone’s funding.  To say that an organization that gets its funding from a donor with a specific agenda is not exactly the same situation as a fossil fuel shill is naïve.

In both cases it does not mean that the results are wrong but that they must stand up on their merits.  (By the way that is the reason that my posts typically include references.)  In this instance the claims of significant health impacts of gas stoves do not withstand scrutiny so the publicized studies do not warrant banning their future use.

Conclusion

The Hochul Administration’s war on natural gas and propane is irrational.  While methane does have a more potent impact on the greenhouse effect than carbon dioxide in a molecular comparison, in the atmosphere methane does not have anywhere near the effect of carbon dioxide.  The atmospheric residence time is on the order of 12 years so methane does not build up in the atmosphere.  Furthermore, there is a large body of evidence showing that the claimed health impacts of methane combustion are weak.  Those fundamental flaws destroy the rationale to eliminate the use of natural gas and propane as planned in the Scoping Plan.

On the other hand, there are significant benefits for the use of natural gas and propane. It is cheaper.  It is energy dense and can be transported easily so when it is combusted in a modern high efficiency appliance you get a lot of bang for the buck with relatively small impacts.  I suspect that many New Yorkers appreciate its dependability relative to electricity.  It allowed my family to survive two extended blackouts and I am not sure what we would have done without it.

I have found that New York’s emissions are less than one half of one percent of global emissions and that the average increase in global emissions is greater than one half of one percent.  In other words, even if we eliminate our emissions, the increase in global emissions will replace our reductions in less than a year.  That does not mean we should not do something but it does mean that we can and should take the time to be sure that the things we mandate do not do more harm than good.  Until such time that the Hochul Administration is held accountable to answer the what if questions not addressed in the Scoping Plan it is likely that the transition to net-zero will do more harm than good.

The politicians who are downplaying the idea of a gas appliance ban are just kicking the can down the road to be somebody else’s problem.  Someway or somehow every building in New York State is going to be electrified to the maximum extent possible according to the Scoping Plan.  Gas and propane users must make their voices heard if they are to prevent a forced transition to electric appliances. Please contact your elected officials and tell them we must have full accountability before a mandated transition.