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NOx, NOx — Who’s There? Decarbonizing Buildings Through Nitrogen Oxides Emissions Standards

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This fact sheet, prepared as a poster for presentation at the ACEEE 2022 Summer Study on Energy Efficiency in Buildings, describes the concept of a model rule to reduce emissions of nitrogen oxides (NOx) from fossil fuel-fired water heaters, an opportunity to transform the market for these appliances by driving the adoption of cleaner, more energy-efficient electric heat pump models.

The clash with gas: Should it stay or should it go?

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Europe’s stated goal of achieving a net-zero power system by 2050 is inherently replete with enormous opportunities and challenges. High energy prices and Russia’s invasion of Ukraine have now ratcheted up the urgent need for action to emergency levels. Policymakers are facing the challenge of a lifetime to secure the supply of energy and protect disadvantaged consumers while maintaining momentum towards long-term climate goals. The events of 2022 have made evident to many experts that the transition away from fossil gas will figure prominently in all of these objectives.

To support policymakers and the numerous stakeholders in planning for a deliberate reduction in the use of fossil gas in the coming years, RAP has developed five fundamental guiding principles. The principles are general in nature due to the breadth of this gas transition and the various policy instruments that governments will need to reform such a large part of our energy economy. In light of the current crises, the authors have also applied these best practices specifically to the European Commission’s proposed Hydrogen and Decarbonised Gas Market package and Hydrogen Strategy, as well as to the hydrogen strategies of selected Member States.

To achieve an efficient and cost-effective transition away from fossil gas, we offer policymakers the following recommendations:

Graphic with five principles for transitioning away from fossil gas

 

‘Game on’ for Germany’s heat pump transformation

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Time is of the essence if Germany hopes to meet its ambitious net-zero emissions target by 2045. To achieve this goal, the country will have to rapidly transform how it heats its buildings while ridding itself of Russian gas. Alongside increasing the renovation rate of buildings and rolling out clean district heating, heat pumps are one of the key technologies that can phase out fossil fuels and bring renewable heat to German buildings.

The situation has become even more urgent following Russia’s invasion of Ukraine and the ongoing fossil gas crisis. About two-thirds of German gas imports came from Russia in 2020 and the building sector is the country’s largest consumer of gas for heating. In the five years leading to 2020, gas boilers made up more than half of the market for space heating, while oil boilers made up another 12%. Heat pumps came in at only 16%.

Germany will need to install around 6 million heat pumps by 2030 to be on track for the 2045 target. That translates to a massive increase in annual heat pump uptake — from 154,000 installations in 2021 to 500,000 yearly by 2023. Up until now, most of these units have been installed in new buildings. The existing building stock will need to bear most of the load and, crucially, low-income households must receive enough support to make the transformation equitable as well.

The challenge is enormous. Despite generous subsidies during the past few years to encourage the replacement of fossil fuel boilers with heat pumps, the market has been stubborn. The year 2021 saw more than 920,000 heating appliances installed in Germany – 700,000 were still oil and gas boilers.

Germany has discovered first-hand that generous subsidies from the country’s federal subsidy program (previously the Market Incentive Program and now the Federal Support Program for Efficient Buildings) are not enough to spur a rapid heat transition in buildings. Recently, Agora Energiewende and RAP released new analysis prepared by the Öko-Institut and Fraunhofer ISE that looks at how to trigger this market transformation.

Germany’s 65% rule: Russian gas out, heat pumps in

To achieve its net-zero target and reduce gas consumption, Germany needs to end fossil fuel boiler installations as soon as possible. Financial incentives for clean alternatives did not trigger the necessary market shifts in the past. Regardless of much higher gas prices, subsidies are unlikely to be enough for the required transition. This is in part because German households pay more than six-times higher taxes and levies per kilowatt-hour of electricity than for fossil gas.

What else can be done? The federal government’s answer was announced in March 2022. Starting in January 2024, all new heating systems will need to run on 65% renewables. This political agreement should apply to heating system installations in new buildings as well as replacements in existing ones.

The 65% threshold must be implemented via laws, but the agreed wording leaves the door open to hybrid heat pumps where, typically, a heat pump is combined with a fossil boiler. That would be the bare minimum — standalone oil or gas boilers are de facto ruled out and even solar thermal systems combined with gas boilers would not meet the 65% baseline.

Hybrid heat pumps are cost-advantageous only in the rarest cases. According to the new analysis, standalone heat pumps hold the economic upper hand until the outside temperature falls to -7°C, at which point it is cheaper to heat with a gas boiler. For comparison, from 1991-2020, January temperatures in Germany averaged 1.7°C.

The plan is ambitious, but Germany is in good company. This policy attention towards heating systems is consistent with efforts at the EU-level, such as the Fit for 55 package, REPowerEU plan and Ecodesign performance standard regulation, and in various Member States, several of which have announced bans for new oil and gas boilers with diverse years of implementation.

Key actions for a swift transformation

Transforming a heating market based on 700,000 fossil fuel heating systems to a market predominately centered around heat pumps in only 18 months is a daunting task. Once implemented, the ‘65% rule’ will become the regulatory instrument that draws the borders of the field on which the game will take place. And in January 2024, it will blow the whistle to kick it off. Before that happens, a massive and swift industrial transformation will be required that sweeps along all members of the supply chain, from manufacturers to installers to households. Targeted support for low-income households will be crucial so they are not disadvantaged.

The total cost of owning a heat pump could slow down their future uptake or significantly increase the cost burden on homeowners. Without considering existing subsidies, the upfront cost of a first time, fossil-fuel-to-heat-pump switch in Germany is still around two- to three-times higher than a gas boiler replacement, though much of this is associated with radiator and pipe upgrades. Upfront costs, however, have risen significantly due to a shortage of skilled craftspeople. Installers say they can reduce costs by shortening the installation time from three to two days, while manufacturers have a 40% cost reduction potential in view based on new production methods as well as economies of scale.

To help reduce operating costs, the government has shifted its famous renewable energy surcharge away from electricity bills onto general taxation. On top of that, it is gradually phasing in a carbon price on heating fuels that should reduce this imbalance in the coming years. The new analysis recommends lowering the electricity price for heat pumps by exempting them from certain levies, reducing the VAT to the EU-minimum, and enabling the use of heat pump tariffs that maximize the contribution of heat pump flexibility to meeting power system needs.

To achieve the Germany’s ambitious net-zero target and provide transparent and predictable market conditions, the whistle is in the hand of the government. Kicking off the heat pump transition in a transparent, equitable and suitably ambitious manner means tabling a draft law to implement the 65% rule as soon as possible.

Read the analysis here (in German).

A Clean Heat Standard for Massachusetts

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The burning of fossil fuels for heat accounts for a significant portion of greenhouse gas emissions and burdens many families and businesses with high energy costs. Meeting climate and equity goals requires that we find effective and affordable pathways to rapidly revamp the thermal sector.

This policy brief — prepared as an appendix to the Massachusetts Clean Energy and Climate Plan for 2025 and 2030 — describes the concept of a new requirement on heating energy providers, which we call a clean heat standard. The paper explores the major design choices that would be necessary to implement this concept.

At the highest level, a clean heat standard is a credit-based performance standard that would be applied to suppliers of heating energy. In the Massachusetts context, that includes gas utilities and providers of heating oil and propane, and possibly electricity suppliers. These parties would be obligated to serve their customers with gradually increasing percentages of low- or zero-emissions heat, earning tradeable clean heat credits while sales of fossil fuels are phased down.

Just as a renewable portfolio standard requires electricity providers to replace coal- and gas-fired generation with wind, solar and other clean electricity generation, the clean heat standard would replace fuel oil, propane and fossil gas heat with weatherization, energy efficiency improvements, heat pumps, clean district energy and other verified low-carbon options.

Making sense of India’s fast-changing policy landscape: Integrated modelling to inform decision-making

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With several notable recent economic reforms, India is one of the fastest-growing emerging economies. The country aspires to become a $5 trillion economy by 2024-25 and a $10 trillion one by 2030. There is ample evidence that India’s growth has been highly unequal in the past. Therefore, transforming this vision of growth into reality will require a comprehensive approach based on a multitude of policies targeting multiple domains. Further, the development trajectory should also be capable of tackling the key environmental challenges that India faces.

In the fast-changing policy landscape of a country as diverse as India, striving for equitable growth will not be possible without gauging regional implications of policy shifts. Equally important will be to understand the direction and distributive impacts of ongoing policies consistently and on a regular basis in conjunction with various decarbonisation goals recently endorsed by India.

A book released in December 2021, Economy-Wide Assessment of Regional Policies in India, takes on these questions. Making use of the outputs from the integrated energy-economy regional model called E3-India, it provides hopeful insight and offers powerful recommendations for India’s energy, economic and environmental policymaking at the national and state levels.

The book (edited by the lead author of this post) is a compilation of articles describing how various ongoing and announced sector-specific policies will, or will not, advance India’s social, economic and climate ambitions in both the near and longer terms nationally and across different states. The focus is largely on recent policies implemented in the primary, secondary and services sectors, including agriculture, capital goods, automobiles, electronics, information technology (IT-ITeS) and energy. The analyses also account for the effects of the COVID-19 pandemic and evaluate the impacts of different policy choices — especially with respect to environmental consequences and energy use — at the national and subnational levels.

The book takes a realistic look at the economic sensitivities and interdependencies at the national and state levels across India. Its aim is to broaden the scope of future action by reducing ambiguity and uncertainty in achieving the key policy targets — that is, by giving policymakers greater confidence that desired outcomes can be achieved. The major policies evaluated against a business-as-usual scenario include: the Agriculture Export Policy 2018; National Capital Goods Policy 2016; National Steel Policy 2017; Electrical Equipment Mission Plan 2012-2022; National Policy on Electronics 2019; Digital India initiative; National Software Policy 2019; Automotive Mission Plan 2026; and several subnational initiatives in a variety of sectors. In addition, the book evaluates regional impacts of national energy targets, along with economic impacts of existing Nationally Determined Contributions for India and economic impacts of Delhi’s airshed management. The book also takes a closer look at impacts of liquidity infusion in the context of COVID-19 through the Atmanirbhar package.

Sector-specific impact analyses of national policies reveal critical regional insights. For instance, the existing policy regime will lead to Gujarat state becoming a leader in international agricultural exports. Maharashtra, Karnataka and Haryana perform exceptionally well in the capital goods sector. With appropriate incentives in place, Haryana also emerges as a leader under the Automotive Mission Plan 2026 along with Tamil Nadu.

Tamil Nadu exhibits diversified leadership by outperforming in the electronics and IT-ITeS sphere along with Delhi and Uttar Pradesh. The state emerges as a front-runner in renewable capacity installation as well, along with Maharashtra, Karnataka and Andhra Pradesh. In contrast, the resource-rich and income-poor states like Chhattisgarh, Odisha and Jharkhand show a greater growth potential only in the capital goods sector.

We find that the more advanced states, like Maharashtra and Tamil Nadu, are already in a position to take up diversified policy action in the short run and direct resources to expand their markets through further integration in the global value chains. Most other Indian states still rely on few specialised sectors and will be able to diversify in the medium to long run only if sustained policy support in terms of investment in both infrastructure and capacity-building is provided. In a country as large as India, with different states endowed with distinct economic and geographic characteristics, formulating policies to strengthen regional value chains is critical for equitable growth of states across all regions.

Regional analysis of sector-specific policies highlights the nuances of regional variations in a particular sector, but in reality, various sectors are highly interconnected. The implementation of a policy in one region therefore has direct and immediate effects in its implementation in other regions and sectors. An integrated analysis that captures the essence of multiple policies simultaneously working together in diversified sectors and development areas is demonstrated in the final synthesis of this book. The comprehensiveness and granularity of the modelling outputs will enable readers (and other researchers, who can download and use the E3-India model free of charge) to derive nuanced and more informed policy insights.

By clearly outlining the short-run as well as the medium- and long-run priority sectors at a regional level in conjunction with impacts of ongoing energy transitions, this book intends to serve as a comprehensive guide for evidence-based economic and energy policymaking in India. Shaping these regional insights into deliverable policy actions ultimately lies in the hands of the policymakers. The book and the E3-India model serve as a primer and a tool to facilitate evidence-based policymaking at the regional level, enabling policymakers to leverage and strengthen India’s unique socioeconomic and geographical diversity, while moving toward national economic growth targets equitably and with a lower carbon footprint.

The E3-India model: It’s come a long way

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In 2016, the Regulatory Assistance Project approached Cambridge Econometrics about building a new macroeconomic modelling tool for India. The rationale for the model was simple: India needed to reduce its greenhouse gas emissions, but much of the policy to do so is set at the state level. A model that could identify the impacts of policies to boost state-level sustainable growth was therefore required.

Years later, the outputs of this work are presented in the book Economy-Wide Assessment of Regional Policies in India, edited by professor Kakali Mukhopadhyay. The book covers a range of topics relating to sustainable economic development in India, always with a focus on realistic (i.e., feasible) policy at the state level.

The model that was built came to be known as E3-India — “E3” for energy-environment-economy. It was developed by experts at Cambridge Econometrics, Professor Mukhopadhyay and former RAP colleagues Ranjit Bharvirkar and Surabhi Joshi. Without this collaboration, it is unlikely the model would have advanced to its present state.

The foundations of the model follow the Cambridge tradition, drawing on the demand-driven framework originally developed by Michal Kalecki and John Maynard Keynes. This approach provides several advantages over the more common equilibrium approach to modelling; it does not make assumptions about perfect information, rational behaviour or frictionless markets. In addition, it models labour markets, including involuntary unemployment — matters of particular importance to policymakers.

This demand-driven approach requires that behavioural parameters be informed by econometrics — that is, it requires, among other things, time-series historical data. With the model disaggregating India’s economy into both states and economic sectors, a substantial exercise in data collection and processing was required. Professor Mukhopadhyay led this herculean effort, yielding a tool that researchers today can download and use free of charge.

Another important feature of the model is its tight integration of energy consumption and greenhouse gas emissions within the wider economy. The model ensures consistency between physical and economic measures of energy consumption and prices — something that is critical for effectively assessing sustainability.

The power sector, which will play a crucial role in decarbonising India’s economy, is modelled in additional detail using an advanced framework developed by Jean-Francois Mercure. This allows the user to test policies such as feed-in tariffs, renewable subsidies and coal phaseouts, along with the standard energy and carbon tax policies that other models typically examine.

Each chapter of the book is dedicated to a different sector of the economy. A set of scenarios is used to explore different possible outcomes by implementing combinations of policies. The demand-driven nature of the model allows the analysis to start from a position in which the Indian economy has been set back by COVID-19; many of the scenarios look at ways to restore jobs and prosperity.

Eleven authors, experts in their respective fields, were involved in the production of the book. They put the E3 model to rigorous use, testing its capabilities and performance, and with it have revealed some important truths about the Indian economy and good news about its ability to transform itself into the sustainable, low-carbon powerhouse that it aspires to be.

The book is by no means the end of the E3-India project; in many ways, it is just the beginning. E3-India is a tool that policymakers can use for many years to come as they embark on the journey of promoting sustainable development. The model will continue to be updated. We encourage readers of the book to work with the model themselves, to challenge its conclusions and to examine other scenarios, all with the aim of developing public policies dedicated to improving the long-term welfare of Indian society and the environment. If India is to contribute to meeting global climate targets, much work remains to be done.

Draft RAP Model Rule for Water Heater NOx Emissions

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​In a presentation for national advocates, Nancy Seidman and John Shenot proposed an innovative model rule concept to reduce nitrogen oxides emissions from water heaters, a significant source of emissions that has received little attention from state regulators.

Power System Blueprint

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Accomplishing climate neutrality by 2050 requires a zero-emissions power sector by the mid-2030s. Securing a decarbonized power system early will unlock pathways for the whole economy. One of the biggest challenges to accomplishing this ambitious goal is time—we have a need for speed if we want to meet decarbonization goals by 2035.  

This is why RAP has created the Power System Blueprint, an interactive website that allows visitors to view different options for decarbonizing Europe’s power system. The Blueprint lays out how to design the regulatory context to achieve a clean, reliable, equitable and affordable European power system by 2035. RAP pulled together the latest insights for supporting regulators, NGO’s, governments and anyone interested in the decarbonization pursuit. 

The Blueprint is designed as a schematic of regulatory solutions linked to six important central principles. In the suite of regulatory solutions (also known as factsheets),you will find comprehensive information, the most important regulatory steps and further reading. 

The decarbonization of the power sector can be done by 2035 but will require a rapid and systemic rethink of the existing European power system regulatory landscape. Within the Power System Blueprint website, you’ll find solutions to some of the some of the largest tasks we face working within this tight timeframe.   

Blueprint logo

Where Do We Go From Here: Visions for a Clean Heat Standard

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In a webinar discussion, panelists discussed efforts across the country to put in place clean heat standards or other mandates for reduction of emissions from thermal end uses.

A Song in the Key of E: Emissions, Efficiency, Equity, and Electrification

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A lot of folks out there (including we at RAP) have, for the last four decades, been devising ways to make utilities more economically efficient, their customers more energy-efficient, and the power system cleaner, sustainable, more equitable, and non-emitting. But now they have a problem: the world has changed, and suddenly we need more of that thing that they for so long tried to constrain. Now that the time has finally come to make the leap that has to be made if our climate crisis is to be solved, we’re like the proverbial deer in the headlights — if only for a moment. The prospect of wild load growth in electric demand is a bit hard to swallow at first. It’s both frightening and, well, electrifying.

Efficiency has been the central theme of electric sector reform for nearly a half century. It is the recognition that meeting a society’s energy needs is not simply a matter of “more is better” but rather of “no more than is necessary (and it’d better be as environmentally benign as possible).” This insight meant that we should not use energy when it was cheaper and more valuable to save it. And it meant that the traditional business model of the monopoly electric utility had to change—that profitability could no longer be linked to growth in commodity sales but to the least-cost provision of energy service and achievement of express public policy objectives.

So what’s the problem?

Well, it turns out that we need more, lots more, of a particular kind of energy — electricity from non-emitting resources — if we’re going to decarbonize as much of the economy as we possibly can. We need clean electricity for transportation, heating and cooling, agriculture, and industry. Are the regulatory reforms that we’ve advanced in the past thirty-odd years — in particular, integrated resource planning, revenue decoupling, and systems of performance-based rewards and penalties — appropriate to a vision that calls for a great expansion in our use of electricity and therefore a sea change in how we produce and deliver it?

The answer is yes, and it shouldn’t surprise us. It follows directly from an approach to economic analysis and policy — aimed at maximizing the net societal benefits of energy use — that we’ve relied on for decades. Thirty years ago, given the costs, expectations, and constraints we faced, the analyses pointed us in certain directions. Today, given different costs, expanded expectations, and more urgent constraints, they point us in new directions. In both cases, they told us how to minimize the costs — that is, maximize the benefits — of our desired path.

At a conceptual level, the problem isn’t daunting. It’s time to truly look at the energy system in its entirety, not just the electric system. How do we minimize the total costs of energy production and use, while meeting our climate, economic, and social goals?

It’s simple. The least-cost path is characterized by massive fuel-switching — from fossil fuels to clean, emissions-free sources, primarily electricity. But it’s not that simple. It doesn’t relieve us of the duty to make sure those new loads are as efficient as possible and are managed as efficiently as possible — indeed, it insists upon it, since any waste only increases costs. It isn’t right simply to say “Electrify!” How we electrify matters.

The good news is that our planning tools and regulatory methods are up to the task. We know how to think about the problem, consider alternatives, test uncertain futures. We know how to change course when circumstances dictate. And we know that utilities and market actors respond to the forces that act upon them, which means that we should still care deeply about whether their private financial incentives align with the public interest. We want these players to be successful by doing the right things.

So what does this mean for the utility business model? For the “wires” sides of the business — transmission and distribution — in both vertically integrated and competitively restructured markets, there’s still every reason to remove the “throughput incentive.” Whether load is growing or not, a utility whose revenues and profits are a direct function of kilowatt-hour sales (that is, of kWh deliveries) has a very powerful incentive to encourage usage, even if that usage is inefficient. We shouldn’t think that, simply because the electricity is clean, we have license to be profligate. The recent decision of the Massachusetts Department of Public Utilities to scrap Eversource’s decoupling regime, on the grounds that good ol’ fashioned price-only regulation will encourage the company to promote electrification. Probably it will, but, alas, it won’t give the utility much, if any, reason to care whether the electrification is in the best interests of society.

Revenue decoupling remains a critical element of a regulatory regime that aims for least-cost investment in, and operation of, the grid. It keeps the regulated monopoly focused on efficient operations. But, by itself, it doesn’t guarantee utility enthusiasm for preferred outcomes. Legal and regulatory obligations go a long way to solving that problem, but there’s a place for carrots and sticks too. Performance measures, with achievement rewards and penalties, overlaid on a decoupling mechanism, are powerful drivers of policy objectives.

What about the commodity side of the business? Again, in both vertically integrated and restructured markets, investment has been and will continue to be propelled in significant measure by policy requirements, such as renewable portfolio standards and emissions reductions requirements (e.g., cap-and-invest programs). These have been effective in transforming our resource portfolios and, moreover, have helped drive deep cost reductions in clean energy technologies, so that now the relative costs begin to favor the preferred investments. Important wholesale market reforms are still needed, but the outlook is good.

In those places where utilities remain vertically integrated, the question of how power costs should be recovered is of acute interest, especially where price risk has been shifted to consumers by means of fuel adjustment clauses and power-cost pass-throughs. How these mechanisms, intended to insulate shareholders from the volatility of global energy prices, distort management imperatives to manage power costs and investment for the long-term good of both consumers and shareholders has been well understood for decades. It’s time to revisit these tools, to consider whether and how they can be reformed to better align private incentives with the public good. Utilities and other load-serving entities possess the comparative advantage for bearing price, climate, and other market risks. Some simple fixes to power-cost recovery mechanisms will go a long way to reordering those risks and creating the environment in which clean, reliable electricity flourishes.

By all means, let’s let utilities and other market actors make money providing the energy and energy services we want. And that includes where increased load is societally most efficient—which is to say, the least-cost means of meeting demand for reliable, equitable service and, among other things, our climate goals.

Stay tuned for more blogs in this series. We’ll dig into some of the knottier regulatory challenges that large growth in load raises and try to answer the question: “Just what does a regulatory scheme look like that promises to achieve these ends?”