Attachment 2 - Public comments received between 1101 am, Dec. 12, 2019 and 1100 am, Dec.16, 2019Robert Gra
Subject:
Attachments:
FW: REACH Discussion - please add to council packet
Marginal Emissions Rate from building Electrification.pdf
From: Robert Lipp <ebob@2lipps.com>
Sent: Thursday, December 12, 2019 1:58 PM
To: Marico Sayoc <MSavoc@losgatosca.gov>
Cc: Council <Council@losgatosca.gov>; Town Manager <ManagerPlosgatosca.gov>
Subject: Re: REACH Discussion - please add to council packet
Ms Sayoc,
At the last council meeting I contended that we cannot both purchase clean energy and have it
delivered to our homes. I also contended that full electrification will delay retiring inefficient gas
fired plants.
You chastised me for these claims long after I had left the podium rather than engage me while I
was up there.
Please review the attachment. It is a chart of the projected marginal green house gas (GHG)
emissions generated by electrification in 2030. Marginal emissions are the only technically sound
way to evaluate electrification. Note that electrification doubles GHG emissions compared to
direct natural gas combustion for most of the day.
The report's unspoken agenda is clearly to create a narrative to support electrification, so these
numbers are as low and optimistic as they could make it and still be creditable.
I hope this will help you better understand one of the nuances of your proposed REACH
ordinances. If you have further concerns, I will be at the next council meeting and will be happy
to discuss either formally or informally.
Thanks and Regards,
Robert Lipp
i ATTACHMENT 2
Marginal GHG Emissions Rate from building Electrification.
Note the marginal GHG emission rate of using electricity is typically twice that of combusting
natural gas for most of the day.
The marginal emission rate is the environmental cost of adding an additional MWh of electricity
to the base Toad.
Using your electric stove at 6PM (19th hr) generates over twice the amount of CO2 gas than
burning natural gas. Multiplied by relative efficiencies (these numbers are in this report) there
is little to no difference between gas and electricity.
The marginal emissions rate is reported in metric tons of CO2, eq/MWh. Figure 8-1 shows the average
calculated emissions rate for each month and hour in 2030.
Hour of Day
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Jan 0.33 0.33 0.34 0.33 0.34 0.36 390.370.180.000.000.000.000.000.000.05+0.350.330.360.380.370.360.350.34
Feb 0.34 0.34 0.34 0.34 0.34 0.37 0.40 0.30 0.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.2110.38 0.40 0.40 0.38 0.36 0.35 0.34
Mar 0.270.280.290.280.310.340.2510.070.000.000.000.000.000.000.000.000.0510.330.350.350.350.330.320.29
Apr 0.180.210.220.200.270.320.020.000.000.000.000.000.000.000.000.000.090.170.3710.290.280.230.270.25
May 0.26 0.27 0.27 0.27 0.33 0.2910.05 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.040.25 .38 0.39 0.35 0.29 0.31 0.28
Jun 0.23 0.24 0.23 0.26 0.30 0.24 0 0'• 0.01 0.01 0.02 0.01 0.00 0.00 0.01 0.05 0.08 0,98 0.19 0.29t0.37'. 0.29 0.27 0.29 0.26
Jul 0.340.340.340.340.350.360.330.120.070.100.120.090.050.030.02 0.02 0.20 0.32 0.36 0.37 0.36 0.36 0.35 0.34
Aug 0.35 0.35 0.36 0.35 0.37 0.39 0.35'0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.12 0.36 0.39 0.34 0.38 0.39 0.37 0.36 0.36
Sep 0.38 0.37 0.37 0.36 0.38 0.41 0.37 0.21 0.02 0.04 0.00 0.00 0.00 0.00 0.02 1 0.16 0.36 0.39 0.40 0.39 0.41 0.39 0.37 0.37
Oct 0.35 0.35 0.35 0.35 0.36 0.40 0.4210.29 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.1540.39 0.45 0,48 0.47 0,39 0.37 0.36 0.36
Nov 0.33 0.33 0.33 0.34 0.35 0.36 0 37 0.2910.04 0.00 0.00 0.00 0.00 0.00 0.00 0.15 0.35 0.36 0.36 0.36 0.36 0.35 0.34 0.33
Dec 0.33 0.34 0.35 0.34 0.35 0.37 i -ti 0.37 0.17 0.00 0.00 0.00 0.00 0.00 0.02 0.12 0.36 0.38 0.39 0.38 0.36 0.35 0.34 0.34
Figure 8-1 Heat map of the assumed marginal emissions rate (metric tons of CO2,eq/MWh), averaged by month and
hour in 2030.
https://www.ethree.com/wp-
content/uploadsJ2019/04/E3 Residential Building Electrification in California April 2019.pdf
For reference, natural gas combustion generates 0.18 metric tons CO2eq/MW.
The source material for this study is not available. From the discussion, the methodology and
modeling is very suspect in favoring electrification (which is the whole object of the report) and
therefore probably optimistic.
For example, one questionable assumptions is it assumes there is always a glut of solar energy
in the middle of the day - even on hot summer days and dark cloudy wintry days.
Robert Gray
Subject: REACH Discussion - please add to council packet
From: Robert Lipp <ebob@2lipps.com>
Sent: Thursday, December 12, 2019 2:47 PM
To: Council <Council@losgatosca.gov>; Town Manager <Manager@losgatosca.gov>
Subject: REACH Discussion - please add to council packet
Dear council members,
I seem to have convinced no one with my arguments about the imperfections of REACH for full
electrification. But I would still like to help by pointing out at least one serious technical
weakness in the current proposal.
In Section 4.106.4.1, most of the original draft regulation by the State was deleted and
replaced. A requirement for a raceway for the EV hookup was deleted and replaced by a
requirement for a 40A connection. This is just wrong!
This low power 40A connection was standardized for backward compatibility with conventional
200A service drops. It is completely inadequate for the future. Without a raceway, it is difficult
and expensive to upgrade. I cannot even begin to imagine why someone would think it was a
good idea to lock in an obsolescent connector for a new service installation.
The requirement should have been to change the 1" raceway to a 1.5" raceway, not delete it. It
is trivial to pull cable through such a raceway, upgrading it as desired.
I think your added requirement for two EV plugs will already require a larger service drop. This
service drop should preferably be 200A 3-phase if available, 400A single phase if not.
Why these suggestions? Future EVs will certainly be outfitted with faster charging options. A
100A EV connection will charge a vehicle 2.5 times faster. A 60A 3-phase connection will charge
a vehicle 4.5 times faster. This is not just a matter of convenience.
Firstly, the vehicle can be charged rapidly during times of solar power gluts at very
low cost, thereby preventing wasting such excess power.
Secondly, in the next 10-20 years base generating plants, gas and nuclear, will be
retiring. This will create a shortage of overnight power. Overnight charging will go
from cheap to expensive, making quick charging during the day imperative.
Overnight charging may even be banned if the mismatch grows too great.
Thirdly, I believe vehicles will evolve to become closely integrated with the grid,
using their batteries for offline power storage. This will only be successful if the
batteries can be charged and discharged rapidly. Just think, your idle car sitting in
the garage buying cheap energy and selling high, both making you money and
performing a community service. They may be supplying that overnight base
power.
i
Lastly, 3-phase power is slightly more efficient than single phase, making heat
pumps both cheaper and more efficient.
BTW - I am quite disturbed with the urgency to pass this new ordinance without a good technical
vetting, rather than take the time to get it right. A much more serious technical review was
needed rather than depend on the unvetted San Jose regulations. The council as much as
admitted they are doing an inadequate job by pressing counsel on how easily it could be
amended later.
Thanks and Regards,
Robert Lipp
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