In a hotly contested rulemaking, the Air Quality Control Commission (AQCC) added a list of sweeping demands on Colorado’s large buildings. As part of this rulemaking the AQCC had to prepare a series of responses to various questions. For example, this rulemaking included an answer to the prompt “To the extent practicable, a description of the probable quantitative and qualitative impact of the proposed rule, economic or otherwise, upon affected classes of persons.”
It’s tempting to think, if you’ve never sat down and read reports like these, that the people who prepare them know exactly what they’re doing. They are experts after all. Therefore, if the AQCC says that building owners will save $3.60 for every $1 they spend, you might not understand how flawed and incomplete a number like that can be. After all, the world is replete with studies where expert forecasts don’t quite pan out. The Soviets didn’t act like the CIA thought they would. A random list of stocks outperforms the portfolio assembled by top people at a mutual fund. Energy and cost estimates are no different and we should be just as skeptical.
When my physics students do lab reports, I often tell them that I will not grade them on getting the exact result. But, I insist they be clear about–and reckon with–their choices, their assumptions and the boundaries of where their results are valid (or not). If the AQCC handed in their recent report as a lab to me, they’d summarily get it handed back and be told to try again.
Missing from the analysis is that roughly 20% of that savings is from the social cost of carbon. Let’s put aside the nebulous and variable nature of that number for a second and think about reality. Colorado doesn’t live under a hermetically-sealed dome. We can reduce carbon here and still end up with more problems because our atmosphere moves and we live in a world with others. Perhaps reducing any carbon anywhere benefits us all, but the AQCC doesn’t note that 20% of the benefit will be global altruism, not specific to Coloradans.
In preparing this report, the AQCC also leans heavily on a study they farmed out to researchers from the Lawrence Berkeley National Laboratory and the Pacific Northwest National Laboratory. These are smart folks indeed, but they’re not omniscient, and I wonder how much practical, real-world experience they have.
In order to make any progress, the researchers had to make their cows spherical: they reduced the complexity of reality to make their task feasible. Unfortunately, this comes at the cost of their results’ applicability to reality. They smeared out the details of all the estimated 8000 newly-regulated buildings. They averaged. They modeled and assumed. In short, they did as told, but did so at the expense of details. And those details matter. They matter greatly.
Buildings, like humans, are different. You might estimate that a certain number of buildings will install a device that recaptures heat from the wastewater in a shower (yes, that’s a thing), but, as anyone who has ever done actual work in construction can tell you, the installations might vary greatly in cost. In one building it slides right in lickety-split. In another, installing it might require moving light fixtures, ducts, etc. Not so cheap then! This kind of dynamic is not accounted for in reports like those prepared for the AQCC. To wit, consider the cost estimate of updating existing gas-powered equipment to newer, more efficient models. That number is simply burped out on the page as $0.34/sq foot. I would ask why not 35? Why not 25? Why not 40? There was neither rationale nor acknowledgement that this cost will be more for some and less for others.
This last example requires a little bit of context, so stay with me. Heat pumps, often cited as a replacement for gas-powered appliances, are rated by their coefficient of performance (COP). The COP tells you how much heat you get for every unit of energy you have to put in. For a COP of 2.5, you get 250 units of heat in your building, but only provide 100. This is fantastic savings indeed, of both energy and money. Not hard to imagine that this would help reach that greater than 1:1 ratio of defray the cost of switching.
Unclear, however, in the report, is whether this is also fantastic in the other sense of the word. In climates like Colorado’s, heat pumps don’t have COPs of 2.5 all year long. As it gets colder they drop to 1, and your heat pump is an electric space heater–one unit of energy in and one out. Perhaps in the Fall and Spring you’d have some savings, but would the numbers the AQCC still hold if you include this detail?
I did call a researcher at each lab to ask them these things about their report. I haven’t gotten a call as of this writing and doubt I will. The seeming goal here is not accuracy or transparency, it’s getting something on paper with a nice topline to feed to a credulous media so they can in turn move on to their next “something on paper” for their job.
Those of us who don’t own large buildings need to remember that the savings goes to the building owner. We’re going to get higher prices due to higher overhead costs, and we (or our children whose future will get mortgaged) will get to pay higher taxes to subsidize the savings via grants and incentives. Since we get to pay, we should have better, and better means full disclosure even if that means uncertainty or acknowledging that we’ll be paying higher prices for our decisions.
