Recent Projects – New York

The New York State Energy Research and Development Authority and Department of Public Service Staff recently proposed modifications to New York's Tier 1 Index Renewable Energy Credit program—the mechanism through which the state procures new large-scale renewable development. The updates aim to save ratepayers money by reducing the need for developers to incorporate costly risk premiums into their REC bids. In our comments, we argue the agencies’ proposal relies on some unexplained assumptions and outdated EPA data.

On June 29, 2026, the New York Independent System Operator (NYISO) filed revisions to its pricing system to comply with Federal Energy Regulatory Commission (FERC) Order 1920's requirements for transmission providers to engage in long-term, holistic transmission planning. Policy Integrity explains that NYISO's compliance filing may not be consistent with Order 1920 because NYISO's current methods do not consider ways in which transmission can meet New York State's resource adequacy needs. Policy Integrity further comments that NYISO can address this defect in its compliance filing and improve its transmission planning process by adopting modeling tools that account for the interdependency of transmission, generation, and storage.

When the New York legislature enacted the Climate Leadership and Community Protection Act (CLCPA) in 2018, it took no action to resolve tensions between existing legal frameworks and the state’s new climate policy. These tensions threatened to undermine the new law’s effectiveness. The Department of Public Service has now floated revisions that would give effect to the statutory changes. In these comments, Policy Integrity emphasizes the urgency of this issue and commends the general approach in the proposed revisions.

In 2016, New York established the Zero-Emission Credit (ZEC) program to preserve the carbon-dioxide emissions avoidance of nuclear generators that were at that time at risk of closing. Policy Integrity’s comments argue that the Commission, in extending the ZEC program, must update its valuation of avoided carbon dioxide emissions to align with the best available science and economics, specifically by adopting the Social Cost of Carbon value promulgated by the New York State Department of Environmental Conservation in its April 2025 guidance.

Policy Integrity submitted comments to the New York Department of Environmental Conservation (DEC) regarding the Mandatory Greenhouse Gas Reporting Rule that DEC has proposed. Our comments propose modifications to the rule in order to ensure accurate, useful data collection, and to ensure resilience in the face of federal regulatory changes.

New York's Environmental Justice Siting Law aims to protect disadvantaged communities from disproportionate pollution burdens by calling for amendments to the State Environmental Quality Review Act (SEQRA). To support agencies’ efforts to follow the revised SEQRA process, the New York Department of Environmental Conservation (DEC) created the Disadvantaged Communities Assessment Tool (DACAT), a screening tool that is meant to assist agencies in the disproportionate pollution burden assessment, and a workbook that describes DACAT and guides applicants on how to complete environmental assessment forms. Policy Integrity offered several comments to DEC regarding DACAT.