Recent Projects

In May 2023, the NYPSC initiated a process regarding the CLCPA's Zero Emissions Target, and the early phases of that process have focused on interpreting the 2040 goal, which is fraught with ambiguity. To date, this process has included two requests for public comment as well as a Department of Public Service technical conference. Policy Integrity has made comments throughout, and hosted a conference on state-level pathways to zero-emissions electric grids, focusing in significant part on this statutory requirement. On November 4, DPS Staff filed a document proposing definitions of key terms that aligns with Policy Integrity's recommendations and approach in key respects.

The Institute for Policy Integrity submitted comments in the New York Public Service Commission’s Proceeding on Motion of the Commission in Regard to Gas Planning Procedures, responding to a notice posing various questions about non-pipeline alternatives (NPAs). Our comments focused on how NPAs can be compared fairly to conventional infrastructure alternatives.

In December 2023, the New York State Department of Environmental Conservation and New York State Energy Research and Development Authority released the Draft Climate Act Disadvantaged Communities Investment and Benefits Reporting Guidance for public comment. The draft guidance proposed a methodology to be used by New York State agencies, authorities, and entities to account for and report the benefits of their clean energy and energy efficiency spending accrued in disadvantaged communities and across the state overall. This information will then be used to calculate the State’s compliance with the Climate Leadership and Community Protection Act’s requirement that a minimum of 35 percent, with a goal of 40 percent, of the benefits of clean energy and energy efficiency spending accrue to disadvantaged communities. In comments, we gave suggestions on how to improve the guidance.

The Institute for Policy Integrity submitted comments to the New York State Energy Research and Development Authority (NYSERDA) regarding its proposal for a new cost-effectiveness test for updates to the state energy conservation construction code. We recommended changes and clarifications that NYSERDA and the Code Council can make to improve their evaluation criteria. 

Policy Integrity submitted comments to the New York State Public Service Commission (NYPSC) regarding the section of the Climate Leadership and Community Protection Act (CLCPA) that amends the Public Service Law to add a new section (Section 66-p), which requires, among other things, that, by 2040, “the statewide electrical demand system will be zero emissions.” NYPSC had posed several questions about how it should interpret the requirements for 2040 under the new Public Service Law provision. 

The New York State Public Service Commission recently issued an order seeking input on how to achieve the state's goal of a zero-emissions electricity system by 2040, as required by the Climate Leadership and Community Protection Act (CLCPA). Policy Integrity submitted comments focused on issues such as the relationship between the Commission’s 2040 zero-emissions goal and other elements of the CLCPA, the need for analytic frameworks that rely on best available science and economics, the circumstances under which hydrogen could qualify as a zero-emissions resource, and tracking benefits to disadvantaged communities.

In 2019, New York’s Climate Leadership and Community Protection Act (Climate Act) was passed by the Legislature and signed by the Governor. The Climate Act set economy-wide greenhouse gas emissions limits and established the Climate Action Council. In its Scoping Plan, the Climate Action Council ultimately recommended implementation of a cap-and-invest program to meet the Climate Act’s emissions reduction requirements. In preparation for developing a proposal, DEC and NYSERDA conducted a preliminary stakeholder outreach process consisting of a series of online Stakeholder Feedback Sessions followed by an informal comment opportunity. Policy Integrity filed comments focused on the scope and structure of the stakeholder outreach process. 

The New York Independent System Operator (NYISO) has appointed Policy Integrity’s Executive Director, Dr. Burçin Ünel, to serve on its Environmental Advisory Council. The Council provides NYISO with information, analysis, and expert perspectives on state and federal environmental policies to help it better achieve its mission of maintaining reliability of the bulk electric system and administering competitive wholesale electricity markets. In her role on the Council, Dr. Ünel will use her expertise in utility regulation and energy policy to help NYISO build and maintain New York's “grid of the future.”

We submitted recommendations to the New York Public Service Commission regarding New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage, a document that analyzes the need to increase New York’s storage target to 6 GW and the barriers to storage deployment, and provides policy recommendations to help the state achieve 6GW of storage deployment by 2030.