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Comments to NYSPSC on Its 2040 Zero-Emissions Electricity Goal
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.
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Comments to the NY Department of Environmental Conservation and NYSERDA on Proposed Cap-and-Invest Program
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.
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Ünel Named to Advisory Council for New York Electric Grid Operator
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.”
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Comments to NY Public Service Commission on Energy Storage Roadmap
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.
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Enacting the “Polluter Pays” Principle
New York’s Climate Change Superfund Act and Its Impact on Gasoline Prices
This policy brief analyzes how New York State’s recently proposed Climate Change Superfund Act is most likely to affect consumer gasoline prices. The Act would require payments from fossil-fuel companies based on their historical contributions to current greenhouse gas levels in the atmosphere. The payments would be used to build green infrastructure to help the state adapt to climate change. The brief finds that the Act would likely have a negligible impact on current and near-term oil prices, while potentially lowering future energy prices in New York, including for transportation.
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Comments on New York PSC’s Grid Planning Process
New York's electric utilities have developed a coordinated grid planning process and an updated approach to analyzing the benefits and costs of infrastructure investments. Policy Integrity filed comments urging the Commission to recognize that compliance with the Climate Act in relation to grid planning requires, at the very least, consideration for planning decisions' impacts of global and local pollutants.
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Carbon Trading for New York City’s Building Sector
Report of the Local Law 97 Carbon Trading Study Group to the New York City Mayor’s Office of Climate & Sustainability
NYU researchers assessed whether New York City should adopt a carbon trading program for its buildings pursuant to its landmark climate law, Local Law 97 of 2019. The study offered two proposals for trading programs, both of which would benefit the City as a whole, and environmental justice communities in particular, and found that both proposals would lead to deeper GHG reductions and lower the cost of complying with LL97.
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Comments to New York PSC on Climate Change Vulnerability Assessments
We submitted comments to the New York Public Service Commission to voice our support for a petition concerning the impacts of climate change on utility infrastructure. Our comments emphasize that it is imperative for public utilities to identify and assess the risks that climate change poses to their assets and operations.
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Comments to NYISO on Buyer-Side Mitigation Reforms
In a recent presentation, the New York Independent System Operator (NYISO) posed key questions related to potential buyer-side mitigation reforms. We submitted comments that provide three recommendations to NYISO.
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Comments to New York PSC on Gas Planning Procedures
The New York Public Service Commission requested input on its Staff Gas System Planning Process Proposal. We submitted comments encouraging the Commission to add several minor requirements and directly address the legal tensions and ambigious policies that make planning decisions more challenging.
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