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Our Work on State Zero-Emission Credits Programs
Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.
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Comments to the New York Public Service Commission on Resource Adequacy
We submitted comments to the New York Public Service Commission on the state’s resource adequacy needs, discussing how policies can best be aligned under existing mechanisms.
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Court Upholds New York’s Zero-Emissions Credit Program for Nuclear Power
The Albany County Supreme Court rejected a challenge to New York’s Zero-Emissions Credit (ZEC) program, which pays nuclear power plants for the value of avoided carbon emissions. The legal challenge focused largely on the state’s decision to use the Interagency Working Group’s Social Cost of Carbon (SCC) to value emissions.
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Comments to FERC on NYISO and Energy Storage Resources
A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.
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Comments on New York State Energy Storage Roadmap
In June 2018, the New York State Department of Public Service and the New York State Energy Research and Development Authority released the New York State Energy Storage Roadmap, outlining a series of recommended approaches to achieve Governor Cuomo’s statewide energy storage target of 1,500 MW by 2025. Our comments, based on our Managing the Future of Energy Storage report, generally support the overall approach to reward energy storage systems for all the values they can bring to the electric system, to allow dual participation in both wholesale and retail electricity markets, and to improve price signals to maximize the benefits of energy storage systems.
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