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Comments on New York State Clean Energy Standard Petitions

We recently submitted comments to the New York State Public Service Commission, responding to petitions for rehearing on the Clean Energy Standard. The Commission’s Clean Energy Standard created Zero-Emissions Credits for nuclear generation, compensating these zero-emissions generators through a valuation system based on the Social Cost of Carbon (“SCC”). Various parties submitted petitions for rehearing or clarification, and criticized the Order on a variety of grounds. Among other criticisms, challengers argue that it was inappropriate for the Commission to use the SCC to value the zero‐emission attributes of nuclear energy resources alone, and that other types of low‐ emitting resources (e.g., small hydro) should receive commensurate payments for their zero‐emission characteristics.

Our comments explain that the Commission should continue using the SCC to value the zero‐emission attributes of nuclear plants, because the SCC is the best available estimate of the monetary value of the marginal external damage of carbon emissions, and is therefore the economically correct approach. Additionally, we explain that the Commission should strive to promote consistency in the way it values the clean energy attributes of all other energy resources, by reevaluating the subsidies to apply more uniformly across resources.