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Comments to New York DEC and NYSERDA on Draft Climate Act Disadvantaged Communities Investment and Benefits Reporting Guidance

In December 2023, the New York State Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA) released the Draft Climate Act Disadvantaged Communities Investment and Benefits Reporting Guidance (Draft Guidance) for public comment. The Draft Guidance proposed a methodology to be used by New York State agencies, authorities, and entities to account for and report the benefits of their clean energy and energy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 (CLCPA) 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 our comments, we offered the following recommendations:

  • The final guidance should include clear definitions for defined terms that are part of the benefits-of-spending metric, and establish a reporting methodology that aligns with the relevant statutory provision.
  • The methodology presented in the section for estimating health impacts from electricity savings is unclear, and DEC and NYSERDA should provide a detailed example to improve clarity and comprehension.
  • Overall, DEC and NYSERDA should refine the discussions about their methods for calculating health benefits and include illustrative examples to demonstrate how their methodology can be applied in different scenarios.
  • DEC and NYSERDA should consider analyzing health benefits at a more granular scale than at the county level.
  • DEC and NYSERDA should issue a revised version of the Draft Guidance for public comment before finalizing the guidance.