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Joint Comments to New York State DEC and NYSERDA on New York Cap-and-Invest Program

The Institute for Policy Integrity submitted comments (jointly with the Guarini Center on Environmental, Energy and Land Use Law) to the New York State Department of Environmental Conservation (DEC) and the New York State Energy Research and Development Authority (NYSERDA) in response to a request for comment on various recent publications and presentations concerning the future New York Cap-and-Invest Program (NYCI).
The comments recommend as follows:
  • Based on DEC and NYSERDA’s modeling results, NYCI alone is unlikely to ensure the statewide GHG emissions limits are met.
  • To enable stakeholders to contribute useful insight to the development of programs that ensure the statewide GHG emissions limits are met, DEC and NYSERDA should provide more detailed information about their assumptions, modeling, and analysis.
  • The Agencies should prepare and provide more granular analysis of building decarbonization dynamics both to appropriately target NYCI program investments and to identify complementary regulations needed for timely achievement of CLCPA GHG emissions limits.
  • The Agencies should study NYCI’s intersections with local building decarbonization policies and coordinate with local governments to support effective local and state policies.
  • The Agencies’ modeling and program proposals relating to LMI households’ energy burdens should be adapted to better align with LMI households’ energy spending experience.
  • Given infrastructure and institutional barriers to reducing GHG emissions associated with natural gas, DEC and NYSERDA should give the Public Service Commission clear direction on the magnitude of reductions needed in that sector.
  • To protect disadvantaged communities against disproportionate impacts, the Agencies should implement measures that target the harm caused by co-pollutants.