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Comments to New York State on Clean Energy Standards for Existing Generators

New York State plans to provide support to some existing small hydro, wind, and biomass generation facilities at risk of closure, in order to prevent the state from backsliding on its ambitious clean energy goals. The New York Public Service Commission released a report on the Clean Energy Standard Tier 2 Maintenance program, which focuses on the criteria a generator should meet in order to receive financial support and how these payments should be determined.

Our comments on the report encourage the Commission to harmonize these payments across all proposed review processes for Tier 2 generators. We also encourage the Commission to consider how the program will interact with other energy initiatives in the state, including a potential carbon charge on wholesale electricity markets and a program that values the environmental benefits of distributed energy resources. These changes would enhance the program’s economic efficiency and help ensure that the state meets its decarbonization goals.