Institute for Policy Integrity logo

Recent Projects

Comments to NYPSC on CLCPA’s Zero-Emissions Amendments to Public Service Law

Policy Integrity submitted comments to the New York State Public Service Commission (NYPSC) regarding the section of the Climate Leadership and Community Protection Act (CLCPA) that amends the Public Service Law to add a new section (Section 66-p), which requires, among other things, that, by 2040, “the statewide electrical demand system will be zero emissions.” NYPSC had posed several questions about how it should interpret the requirements for 2040 under the new Public Service Law provision. 

Our comments suggested that:

  • The term "zero emissions," as used in Section 66-p of the Public Service Law, should be interpreted to refer exclusively to greenhouse gas emissions.
  • The requirement that the statewide electrical demand system be zero emissions in 2040 should be understood as part of the CLCPA’s “comprehensive regulatory program to reduce greenhouse gas emissions.”
  • The Commission and the Department of Environmental Conservation (DEC) should work cooperatively to ensure that the CLCPA’s comprehensive regulatory program, which includes the DEC’s program as well as the PSC’s program, addresses all statewide greenhouse gas emissions, including emissions associated with imported electric generation and behind-the-meter generation.