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Comments to NYSERDA on Proposed Cost-Effectiveness Test for Updates to the State Energy Conservation Construction Code

The Institute for Policy Integrity submitted comments to the New York State Energy Research and Development Authority (NYSERDA) regarding its proposal for a new cost-effectiveness test for updates to the state energy conservation construction code. The Advanced Building Codes, Appliance and Equipment Efficiency Standards Act of 2022 amended New York’s Energy Law to state that New York policy is, in addition to encouraging conservation of energy, “to promote the clean energy and climate agenda, including but not limited to greenhouse gas reduction….” The 2022 law modified New York’s Energy Law to specify that the consideration of the cost-effectiveness of any code updates proposed by New York State Fire Prevention and Building Code Council (the Code Council) must consider, among other important factors, “secondary or societal effects, such as reductions in greenhouse gas emissions.”  

We recommended that:

  • NYSERDA and the Code Council (the Agencies) should anticipate that the Department of Environmental Conservation’s social cost of greenhouse gases methodology will likely change and improve over time.
  • The Agencies should amend the evaluation criteria for determining “cost-effectiveness” to include societal benefits beyond GHG emissions reductions that may be readily monetizable, particularly societal benefits from emissions of non-GHG emissions.
  • The Agencies should explain the omission of certain parameters that are relevant to privately owned buildings, and examine whether the private ownership perspective is appropriate for a methodology that is required by law to include the value of avoided greenhouse gas emissions.
  • The Agencies should confirm that the terms used in the proposed rule, particularly “lifecycle costs,” are defined and used accurately and consistently.