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Comments to NYSPSC on Its 2040 Zero-Emissions Electricity Goal

The New York State Public Service Commission recently issued an order seeking input on how to achieve the state's goal of a zero-emissions electricity system by 2040, as required by the Climate Leadership and Community Protection Act (CLCPA). Policy Integrity submitted comments focused on issues such as the relationship between the Commission’s 2040 zero-emissions goal and other elements of the CLCPA, the need for analytic frameworks that rely on best available science and economics, the circumstances under which hydrogen could qualify as a zero-emissions resource, and tracking benefits to disadvantaged communities.

The comments make several key points:

  • The Commission's efforts to achieve the 2040 zero-emissions target must be coordinated with other state agencies like the Department of Environmental Conservation (DEC) to support economy-wide emissions reductions under the CLCPA. The Commission should use the best available science and methodologies aligned with DEC, including adopting DEC's Social Cost of Carbon valuation for analytic purposes.

  • For hydrogen to qualify as zero-emissions, it must have zero lifecycle greenhouse gas emissions. This requires both zero emissions during production and controlling leakage emissions. Currently, the only form of hydrogen meeting this standard is green hydrogen produced via electrolysis powered entirely by renewable electricity. Rigorous verification protocols are needed to ensure grid-connected electrolyzers actually use zero-emissions marginal electricity.

  • The climate impacts of leaked hydrogen cannot be ignored. As an indirect greenhouse gas, leaked hydrogen contributes significantly to warming. The Commission should evaluate whether leakage rates allow hydrogen to qualify as zero-emissions given its high global warming potential.

  • Benefits to disadvantaged communities, which the CLCPA mandates, should be defined in coordination with other agencies and with stakeholders. These benefits should be tracked and visualized using mapping tools overlaying clean energy investments and disadvantaged community boundaries.