New York State Zero-Emissions Attributes Comments
We recently submitted comments to the New York State Department of Public Service Staff regarding their Responsive Proposal for Preserving Zero-Emissions Attributes. This Proposal offers recommendations on how to achieve New York’s clean energy target: 50 percent of all electricity used in the state by 2030 should be generated by renewable energy sources.
In valuing and compensating clean energy resources, it is important to have consistency across different types of resources. Our comments explain that while using the Social Cost of Carbon to value zero-emission attributes of energy resources is a correct approach, the Commission should be consistent in its valuations to avoid distortion of the relative value of different types of resources, which could lead to artificially low valuation of renewable energy sources.