Carbon Free New York's Response to the State's Draft Scope
November 25, 2024
To The New York State Energy Planning Board:
Carbon Free New York (CFNY) is pleased to submit comments in response to the Draft Scope of the New York State Energy Plan. As a coalition inclusive of generators, developers, environmental organizations, and labor unions dedicated to advancing a carbon-free economy through a balanced, sustainable energy framework, we recognize the critical importance of the Climate Leadership and Community Protection Act (CLCPA) and are committed to ensuring New York meets its ambitious decarbonization goals.
CFNY advocates for a New York State Cap-and-Invest Program, inclusive of the power sector, which represents a critical step towards aligning carbon emission reductions with economic growth and environmental stewardship. By capping total emissions and allowing the exchange of emission allowances, this program not only ensures that New York stays on track to meet its climate targets but also encourages cost-effective solutions, technological innovation, and continued clean energy development.
We commend the State Energy Planning Board for releasing a Draft Scope that outlines a comprehensive approach to balancing climate action with energy reliability, public health, economic development, and equity. While the Draft Scope lays a strong foundation, CFNY would like to note several critical areas that require additional attention, including grid reliability and modernization, clean energy deployment, the equitable distribution of benefits, and workforce development.
Decarbonization and Climate Targets
New York is at a pivotal moment in its clean energy transition, with the CLCPA mandating reductions in greenhouse gas (GHG) emissions of 40% by 2030 and 85% by 2050, along with a 100% zero-emissions electricity system by 2040. Despite the recent biennial Clean Energy Standard (CES) review indicating we are currently behind our interim targets, we believe it is far too early to consider this an insurmountable setback. With concerted efforts and innovative solutions, we can still achieve New York’s clean generation goals.
CFNY strongly supports the accelerated deployment of clean energy resources, as these are critical to achieving the CLCPA’s targets. Meeting these targets requires immediate and decisive action to ensure that these resources are scaled efficiently and equitably across the state. As one example, New York has doubled its solar energy capacity over the past five years, and we still need continued investment to meet the projected demand for carbon-free energy.
To meet New York’s clean energy targets and complement a deeply renewable grid, NYISO estimates that the state will need at least 20, and upwards of 40, gigawatts of Dispatchable Emissions-Free Resources (DEFRs) by 2040 to support the grid during periods of intermittent energy generation and high demand as existing fossil generation is taken offline.,
The Draft Scope rightfully acknowledges the importance of decarbonization but must provide more detail on the role of emerging DEFR technologies and the pathways to integrate them into New York’s energy system. As highlighted in CFNY’s response to the Clean Energy Standard Biennial Review, continued investments in renewables and expanding investments in additional resources are essential for ensuring the reliability of the grid.
More on the Role of Cap-and-Invest
A Cap-and-Invest Program is designed to set a firm limit on carbon emissions while incentivizing the adoption of cleaner energy sources through market price signals. Cap-and-invest will provide a natural complement to state and federal programs that support and expand the supply of carbon-free energy by maintaining a meaningful economic incentive to limit carbon emissions.
Such a market-based approach has a long history2 in emissions reduction programs. New York’s Cap-and-Invest program will play a pivotal role in:
Accelerating Clean Energy Deployment: By capping carbon emissions, the program will drive investments towards clean energy resources, enhancing revenue certainty and accelerating the deployment of carbon-free projects.
Economic Growth and Job Creation: The program will stimulate economic growth by creating high-quality green jobs in carbon-free infrastructure, energy efficiency, and clean technology sectors.
Improving Public Health and Environmental Justice: Reducing emissions, particularly from fossil fuel plants in disadvantaged communities, will significantly improve air quality and public health outcomes.
Ensuring Efficient Infrastructure Investments: Incentivizing cost-effective investments in grid-support infrastructure will enhance system-wide reliability and ensure the efficient delivery of clean energy.
Fostering Innovation and Technological Advancement: The Cap-and-Invest program will foster innovation, encouraging the development of new technologies, products, and services.
Providing Regulatory Certainty: By structuring a cap-and-invest program around CLCPA goals, the State provides welcome long-term certainty that stakeholders can use in planning and risk analysis.
CFNY agrees with the Independent Power Producers of New York (IPPNY) that this Cap-and-Invest program can be successfully integrated with the Regional Greenhouse Gas Initiative (RGGI) with reasonable controls against double-charging electricity generating companies.
New York should remain in RGGI to ensure the program’s continued success during the introduction of the State’s Cap-and-Invest program and due to the proven benefits of participation in a regional carbon market. However, the electricity generating companies that are covered by RGGI should receive a credit (i.e. rebate) of their RGGI compliance costs by rebating the average RGGI allowance auction cost for a year to each generating company based on its RGGI-related emissions in that year. This will ensure that, between RGGI payments and Cap-and-Invest payments, the generating company would pay a total emission cost consistent with the Cap-and-Invest program. In the unlikely possibility that RGGI has a higher allowance price than Cap-and-Invest, the rebate could be limited to the Cap-and-Invest allowance price.
Grid Modernization and Renewable Energy Integration
The success of New York’s decarbonization efforts is contingent upon the modernization of its electric grid. New York’s electricity system has undergone significant changes, and with the right strategies, we can navigate the current challenges posed by global interest rates, inflation, and supply chain pressures.
CFNY applauds the emphasis on grid investments in the Draft Scope and we urge the State Energy Planning Board to prioritize rapid modernization through smart grid technologies, energy storage, and critical transmission upgrades. These investments are not just desirable; they are necessary to ensure the state can scale its renewable energy capacity while maintaining reliability.
As noted in CFNY’s response to the Cap-and-Invest framework, modernizing the grid to accommodate renewable energy resources—particularly in regions experiencing transmission congestion—is essential. NYISO has identified grid congestion as a significant challenge, especially with the expansion of large-scale renewables.2,
By enhancing grid flexibility, reliability, and capacity, we can better integrate intermittent renewable resources while ensuring the continuous delivery of clean energy across the state. The state must address these bottlenecks by advancing smart grid technologies and expanding transmission lines to ensure efficient energy distribution. These upgrades will facilitate a safe, efficient flow of carbon-free energy from where it’s generated to where it’s needed most, helping to balance supply and demand.
Environmental and Climate Justice
The Draft Scope's focus on environmental and climate justice is vital for ensuring that historically marginalized communities benefit from New York’s clean energy transition. Disadvantaged Communities (DACs) must not only share in the environmental benefits of reduced pollution but also in the economic gains from job creation and energy cost savings.
CFNY strongly supports the Climate Act’s mandate that a percentage of the benefits of clean energy investments accrue to DACs. Programs like the expanded NY-Sun initiative, which aims to bring solar energy and its economic benefits to DACs, are important steps toward achieving these goals. However, the Draft Scope must further elaborate on the mechanisms to ensure DACs receive these benefits.
Clean Energy Jobs and Economic Development
The clean energy transition presents a unique opportunity for economic growth and job creation in New York. According to a report from NYSERDA, the state’s clean energy economy has grown by 8% over the past three years. This growth is expected to accelerate as investments in carbon-free energy, energy efficiency, and grid modernization increase. CFNY fully supports efforts to foster workforce development programs that will equip New Yorkers with the skills they need to succeed in the clean energy sector.
CFNY commends the focus on clean energy jobs in the Draft Scope, particularly in light of New York’s commitment to just transition principles. However, achieving the full potential of clean energy job growth will require a more detailed strategy to expand workforce development and training programs.
The Draft Scope should emphasize training for workers transitioning from fossil fuel-dependent industries and prioritize the recruitment of individuals from DACs. CFNY encourages the State to leverage partnerships with labor unions and educational institutions to create robust training pipelines for clean energy jobs. Emerging sectors provide opportunities for high-quality, well-paying jobs, and investments in these sectors need to be tied to labor standards that ensure job quality.
Public Health and Safety
One of the most significant co-benefits of transitioning to a clean energy economy is the potential to improve public health outcomes by reducing pollution from fossil fuel power plants. Communities located near these plants, particularly in disadvantaged areas, have been disproportionately affected by higher rates of respiratory diseases such as asthma and cardiovascular conditions. The Department of Environmental Conservation (DEC) highlights that areas surrounding fossil fuel plants suffer from significantly worse air quality, leading to adverse health effects, especially in urban and frontline communities.
Reducing emissions through the deployment of cleaner energy sources will not only advance New York’s climate goals but will also lead to significant improvements in air quality and public health. The CLCPA’s focus on reducing emissions in DACs will be critical to addressing long-standing health disparities. Additional investments in air quality monitoring and mitigation efforts would ensure that these improvements are realized equitably across the state. To that end, programs that focus on air quality in urban areas should be prioritized to further reduce public health burdens associated with fossil fuel emissions.
Energy System Reliability and Resilience
As New York continues to decarbonize its energy system, ensuring grid reliability and resilience becomes increasingly essential. The rising frequency of extreme weather events, driven by climate change, poses significant risks to the grid. Heatwaves, hurricanes, and severe storms will continue to stress the energy system. Electrification increases demand while introducing new variations –– electrifying transportation creates charging demand at new times of day and building electrification varies with weather.
CFNY strongly supports the state’s emphasis on building resilient infrastructure, including investments in advanced energy storage systems, grid hardening technologies, and climate adaptation strategies. These systems will be critical in maintaining energy supply during periods of high demand and ensuring resilience in the face of climatic events. Long-duration energy storage (LDES) solutions as well as previously discussed DEFRs are particularly important for providing firm, reliable power.
As electrification drives higher electricity demand, especially from the transportation and building sectors, these investments must ensure that the grid remains stable and can meet peak demand under extreme conditions. CFNY urges the state to continue prioritizing investments in smart grid technologies, real-time energy management systems, and new forms of dispatchable, clean power to ensure that the energy system can withstand both climatic and operational challenges.
Technological Innovation and Emerging Solutions
New York’s leadership in clean energy innovation must continue to foster the development of cutting-edge technologies. As noted in CFNY’s comments on the Cap-and-Invest framework, fostering innovation through public-private partnerships and R&D investment will be essential for achieving the state’s long-term decarbonization goals.6
The Draft Scope outlines the importance of supporting innovation, but it should also set specific targets for the commercialization of these technologies. CFNY encourages the state to continue funding pilot programs and demonstrations of new clean energy technologies, and encourages the state to also explore opportunities for cross-sector innovation.
Path Forward
CFNY commends the New York State Energy Planning Board for its thorough and forward-thinking Draft Scope. To fully achieve New York’s ambitious climate and energy goals, the plan must place a greater emphasis on grid modernization, equitable distribution of benefits, and the rapid deployment of emerging clean energy technologies.
We believe that with sustained commitment, strategic investment, and inclusive policies, New York can still meet its ambitious climate goals. The path to a carbon-free New York is challenging, but it is achievable, and together, we can propel New York to the forefront of clean energy leadership.
Thank you for your consideration.
Sincerely,
Carbon Free New York
ACE NY
AES
APEX Clean Energy
American Wind Energy Association (AWEA)
Citizens' Climate Lobby New York
ConnectGEN
Constellation
CS Energy
Cypress Creek Renewables
EDF Renewables
EDP Renewables
East Light Partners
Egg Geo
Healthy Planet
International Union of Operating Engineers Local 30
Invenergy
Key Capture Energy
New York State Building & Construction Trades Council
New York State Pipe Trades Association
UBC Millwrights
United Brotherhood of Carpenters
U.S. Green Building Council - Long Island Chapter
National Hydropower Association (NHA)
Northland Power
Nuclear New York
New York Energy and Climate Advocates
New York League of Conservation Voters (NYLCV)
New York State Laborers Organizing Fund (LiUNA)
ReEnergy
RWE
Solar Energy Industries Association (SEIA)
Shell Energy
Upstate Energy Job