Memorandum in Support - S.2352-A (Parker) / A.2720-A (Cusick)

AN ACT to amend the energy law, in relation to directing the state energy planning board to conduct a study of the technical and economic feasibility of a one hundred percent renewable energy system and a reduction in greenhouse gas emissions

The Independent Power Producers of New York, Inc. (IPPNY) is a trade association representing companies involved in the development of electric generating facilities, the generation, sale, and marketing of electric power, and the development of natural gas facilities in the State of New York. IPPNY Member companies produce more than 60 percent of New York's electricity, utilizing almost every generation technology available today such as wind, solar, natural gas, oil, hydro, coal, biomass, and nuclear.

IPPNY supports S.2352-A (Parker) / A.2720-A (Cusick). This legislation would require the State Energy Planning Board to determine the technical and economic feasibility and electric system reliability impact of meeting a 100 percent renewable energy goal by 2030 or by 2050, along with a 100 percent greenhouse gas emission (GHG) reduction goal from 1990 levels by 2050, including an incremental target of at least a 50 percent reduction from 1990 levels by 2030. The bills would evaluate whether and how these goals could be implemented in a way that preserves electric system reliability and protects consumers. This legislation would require the State Energy Planning Board to conduct the study by September 1, 2020, and there would also be a public hearing and comment process on the study, as required under the existing Energy Planning Law.

According to data from the New York State Energy Research and Development Authority (NYSERDA), from 1990 through 2015, the power sector already has reduced GHG emissions by 53.8 percent. However, in that same span of time, emissions from the transportation sector grew by 22.2 percent, and emissions from the residential sector increased by 3.8 percent. Also, since 2000, power plant emissions of sulfur dioxide are down 99 percent and nitrogen oxides declined by 88 percent. Other sectors of the economy have a long way to go to meet the emission reductions accomplished by the power sector, and the evaluation under this legislation would analyze the efficacy and cost of those needed reductions by residents and businesses, especially since most of them rely upon gasoline powered transportation which results in emissions.

In 2017, the New York State Department of Environmental Conservation and NYSERDA were directed to undertake a comprehensive study to determine the "most rapid, cost-effective, and responsible pathway to reach 100 percent renewable energy statewide,” and this study still has not been made public. The analysis under this legislation is consistent with the intent of that study and would provide more specifics for how it would be done.


Pursuant to its order issued in August of 2016, the New York Public Service Commission’s Clean Energy Standard (CES) requires that 50 percent of all electricity used in the State be generated from renewable energy resources by 2030. Looking at how much renewable energy supply would need to be added to meet the existing CES helps put into context the need for a determination of the technical and economic feasibility of achieving a goal that is double that current amount. According to the most recent data from the New York Independent System Operator, Inc. (NYISO), in 2017, 28 percent of New York’s power came from renewable resources.  Hydroelectric facilities that were built generations ago provide 23 percent of the State’s power. The New York State Department of Public Service and the NYISO have estimated that a mix of 12,000 megawatts (MW) to 17,000 MW of new renewables would need to be developed to meet the current 50 percent requirement by 2030. Between 2000 and 2018, the NYISO reports that 11,846 MW of generating capacity was added from all resource types. 2030 is only 11 years away, and, to meet the existing CES goal, New York must add more than the amount of capacity added during an 18-year period – and the new capacity only can come from carbon-neutral sources.

NYSERDA and the New York Power Authority (NYPA) have issued awards as a result of their Requests for Proposals (RFP) to make progress toward implementing the current CES. Through NYSERDA’s two solicitations, 46 projects were given awards, totaling 3,037 MW of new, renewable capacity, and NYSERDA intends to issue another RFP in April of this year. NYPA’s RFP award was for 290 MW of renewable capacity. Clearly, more private sector development continues to be needed, yet local opposition to infrastructure projects of all types (including wind and solar) abounds.

Importantly, the State Energy Planning Board includes the NYISO, who is responsible for ensuring electric system reliability, and this legislation would require the Board to examine the reliability impact of meeting the goals under the bills. The needed emission reductions would result in the elimination of gas-fired baseload electric generating facilities and of dual fuel (natural gas and oil) peaking facilities. Currently, 34 percent of the State’s electricity is generated by dual-fuel resources, and 70 percent of the electricity downstate, in the most highly populated portion of the State, is produced by dual-fuel resources. These facilities are essential to the provision of reliable electricity, when energy consumers need it the most and when intermittent renewable energy facilities are not operating. The study under this legislation would determine whether and how electric system reliability could be maintained without these current resources or with resources that could be carbon-neutral. Energy storage facilities are in the process of being developed, and other resources capable of filling reliability gaps still will be needed in the interim.

The study under this legislation would allow informed decision-making on how to increase the use of renewable energy resources and to reduce GHG by all sectors of the economy in the most efficient and cost-effective manner.  Knowing whether and how the goals could be accomplished, and at what cost, would result in the best implementation of requirements to address climate change.

For the reasons stated above, IPPNY supports S.2352-A (Parker) / A.2720-A (Cusick).

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