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Gavin Donohue's Written Statement on the Climate Action Council Draft Scoping Plan

IPPNY’s Gavin Donohue provided written feedback on an initial version of the draft Plan and has issued a statement on the top tier issues within the draft Plan. In terms of areas of concern for which additional Council resolution is needed, the statement emphasizes the importance of having the finalized Plan ensure energy reliability and consumer affordability. The statement also commends the State for finally beginning a robust discussion of the NYISO’s carbon pricing proposal, upon which it long has been silent.

In the area of reliability, the statement emphasizes the need for zero-emission dispatchable resources to maintain reliability. Even though the draft Plan does discuss this provision, it stops short of having it be an actual recommendation, and it fails to mention the joint petition (Member Alert # 49-2021) that IPPNY submitted with labor unions to the PSC to ask for the creation of a competitive program for the development of these technology solutions, as was acknowledged to be necessary by both the State’s consultant and the NYISO. Another concern with the document is that it includes cursory discussion of the need to maintain existing renewable facilities by briefly mentioning the CES Maintenance Tier and omitting discussion of the need to improve the Competitive Tier 2 program, as the statement underscores.  The draft Plan mentions moratoriums on the permitting of new fossil fuel plants and natural gas infrastructure, but they are not a Council-wide recommendation. IPPNY continues to oppose moratoriums, and the statement points out that the Article 10 power plant siting law and DEC’s existing regulations ensure that continued operation of facilities in a manner that is consistent with the CLCPA until the DEC’s regulations to implement the Scoping Plan are adopted in 2024. Additionally, the document does not ban cryptocurrency mining and instead includes provisions for the State to find ways to help energy intensive businesses to comply with the CLCPA’s targets.  

In terms of consumer affordability, the draft Plan includes provisions for a macro-economic examination of the societal costs and benefits of the draft Plan and concludes that more benefits will result in a way that far outweigh the costs; however, the statement points out that this high-level analysis does not provide consumers with practical information about what it will cost them to comply with the draft Plan’s provisions and how to afford paying for those costs.