Legislative Memos

IPPNY opposes A.10236-A (Galef) / S.8154-A (Harckham). The legislation is pre-empted by the jurisdiction of the Nuclear Regulatory Commission (NRC) and other federal agencies over the decommissioning of nuclear power plants and the use of their nuclear decommissioning trust (NDT).

IPPNY supports A.10006 (Cusick). This legislation would enhance protection of critical infrastructure, such as power plants, from cyberattacks. Among other provisions, the bill would amend existing law on the power and duties of the Division of Homeland Security and Emergency Services, and it would add cyberattacks to the list of parameters for which an assessment of the vulnerability of critical infrastructure (including, but not limited to, power plants and now, under the legislation, industrial control systems) would be done and for which protective strategies would be developed.

IPPNY supports A.7682 (Cusick) / S.6195 (Parker). The bills would establish: (a) minimum cybersecurity and safety standards; and (b) minimum cybersecurity insurance requirements, which would be applicable to third parties seeking to connect to any electric or gas corporation's systems to receive consumption or other data. The legislation would require the New York State Public Service Commission to promulgate rules and regulations by January 1, 2021 to ensure the implementation and enforcement of the bills’ provisions.

IPPNY opposes A.7569-B (Galef). The legislation conflicts with, and is pre-empted by, federal labor law, and it would establish a damaging precedent for all types and sizes of businesses. The legislation specifically would require employees at the Indian Point Nuclear Power Plant to be paid prevailing wages. The bill would require the successor owner of the Indian Point facility to retain its workforce. The legislation would require the Department of Labor to oversee the payment of prevailing wage to employees at Indian Point until the facility is closed.

IPPNY strongly opposes S.6112 (Parker) / A.7376 (Cusick). These bills would allow utilities (combination gas and electric corporations) to own "renewable reclamation projects," in contravention of long-standing State policy that prohibits utility ownership of electric generating facilities, which could expose ratepayers needlessly to higher costs. The bills send the wrong investment signal to private independent developers of renewable energy and energy storage projects at exactly the wrong time, when the State has announced its goals to dramatically increase its renewable and energy storage resources and is seeking private sector investment to meet those goals. If adopted, these bills would have the immediate impact of chilling private sector energy investment in the state because private developers cannot compete with rate-regulated utilities that charge energy consumers for all costs.

One of the most essential aspects to consider under the Climate and Community Protection Act (CCPA) is the role of carbon offsets. The implementation of offsets allows for the continued use of efficient facilities that are the backbone of our reliable electric system while accounting for their emissions. Furthermore, the economy-wide approach needed to significantly cut emissions requires the flexibility for implementation that can be provided by offsets.

IPPNY supports S.2352-B (Parker) / A.2720-B (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 and publish 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.

Addressing climate change and transitioning New York to a new energy future are important issues, and we appreciate the fostering of conversations on how the Climate and Community Protection Act (CCPA) can address those topics. Senator Kaminsky, holding hearings, welcoming comments on such a complex topic, and recognizing this is an energy matter just as much as an environmental matter are reasoned and appropriate steps towards a practical solution.

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.

IPPNY strongly opposes Parts FF and GG of A.9508 / S.7508. This Budget language would significantly expand the New York Power Authority's (NYPA or Authority) authority to provide energy-related projects, programs and services and to develop, own and operate new renewable electric generating facilities in the State. This Budget language could result in higher costs for energy consumers and sends the wrong signal to the private sector whose investment is critically needed to meet the State's renewable energy, energy storage, and emission reduction goals.