July 26, 2016
by Bob Ciesielski
Last year, the NYS Energy Plan (SEP) set goals to produce 50% of the state’s electricity from renewable energy sources by 2030, reduce greenhouse gases 40% from 1990 levels by 2030, and gain 23% in energy efficiency from 2012 levels by 2030. On January 25, 2016, the Department of Public Service (DPS) issued its “Staff White Paper on Clean Energy Standard” with proposed mechanisms to implement the SEP. The Clean Energy Standard (CES) focuses on renewable energy and greenhouse gas reductions, and recommends three tiers: Tier 1 for new renewable energy; Tier 2 for existing renewable energy; and Tier 3 for nuclear energy.
The Sierra Club, as part of the Clean Energy Organizations Collaborative (CEOC), filed written comments on the CES with the Public Service Commission (PSC) on April 22, 2016.* These submitted comments were circulated to Chapter Energy Committee members for review before their submission to the PSC.
The Sierra Club filed a separate letter with the PSC on May 13, 2016, opposing the inclusion of Canadian hydropower as part of the CES.
Public hearings on the Clean Energy Standard were held in Binghamton, Buffalo, Rochester, Albany, Plattsburgh, Oswego, Syracuse, Kingston and NYC between May 10 and May 31. The Sierra Club was involved in a press conference in Buffalo on May 11, and a press conference and rally attended by some 200 people in NYC on May 31. The Chapter circulated the hearing schedule, “Suggested Talking Points” and tips on presentation of testimony by listserv and by postings on the Atlantic Chapter website. Several email alerts were sent announcing the hearings and circulating a petition in support of our stance on the Clean Energy Standard. Hard copies of the petition were collected at tabling events by Sierra Club members.
These are some of the major comments presented to the Public Service Commission by the Sierra Club:
- We support establishing enforceable interim goals for installing renewable energy facilities to ensure that the 2030 goal of 50% renewable electricity is met. If utilities do not meet renewable energy distribution targets, payments would be made to the state for further renewable energy development.
- Twenty-year Power Purchase Agreements will ensure stability to developers, installers and financiers of renewables, and demonstrate the state’s commitment to its renewable energy goals.
- We request that the state establish an offshore wind component to supply the populated areas of New York City and Long Island with renewable electricity.
- Additionally, the state power agencies — NY Power Authority (NYPA) and Long Island Power Authority (LIPA) — should be included in the CES plan, as 20% of New York’s electricity is now supplied from these agencies.
- We also request that the state establish an enforceable mechanism to reach the energy efficiency goals stated in the New York Energy Plan.
- We request that funds earmarked for renewable energy development not be used to subsidize nuclear facilities in New York State.
- The rapid deployment of renewable energy is essential to show the firm determination of New York State to become a renewable energy state, to replace unhealthy and environmentally dangerous fossil and nuclear fuels, and to reduce the human-made greenhouse gas emissions that exacerbate climate change.
Nuclear Tier Subsidies
In his call for the Public Service Commission to develop the Clean Energy Standard, Governor Cuomo initially asked for a determination by June 2016. On July 8, 2016, the Nuclear Tier raised its ugly head. On that date, the PSC added a supplemental proposal to the CES concerning subsidies for Zero Emission Credits (ZECs), with a short public comment period. This PSC recommendation actually outlined massive ratepayer-funded subsidies to the nuclear power industry — estimated by some to total approximately $8 billion through 2029. The PSC stated that the subsidies would be needed to maintain lower greenhouse gas (GHG) emissions during the ramp-up period for renewable installations and insure job continuation in the nuclear industry. The PSC proposes subsidies to all nuclear facilities in New York, except Indian Point on the Hudson River. The potential sole beneficiary of the subsidies would be the Exelon Corporation, the owner of three upstate nuclear reactors and prospective owner of a fourth.
The Chapter has answered the PSC nuclear-subsidy recommendation with a two-pronged reply: (1) the PSC should approve the renewable energy Tiers 1 and 2 of the Clean Energy Standard as soon as possible, and (2) the Sierra Club opposes the enormous proposed nuclear subsidies. Our submission opposing subsidies can be found filed July 22, 2016 on the PSC site under the CES docket number 15-E-0302.
* (Case 15-E-0302 – In the Matter of the Implementation of a Large-Scale Renewable Program http://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=15-e-0302)