Memorandum in Support - S.2474-B (Parker) / A.4999-B (Cunningham)
S.2474-B (Parker) / A.4999-B (Cunningham) – An ACT to amend the public authorities law, in relation to directing the New York state energy research and development authority to conduct a study of the technical and economic feasibility and ratepayer impact of a zero-emission electrical system and a reduction in greenhouse gas emissions
The Independent Power Producers of New York, Inc. (IPPNY) is New York’s premier trade association dedicated to representing the largest fleet of clean energy generators in New York State and companies involved in: the competitive power supply industry; the development of electric generating facilities; the generation, sale, and marketing of electric power; and natural gas transmission facilities. IPPNY Member companies produce the majority of New York’s electricity, utilizing all sources such as wind, solar, hydro, energy storage, natural gas, low sulfur oil, waste-to-energy, biomass, and nuclear.
IPPNY supports S.2474-B (Parker) / A.4999-B (Cunningham). This bill is in alignment with the State’s growing commitment to maintaining the affordability of the State’s programs for energy consumers. This legislation would help the State’s residents and businesses understand the ratepayer impacts from the costs of meeting the Climate Leadership and Community Protection Act’s (CLCPA) targets and how to pay for them.
Under this legislation, the New York State Energy Research and Development Authority (NYSERDA), in consultation and coordination with the Department of Public Service, the Department of Environmental Conservation, and the New York Independent System Operator, would publish and update a comprehensive study to determine the ratepayer impact and economic and technical feasibility of meeting the CLCPA’s goals: having the statewide electrical demand system be zero-emissions by 2040; and reducing statewide greenhouse gas emissions by 85 percent from 1990 levels by 2050. The study would assess: the timing and costs of meeting these targets, especially an evaluation of the economic impact on the State’s ratepayers, businesses, and jobs; feasibility associated with pathways to meet these goals; and the existence of technology to maintain electric system reliability, such as long-term energy storage systems and other dispatchable emissions free resources.
For the past three years, over 60 organizations, in collaboration with IPPNY, have asked for an independent, transparent, and comprehensive ratepayer cost impact analysis of meeting the CLCPA’s targets and were told that one would happen when specific programs were implemented. Now, the State is in the process of developing the New York Cap-and-Invest (NYCI) program, and this bill would be a pathway to accomplish that review. Knowing how the CLCPA’s goals could be achieved, and at what cost, would result in the best implementation of requirements to address climate change. Although NYSERDA’s Integration Analysis, as part of the CLCPA’s Climate Action Council process, looked at the “total potential costs and potential economic and non-economic benefits of the [Climate Action] Plan,” as required by the CLCPA, this macroeconomic examination of societal costs and benefits is not enough for energy consumers to fully understand the impact the Plan, and its implementing programs such as NYCI, will have on their energy bills and the economy.
The evaluation under this legislation should include specific cost study scenarios that show residential, commercial, industrial, and institutional energy consumers, along with local governments and not-for-profits, the increased costs they would be facing. The analysis should specify consumers’ costs of installing or accessing renewable energy and energy storage, replacing their heating systems, upgrading their electric service, buying electric cars, and figuring out ways to charge them. Importantly, it should detail how consumers will pay for these measures. All sources of State and Federal funds should be identified and exhausted before costs are passed down to consumers.
Growing awareness of the need to quantify and address the cost of meeting the CLCPA’s targets was spotlighted by the New York State Public Service Commission’s (PSC) October 2023 Session, during which the PSC observed that the Legislature enacted the CLCPA but did not specify how to pay for it. The PSC noted that the obligation to meet the CLCPA’s targets does not supersede the PSC’s mandate to ensure just and reasonable rates and to maintain reliability, while meeting the CLCPA’s goals. This legislation would continue to refine the best pathways to meet the CLCPA’s targets.
For the reasons stated above, IPPNY supports S.2474-B (Parker) / A.4999-B (Cunningham).
