Dear Governor Hochul:
On behalf of the Utility Labor Council (ULC) and the Utility Consultation Group (UCG), a consortium of New York’s energy utilities focused on providing expertise and perspective to the Climate Action Council (CAC) and its advisory panels, we would like to express our support for the State’s ambitious climate goals as set forth by the Climate Leadership and Community Protection Act (CLCPA). As an industry, we stand ready to help lead this transition which will impact virtually every aspect of New Yorkers’ lives. We share your commitment to a decarbonized future that also prioritizes affordability, reliability, resiliency, and job creation while maintaining and improving safety for all. The State’s energy utilities and its skilled workforce, working with our regulators and other State agencies, have already made meaningful progress in reducing carbon. Our members have expanded the scope and scale of utility energy efficiency programs, are working actively to make our system ready for electrified transportation, are advancing heat pump and geothermal heating technologies, and offer customers demand reduction programs that reduce peak energy use, when carbon intensity of energy is at its highest.
We recognize that electrification will be a significant contributor to decarbonizing the State’s energy use. Because electricity will play a much bigger role in an electrified economy, meaningful expansion of the transmission and distribution system should be a top priority. For these reasons, we must construct the grid of the future while carefully maintaining grid reliability and resiliency. Recent events in other states where customers lost access to energy in part due to extreme weather events show that our public safety and state economy depend on it. New York State is not immune to similar events and must incorporate these risks into our planning processes. Providing New York’s customers with energy systems that are reliable and resilient, by building sufficient new electric infrastructure and maintaining existing storm-resistant electric and gas infrastructure, will support existing and new utility jobs, provide businesses the confidence to stay in New York, and may help attract new industries. For this transition to be successful, it also must be orderly and mindful of the health of the State economy. The CAC’s Scoping Plan should consider the impact on current, living wage jobs while creating new green jobs – it should represent a ‘net-plus’ outcome for the State economy. A successful transition that considers market readiness, customer adoption, cost effective solutions, energy delivery reliability, and technology development will accelerate the achievement of our State goals.
As an industry, we know that we need to reduce the use of traditional fossil fuels and believe that an approach that continues to evaluate and develop promising technical solutions to challenges associated with decarbonization – including long-duration storage, hydrogen, and renewable natural gas (RNG) – will facilitate achievement of the State’s goals, particularly in the generation, transportation, and heating sectors. Limiting the technical options at this early stage could result in stunting economic growth and the ability to explore the most cost-effective solutions.
The Pathways to Carbon-Neutral NYC study, conducted by the New York City Mayor’s Office of Sustainability in conjunction with Con Edison and National Grid, showed that in 2050, about 90 percent of buildings will require meaningful energy efficiency investments, and electrification of heat falls in the range of 30 to 60 percent. This range is based on factors including cost, technical feasibility, and building typology. This means that 40 to 70 percent of the buildings in New York City would not be electrified in 2050, underscoring the fact that this transition is not binary – we will need all options and technologies to get to net-zero.
A large percentage of new resources will require 24/7 zero-carbon resources as backup support when those intermittent resources are not available – a fact supported by the recent CAC Reliability Forum. Assorted studies such as the NYISO Brattle Study, NYISO Analysis Group Study, and the initial CAC Integration Analysis results also support this fact. The zero-carbon resource technology to be used is still to be determined, underscoring the need to continue evaluating and developing new technologies. Additionally, the CAC’s forthcoming Scoping Plan will take time to implement over the next three decades. Allowing for the development of research and emerging technologies over that period is good public policy, ensuring long term economic stability.
During the decarbonization transition, the State should leverage existing assets and invest in new technologies to help cost-effectively reach its goals. To that end, exploring ways the existing gas distribution system can contribute to State decarbonization efforts is prudent. Existing infrastructure can be modified and modernized to carry newer zero-carbon fuels – like renewable hydrogen and RNG from sustainable biomass feedstocks – allowing it to contribute to mitigating climate change while continuing to provide reliable, affordable energy to those who need it today.
Similarly, dormant power plants, industrial sites, and environmental remediation sites are ripe for development of clean energy projects – and job creation – including within disadvantaged communities. Developing these sites is smart growth that focuses investment dollars where they are needed most.
We stand ready to help move the State toward its decarbonized future. Please do not hesitate to reach out if our organizations can provide information or be of service going forward.