Comment on the Draft New York State Energy Plan

Thank you for this opportunity to offer comments about the draft State Energy Plan.

New York is at a crucial moment with respect to energy policy. The state today is near the midpoint between 2019, when the Legislature enacted the Climate Leadership and Community Protection Act (CLCPA), and 2030, when New York is supposed to get 70 percent of its electricity from renewable energy sources (up from less than 35 percent last year) and to have cut emissions by 40 percent from 1990 levels.

The CLCPA is failing on its own terms. The Board has indicated, in its Draft, that New York will not meet its 2030 goals (which were supposed to take 11 years) before 2036—that is, in another 11 years:

Under the current set of assumptions and the Climate Act GHG accounting methodology, Current Policies will hit 40 percent economywide emissions reduction in 2038, while Additional Action will hit 40 percent reduction in 2036. (Summary for Policymakers, p.24)

The 2030 targets have gone from being aspirational goals meant to spur transformational changes to a paralytic preventing private actors from reducing emissions.

Ken Girardin is a fellow at the Manhattan Institute.

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