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Carbon Free New York Open Letter to Governor Cuomo

Office of the Governor
633 3rd Ave 38th floor, 
New York, NY 10017

Dear Governor Andrew M. Cuomo:

The passage of the Climate Leadership and Community Protection Act (CLCPA) was a transformative moment in the global efforts to combat the climate change crisis. Considering that New York State’s economy accounts for one out of every 230 tons of energy-related carbon dioxide (CO2) emitted anywhere in the world, the CLCPA’s mandate to achieve carbon-free electricity by 2040, 70 percent renewable generation by 2030 and a net-zero carbon economy by 2050 stands as arguably the most significant and ambitious clean energy policy anywhere in the world and would realize public health benefits for all New Yorkers, but especially the most vulnerable. 

Governor Cuomo, the State Legislature and all of the activists that fought to reach what many have long advocated for deserve credit for their leadership and action. But as with any legislative achievement, we know that the real work begins now.

As members of the new Carbon Free NY coalition, comprised of environmental, renewable and clean energy, and labor groups, we have joined together in support of what we believe is a critical tool that can help achieve the goals of the CLCPA––the approval and implementation of the carbon pricing plan proposed by the New York Independent System Operator (NYISO) that would help decarbonize the electric grid in support of our economy-wide goals.

Together with other policies, a carbon price in the NYISO’s electricity market can help to speed up the state’s clean energy transition through early action. Older, inefficient and higher-emitting plants, many of which are located near the lower-income minority communities that are now most impacted by fossil fuel emissions, must either be re-powered or replaced as quickly as possible.

Especially in light of the failure of the federal government to address the climate change crisis, and the near-term risks associated with FERC’s recent actions to undermine New York’s renewable and carbon-free resources, it is more important than ever to fortify our state’s decarbonization efforts with sensible and quickly achievable actions in the electric sector, which underpins many other decarbonization efforts. A carbon price in NYISO’s electricity market would provide a sound economic basis to safeguard against FERC action to mitigate New York’s clean energy resources and the significant consumer cost impacts of such policies.

The carbon pricing plan proposed by NYISO, which administers the state’s wholesale electricity markets, will charge those who produce “dirty” carbon-intensive electricity and reward those who produce “clean” carbon-free electricity. Such a policy will immediately help meet the CLCPA’s goals and set New York on a path to a 100 percent emissions-free electric system. We believe NYISO’s carbon pricing plan is a home-grown policy tool that empowers the state to eliminate greenhouse gas (GHG) emissions from the electric sector in the most efficient and affordable manner, while improving public health and providing more opportunities to invest in workers and communities. NYISO’s carbon proposal will create an efficient incentive furthering the state’s achievement of its clean electricity goals using a market-based, technology-neutral approach.

By leveraging competitive markets to accelerate decarbonization of New York’s generation fleet, jump-starting new renewable projects––particularly in vulnerable downstate communities––and creating incentives for cost-effective and more efficient alternatives to fossil fuels in the transition, the NYISO carbon pricing plan would significantly reduce the cost and time to achieve the state’s goal of 100 percent carbon-free electricity.

In fact, Resources for the Future (RFF), a renowned independent nonprofit organization that conducts research of environmental, energy, and natural resource economics, found that carbon pricing in the electric sector would reduce sector emissions by up to 22 percent and would result in economic and climate benefits of up to $691 million annually by 2025. Furthermore, the NYISO carbon pricing plan would serve as a firewall to protect New York’s decarbonization efforts from the near-term risks of federal interference.

Our coalition fully recognizes that there are many tools the state can use to eliminate greenhouse gas emissions. But we strongly believe the implementation of the NYISO proposal should be pursued in conjunction with additional clean energy policies and environmental justice goals. By aligning New York’s wholesale electricity markets with its public policy objectives, carbon pricing is an effective means to support New York’s clean energy transition and reach the CLCPA’s decarbonization and zero-emission mandates.  

However, we know that our endorsement is not enough. We respectfully urge the Governor and the Public Service Commission to endorse the NYISO’s carbon pricing plan and direct NYISO to begin the stakeholder and FERC approval process. The immediate and wide-ranging benefits that a carbon pricing plan will yield for our clean energy and zero-emissions efforts deserve your attention and cannot be achieved without your action.

CC: John B. Rhodes, Chairman, Public Service Commission 

Alicia Barton, President and CEO, NYSERDA

Bassil Seggos, Commissioner, Department of Environmental Conservation

Gil Quiniones, CEO, NYPA

Richard Dewey, President and CEO, NYISO

Respectfully,

Alliance for Clean Energy New York
APEX Clean Energy
American Wind Energy Association
CS Energy
EDP Renewables
East Light Partners
Exelon
Innogy
Invenergy
Key Capture Energy
UBC Millwrights
EDF Renewables
Northland Power
New York League of Conservation Voters
ReEnergy
Solar Energy Industries Association
sPower
Upstate Energy Jobs
Citizens Climate Lobby of New York
National Hydropower Association
NYS Conference of Operating Engineers