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Carbon Free New York Sends Open Letter to Governor Cuomo on 206 Complaint

November 18, 2020

Carbon Free New York Send Open Letter to Governor Cuomo on 206 Complaint

What Happened: On October 14, Cricket Valley Energy Center and Empire Generating Company filed a complaint with the Federal Energy Regulatory Commission (FERC) requesting that FERC issue a “clean” Minimum Offer Price Rule (MOPR) with “no exceptions or exemptions”.

What That Means: They want all carbon-free energy resources––including wind, hydro, nuclear, and solar power as well as energy storage and demand response––to unfairly compete with emitting fossil-fueled plants in energy markets that currently allow to them to pollute for free.

Explain the Impact: If FERC expands the MOPR into NYISO, it will jeopardize the ability to achieve the state’s nation-leading Clean Energy Standard and Climate Leadership and Community Protection Act (CLCPA) and:

Significantly increase consumers’ costs and time to achieve the state’s goal of 100 percent carbon-free electricity;
Worsen public health, especially downstate, where the most dangerous carbon-emitting generators operate;
Chill cost-effective transmission investments aimed to provide downstate New Yorkers access to carbon-free electricity produced upstate;
Risk new and existing, highly-skilled clean energy jobs – killing New York’s green economy at a time when New York needs to Build Back Better.

Carbon Free New York has released an open letter to Governor Cuomo in response to the 206 Complaint: Full open letter below. Pull quotes immediately below.

As members of the Carbon Free New York 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 swift implementation of New York Independent System Operator (NYISO)’s carbon pricing plan that would help quickly and cost-effectively decarbonize the electric grid in support of our economy-wide goals.

FERC has indicated publicly a willingness to approve plans that incorporate state-determined carbon pricing proposals within wholesale electricity markets – all FERC needs is for New York to lead, again. NYISO’s proposal complements the state’s existing clean energy programs and greatly lessens the immediate tensions created by the recent complaint and guarantees progress towards the legally mandated CLCPA targets.

Office of the Governor
633 3rd Avenue 38th Floor
New York, NY 10017

Dear Governor Andrew M. Cuomo:

On October 14, Cricket Valley Energy Center and Empire Generating Company filed a complaint with the Federal Energy Regulatory Commission (FERC) seeking to expand market mitigation rules to carbon-free energy sources participating in the New York Independent System Operator (NYISO)’s capacity markets, similar to the controversial measures FERC is finalizing in the mid-Atlantic power grid, PJM.

Specifically, the fossil-fueled plants request that FERC issue a “clean” Minimum Offer Price Rule (MOPR) with “no exceptions or exemptions” – meaning they want all carbon-free energy sources, including wind, hydro, nuclear, and solar power as well as energy storage and demand response to unfairly compete with fossil-fueled plants that are currently enabled to pollute freely.

Restrictions of this nature are already at play in New York City and the mid-Hudson valley, putting New York’s carbon-free energy resources at risk and threatening progress towards achieving a 100 percent carbon-free electric grid by 2040. If FERC expands the NYISO’s mitigation measures, it will jeopardize the success of the state’s nation-leading Clean Energy Standard and Climate Leadership and Community Protection Act (CLCPA) and:

Significantly increase consumers’ costs and time to achieve the state’s goal of 100 percent carbon-free electricity;
Worsen public health, especially downstate, where the most dangerous carbon-emitting generators operate;
Chill cost-effective transmission investments aimed to provide downstate New Yorkers access to carbon-free electricity produced upstate;
Risk new and existing, highly-skilled clean energy jobs – killing New York’s green economy at a time when New York needs to Build Back Better.

Expanded mitigation could lead to the loss of carbon-free resources, resulting in higher emissions, significantly greater costs to consumers, lost jobs and a huge setback to New York’s green economy. Taken individually, these are devastating consequences; in aggregate, they mean a reduced likelihood of reaching our decarbonization goals and reversing the dangerous trajectory of climate change facing New Yorkers and the planet.

As members of the Carbon Free New York 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 swift implementation of NYISO’s carbon pricing plan that would help quickly and cost-effectively decarbonize the electric grid in support of our economy-wide goals.

Together with other policies, a carbon price in New York’s wholesale electricity market can help to speed up the state’s clean energy transition. 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.

Resources for the Future (RFF), a renowned independent nonprofit organization that conducts research into environmental, energy, and natural resource economics, found that NYISO’s carbon proposal could reduce sector emissions by up to 22 percent, resulting in economic and climate benefits of up to $691 million annually by 2025.

As a single state electricity market, New York is in a unique position to set an example for the nation by embracing NYISO’s carbon pricing proposal establishing a market-friendly approach and harmonizing state and federal public policy objectives. FERC has indicated publicly a willingness to approve plans that incorporate state-determined carbon pricing proposals within wholesale electricity markets – all FERC needs is for New York to lead, again. NYISO’s proposal complements the state’s existing clean energy programs and greatly lessens the immediate tensions created by the recent complaint and guarantees progress towards the legally mandated CLCPA targets.

Furthermore, implementing NYISO’s carbon adder immediately would minimize the impact of FERC’s mitigation efforts, while advancing our nation-leading clean energy goals through near-term cost-effective emissions reductions. This major step would again demonstrate the leadership of New York and serve as a national model for neighboring market adoption, consistent with the state’s legacy of leadership.

Our coalition fully recognizes there are many tools the state can use to eliminate greenhouse gas emissions. We strongly believe the implementation of NYISO’s carbon proposal should be pursued in concert with New York’s Clean Energy Standard and objectives outlined in the CLCPA.

We respectfully urge the state and more specifically the Public Service Commission to endorse NYISO’s carbon pricing plan and direct NYISO to seek FERC approval before this complaint potentially moves forward by the end of this year. Given the abbreviated timeline established by the complaint, now is the time for New York to lock in the immediate and wide-ranging benefits that NYISO’s carbon pricing plan will yield for our clean energy efforts, which cannot be achieved without your action.

Respectfully,

Alliance for Clean Energy New York
APEX Clean Energy
American Wind Energy Association
Citizens Climate Lobby of New York
ConnectGEN
CS Energy
Cypress Creek Renewables
EDF Renewables
EDP Renewables
East Light Partners
EggGeo
Exelon
Healthy Planet
Invenergy
Key Capture Energy
NYS Building Trades Council
UBC Millwrights
United Brotherhood of Carpenters
National Hydropower Association
Northland Power
New York League of Conservation Voters
NYS Conference of Operating Engineers
NYS Laborers, LiUNA
ReEnergy
RWE Renewables
Solar Energy Industries Association
sPower
Upstate Energy Jobs

CC: John B. Rhodes, Chairman, Public Service Commission
Doreen Harris, Acting President and CEO, NYSERDA
Bassil Seggos, Commissioner, Department of Environmental Conservation
Gil Quiniones, CEO, NYPA
Richard Dewey, President and CEO, NYISO