In The News

Letter to NY Forward Advisory Board and Governor Cuomo on Carbon Pricing For COVID-19 Economic Recovery Efforts

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


Dear New York Forward Advisory Board Co-Chairs Steve Cohen and Bill Mulrow:

Thank you for your service to the state of New York during this unprecedented public health crisis. As leaders in your respective industries and representing regions across the state, your unique expertise provides diverse representation to help guide the state’s re-opening strategy.

While we realize that many factors will be part of your deliberations for re-opening and economic recovery plans, as leading environmental, renewable, clean energy, and labor groups, we would like to raise a key issue for your consideration: the clear link between the COVID pandemic and the climate change crisis.

Our most vulnerable populations, such as seniors and low-income communities of color, are already disproportionately affected by climate-influenced health issues and face the most exposure to dirty air due to their proximity to fossil fuel power plants. Now, these underlying respiratory issues have allowed COVID to impact these very people with pre-existing health conditions the hardest, showing just how important reducing pollution and improving air quality are to protecting public health, especially in times of crisis. In addition to protecting public health and addressing the disastrous and irrevocable effects of climate change, we also need solutions to reboot New York’s economy in the aftermath of COVID with more than 1.9 million New Yorkers having to file for unemployment insurance claims, according to the state Labor Department.

Fortunately solutions for improving air quality and creating jobs can be found within New York’s already existing clean energy goals. Meeting the ambitious and transformational goals established by the Climate Leadership and Community Protection Act (CLCPA) will not just help us address the impending climate change crisis, but also can be a significant factor in helping the state build back stronger, safer and healthier than before. Decarbonization of New York’s electric generation fleet will help address the respiratory issues that have allowed COVID to attack our most vulnerable populations and reduce our reliance on dirty fossil fuels that also drives the climate change catastrophe. Fortunately, clean energy development can be efficiently and effectively operationalized through the implementation of the carbon pricing plan proposed by the New York Independent System Operator (NYISO).

When Carbon Free New York (CFNY) first formed earlier this year, its mission to advocate for New York’s adoption of NYISO’s carbon pricing plan was grounded in the belief that incorporating the social cost of carbon within the state’s electricity markets would be one of the most effective tool to meet the CLCPA clean energy goals and help New York better prepare itself to address the climate change crisis.

The attendant goals of the CLCPA are more important than ever as we begin the process of preparing for a post-COVID-19 economic recovery. NYISO’s carbon pricing plan advances these objectives by providing New York with an essential tool to restart the economy and build it back cleaner and stronger than ever. Pricing the social cost of carbon within New York’s electricity markets will align our environmental and public health interests––while simultaneously jump-starting the economy at a very timely moment.

In tandem with New York’s broad CLCPA implementation, NYISO’s carbon pricing proposal will support investments in green jobs and accelerate the build-out of renewable energy infrastructure, putting thousands back to work while safeguarding the health of our environment. At a time when the state has limited resources, carbon pricing offers a consistent mechanism to incentivize carbon-free energy production and clean energy job creation and business growth. Leveraging the power of markets, NYISO’s carbon pricing proposal ensures the most efficient utilization of public resources to achieve the CLCPA goals.

New York accounts for one out of every 230 tons of energy-related carbon dioxide (CO2) emitted anywhere in the world. With 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, incorporating the social cost of carbon into New York’s energy markets is the most efficient and affordable approach to reaching these goals, while protecting public health and rebuilding the state’s green economy. This is a moment for bold leadership.

New York has an opportunity to build back better and cleaner and be the nation’s clean energy leader by decarbonizing our electricity sector with a market-based model that preserves our state’s ability to choose and achieve our clean energy policy goals.

Within the electricity sector, the challenges of eliminating GHG emissions by 2040 are significant, even more so absent  a carbon price in the state’s electricity markets. Fortunately, NYISO has developed a carbon pricing proposal that will charge those who produce carbon-intensive electricity and reward those who produce carbon-free electricity. The state can immediately use this carbon pricing plan to help achieve the lofty goals of the CLCPA and set New York on a path to a 100 percent emissions-free electric system. NYISO’s carbon proposal is a workhorse that efficiently aligns our climate energy goals with a market-based, technology-neutral model for decarbonization.

The NYISO carbon plan would give New York a tool to kickstart its health and economic recovery efforts, while simultaneously enhancing our ability to meet long-term climate goals identified in the CLCPA. By leveraging competitive markets that include the social cost of carbon, we can accelerate decarbonization efforts, improve public health, and create highly skilled jobs that can be part of the backbone of rebuilding New York’s economy.

As an innovative tool to support investments in renewable energy projects, particularly in areas currently served by fossil fuel, NYISO’s proposal reduces the cost and time to achieve the state’s clean energy goals, revitalize our workforce with the next generation of green economy job opportunities, while benefiting consumers.

In short, the NYISO carbon proposal will help deliver New York’s clean energy transformation while also providing the state with an environmentally friendly tool to Build Back Better post COVID.

By incorporating the social cost of carbon within NYISO’s markets, New York will align its wholesale electricity markets with its public policy objectives to decarbonize the electricity sector and help fortify our defense against the current public health and climate crisis––for which there can be no vaccine.


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


CC: Governor Andrew M. Cuomo

       New York Forward Advisory Board Members

       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