The letter below is not my letter. It was written by NY Renews on the draft scoping plan for New York’s climate plan and is just excellent. It is long but worth the time and effort, especially if you have not heard much about CLCPA, the Climate Leadership Community Protection Act yet.

This is an opportunity to learn about this critical piece of legislation that was passed last year, not as a bill but as a scoping plan.

NY Renews has broken the plan down into sectors which are posted on their site. They have been posting one a week with a letter. This is from the sector on power generation and electricity. The hearing for this piece is over but evidently they are still accepting sign ups because I just used the link.

This is important because it will set the path for New York’s clean energy future. Fossil fuel and pro nuclear interests have been very active in speaking up.

Our voice, starting with you, has got to be louder. Sign up now!

Marilyn Elie

Help shape NY’s climate future by submitting a public comment on the “Power Generation and Electricity” section of our state’s current climate plan! Use this one-click tool to submit a letter today! https://nwmd.io/s/email/ZhE9ATnEHPLrQmyjLb8=/r

Thank you for this opportunity to provide comments on the draft scoping plan. As required by New York’s nation-leading climate law, the CLCPA, climate and environmental justice must be the driver of the outcomes of this scoping plan. To achieve this, please ensure that the following recommendations on the Power Generation/Electricity Sector are included in the final draft:

The power generation and electricity sector lays out a strong set of recommendations, but it needs a bolder hand and stronger commitments. By 2050, our electricity needs in New York will double, as we will be heating our homes and powering our vehicles with electric power. New York must make plans to phase out existing fossil fuel plants, many of which are reaching the end of their lifespan.

Acknowledging the concerns of the Climate Justice Working Group, it is evident that New York will need a big increase in renewable energy, battery storage, and energy efficiency. There needs to be a clear moratorium on fossil fuel power plants and focused deployment of proven renewable energy technologies and expanded battery storage. We are in a critical decade for building out a huge fleet of renewable generation; we cannot rely on false solutions and hypothetical technologies like hydrogen, “renewable” natural gas (RNG), and carbon capture and storage (CCS). Current fossil fuel plants need to be retired and replaced to eliminate pollution impacts on communities, and the state must provide funding and support for both workers affected by this transition, and the communities around these plants as we reach our goal of zero emissions by 2040.New York should set a year-by-year target for permitting new wind, solar, and battery storage. State agencies should fully leverage tools like community workforce agreements, community benefit agreements, first-source hiring, and project labor agreements to increase access to construction jobs and permanent jobs for disadvantaged communities (DACs); work with the capacity of people and develop agreements in partnership with frontline communities, industry, and organized labor; and further emphasize green worker-owned cooperatives. It is crucial that this point is stressed to continually call attention to the state to address barriers to renewable energy siting. All work to this end requires full staffing of relevant state agencies, including the Office of Renewable Energy Siting, engagement with Indigenous Nations in NY, and a comprehensive public education and information push on the benefits and opportunities of clean energy

In conclusion, there isn’t enough emphasis on energy democracy. Low-and-moderate income (LMI) program size needs to be commensurate with need and incentive and rate structures for distributed energy resource (DER) resources should reflect the benefits they can provide when paired with equity goals.


The power generation/electricity chapter rightly recognizes that:

Hydrogen combustion emits nitrogen oxides (NOx), a precursor to ozone, particulate matter, and nitrogen dioxide (NO2) at levels that may be higher than those from natural gas combustion because of hydrogen’s high combustion temperature. RNG combustion also results in pollutant emissions similar to fossil gas combustion. The scoping plan must hold firm to the commitment for zero emissions in the electric sector by 2040, and account for the cumulative impact of pollutants on disadvantaged communities (DACs).

The health risks associated with combustion emissions and combustion waste products are not associated with renewable power generation and will substantially decrease with large-scale reduction in combustion for power generation. To prioritize public health, the state must prioritize renewable energy.


Marilyn Elie