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Shaping Energy Policies
Shaping Energy Policies through Advocacy in Regulatory Proceedings
The Pace Energy and Climate Center is actively working to shape energy policy through advocacy in regulatory proceedings. The Center is involved in several ongoing policy and regulatory proceedings before various New York State agencies, primarily the New York State Public Service Commission (PSC). Influencing decision-making with current scientific studies and research will lead to a more efficient and robust energy policy.
Con Edison Network Outage Study
In July 2006, Con Edison experienced an electrical failure of its Long Island City network. Pace Energy and Climate Center and several partners were selected by the NYS PSC to study the economic and health impacts that were a result of the outage. Click on the following links below to see the full report and appendices to the report.
New York State Energy Plan
In September 2009, the State Energy Planning Board was established and charged with completing a State Energy Plan on or before March 15, 2013. The New York State Energy Plan will contain analyses and policy recommendations that will guide the State’s energy future, including how energy needs will be met, how related environmental goals will be achieved, and how renewable and clean alternative energy generation will be developed.
Pace Energy and Climate Center has commented on the 2013 Energy Plan “draft scope,” and will continue to offer input as the Energy Plan process goes forward. The Center’s recommendations address the following topics:
- Advanced carbon accounting
- Encouraging the federal government to adopt a responsible carbon policy
- New comprehensive cost-benefit measures for measuring the performance of energy efficiency and renewable energy programs
- The use of current low natural gas prices in projections and analyses
- The inclusion of health cost and heath benefit monetary estimates
- The costs and benefits of closing coal plants
- Estimates of long-term technology development rates for energy efficiency and renewable energy
- The performance of competitive wholesale electric markets
- Large new Eastern Interconnect transmission alternatives
- Analyses of hydraulic fracturing for natural gas
- Emerging state and federal environmental regulations, and their implications for New York’s energy infrastructure
- The future of Indian Point Nuclear Plant
To view the Center’s comments, click here.
For more information, please contact Franz Litz at flitz@law.pace.edu.
PSC Implementation of Renewable Portfolio Standard
On October 1, 2008, the PSC issued two notices in Case 03-E-1088 concerning proposed revisions the state's Renewable Portfolio Standard ("RPS"). One proposal (SAPA No. 03-E 0188SA18) concerns proposed revisions that would increase the target level of photovoltaics and of other on-peak resources in high-cost areas. The other proposal (SAPA No. 03-E 018SA19) addresses potential revisions to among other things the tier allocations and annual targets, and included a proposal to increase the existing RPS procurement requirement from 25 percent by 2013 to 30 percent by 2015. The Pace Energy and Climate Center submitted comments to the PSC in this proceeding on November 17, 2008. See the "Publications" link to view these comments. For more information, please contact Franz Litz at flitz@law.pace.edu.
PSC Implementation of a "15x15" Initiative
As described above, the Pace Energy and Climate Center helped conceive the initiative of the New York Governor to reduce energy consumption by 15 percent by 2015. In the New York PSC’s Energy Efficiency Portfolio Standard (EEPS) proceeding implementing the 15 X 15 initiative, the Commission issued an order in June 2008 which moved forward aggressively to implement energy efficiency programs throughout New York. The PSC established efficiency targets to be achieved through 2011 by the utilities under its jurisdiction, and required utilities to start collecting $172 million annually beginning in October to invest in energy efficiency programs – an unprecedented level of funding for energy efficiency in New York State. The Center will continue to participate in the EEPS proceeding, as utilities and NYSERDA submit proposals to implement the Commission’s order.
Long-Run Electric Resource Planning
In addition to the EEPS proceeding convened by the PSC, the PSC is also conducting a proceeding to consider longer range electric resource planning. The Pace Energy and Climate Center is participating in the proceeding and helping to shape the state’s long-term energy planning process.
Electric Utility Rate Proceedings
The Pace Energy and Climate Center intervened in the currently pending Con Edison electric rate case before the PSC (Case 08-E-0539) and offered testimony in September 2008 by Deputy Director Tom Bourgeois, proposing an incentive mechanism to promote the development of Combined Heat and Power (CHP) resources in Con Edison's service territory. See the "Publications" link to view this testimony. Copies of the Initial and Reply Briefs filed by the Center are also available at the "Publications" link. The Center's Reply Brief also discusses the submetering proposal by the Department of Public Service (DPS) Staff in the case.
Gas Utility Rate Proceedings
The Pace Energy and Climate Center intervened in the last two Con Edison gas rate cases and recent merger proceedings as part of an effort to obtain either a natural gas system benefit charge or individually utility funded gas energy efficiency programs. Both cases were settled with the companies having committed to significant new programs; the Center is engaged in collaborative efforts with both utilities regarding program design.
Revenue Decoupling
The Pace Energy and Climate Center actively participated in the generic case that resulted in a PSC order that all electric and gas utilities implement a revenue decoupling mechanism (RDM) in their current or next rate cases. The Center simultaneously urged development of RDM in the Con Edison gas rate case, Con Edison electric rate case and the National Grid/KeySpan rate case. We are now participating in separate Con Edison gas and National Grid/KeySpan collaboratives to develop their respective RDM clauses.
Distributed Generation Emissions Rules
The Department of Environmental Conservation is promulgating new emissions standards for distributed generators, and the Pace Energy and Climate Center is participating in this rulemaking process.
Power Plant Siting Reform
The Pace Energy and Climate Center provides legal research, policy analysis and legal representation to civic organizations to improve the way in which environmental and other social burdens are addressed in the siting of major energy infrastructure projects.