Utility Consultation Group Comments on CLCPA

The Utility Consultation Group is represented by New York’s gas and electric utilities, and is focused on providing expertise and perspective to the Climate Action Council and its advisory panels. Their resources can be found at https://jointutilitiesofny.org/ucg_clcpa

View the full Utility Consultation Group comments on the state’s draft scoping plan here, or link to their comments by sector, below:

• Executive summary of utility feedback to Advisory Panels, summarizing key aspects of the draft scoping plan including power generation, transportation, efficiency & housing, energy-intensive & trade exposed industries, agriculture & forestry and adaption & resilience. 
  
  
• Gas System Transformation. A carbon reduction pathway that leverages existing gas infrastructure investments coupled with efficient expansion of the electric distribution and transmission grid will achieve decarbonization in a more cost-effective, lower risk way as called for by the CLCPA, while supporting overall energy system reliability and resiliency. Efficiency will also play an important, cost-effective role.
  Gas Transition Executive Summary
  Case Study of January 2022
  
  
• Energy System Reliability and Need to Address Resource Intermittency. Reliability of both gas and electric systems will continue to be critical to the well-being of the residents of New York State as the CLCPA is implemented. The natural intermittency of renewable generation and the need for electric supply to meet customer energy demand every hour of the day can result in reliability issues if not proactively addressed.
  
  
• The Role of Utilities in CLCPA Implementation. The vast majority of the energy infrastructure in the State was built by independent utilities, and those same utilities operate and maintain that complex energy infrastructure today. Utilities' knowledge of their infrastructure makes them ideally suited to plan for and execute the clean energy transition the CLCPA requires.
  Role of the Utility
  
  
• Economy-Wide Strategies and Carbon Pricing. If a carbon price is implemented, a well-designed program should include quantitative analysis that holistically evaluates energy, economic and environmental costs and benefits of any change, and include all energy sectors in addition to power generation.
  Carbon Pricing -Economy Wide Strategies White Paper
• Managing Energy System Reliability During the Clean Energy Transformation. The transition from conventionally-fueled dispatchable resources to renewables – with unavoidable intermittency – to meet CLCPA goals must be accomplished in a way that maintains reliability. Reliability can be maintained by optimizing the decarbonization of both the electric and gas delivery systems. In the same way that the electric generation mix continues to transition to less carbon emissions, the gas delivery system can also be decarbonized with a transition to no- and low-carbon fuels that provide diversified, safe and secure sources for dispatchable generation units.
  UCG White Paper on Reliability - Executive Summary
  UCG White Paper on Reliability - Full
  
  
• January and July 2022 energy demand peaks, renewable lulls. Very low wind and solar production occurred in the winter and summer of 2022 due to wind lulls and cloud cover and causing a higher reliance on natural gas, nuclear and large hydro for power supplies.
  Case Study-Executive Summary
  Case Study - Final
  
  
• Agriculture & Forestry Advisory Panel’s Recommendations: Biobased Low-carbon Fuels Can Help Meet New York’s Ambitious Emission Reduction Goals in an Affordable, Resilient and Reliable Manner.
  UCG Comments - Agriculture Forestry AP Recommendations

• Energy Efficiency and Housing Advisory Panel’s Recommendations: The EE&H Panel Recommends The Advancement Of New Technologies Through R&D And Demonstrations To Achieve CLCPA Targets, And Should Consider Inclusion of Technologies That Can Leverage Existing, Reliable Natural Gas Infrastructure In Those Technology Development Roadmaps
  UCG Comments - EEH Panel Recommendations

• Energy-Intensive Trade Exposed Industries Advisory Panel: Decarbonization of this sector can be achieved through other pathways beyond electrification, in order to avoid economic and emissions leakage from these industrial customers. We can create an economic competitive advantage for NYS by assisting these large commercial and industrial companies in meeting their CLCPA requirements while maintaining good-paying jobs, as well as tax revenues and support to local communities
  UCG comments - EITE Advisory Panel recommendations

• Power Generation Advisory Panel’s Recommendations  A Decarbonized Energy System Still Needs To Support The Reliable And Resilient Delivery Of Energy. Cost-Effectiveness For Customers Is Critical To Retaining Support For Clean Energy, And The State Should Support Efforts To Mitigate Cost Impacts And Maximize Economic Benefits Of The Clean Energy Transition
  UCG Comments - Power Generation AP Recommendations

• Transportation Advisory Panel’s Recommendations: The UCG Supports The Panel’s Recommendations To Invest in ZEV Charging Stations And Also Emphasizes The Importance Of The Role Utilities Can Play In Supporting Charging Infrastructure Build Out
  UCG Comments - Transportation AP Recommendations 

• Land Use & Local Government Advisory Panel, Adaptation & Resilience Group’s Recommendation with Respect to Existing Natural Gas Infrastructure:    The Adaptation & Resilience Group’s Proposed Recommendation to Ensure Reliability, Resilience and Safety of a Decarbonized Energy System is Critical to Achieve Responsible Decarbonization in the State. RNG is Abundant in and Around New York, and the Potential for Hydrogen is Being Actively Explored in the US and Abroad
  UCG Comments - Land Use Local Government - Adaptation Resilience Recommendation