GELF Testimony State Energy Master Plan - Green Education and Legal Fund

Testimony of the Green Education and Legal Fund
on the New York State Draft Energy Master Plan
September 28, 2025

The Green Education and Legal Fund urge the Energy Master Plan to be much stronger in trying to prevent climate collapse, keeping global warming below 1.5 degrees Celsius. The plan needs far more detailed activities, timelines, and funding allocations,

The plan should incorporate a declaration of a climate emergency. For much of the last two years, global warming has exceeded that target. A recent study found that at current rate of global emissions, the world will exceed its remaining carbon budget within two years. In addition, six of the planet’s life boundaries have already been breached with a seventh – ocean acidification – also quickly approaching its threshold. And the planet is in the midst of the sixth great extinction of species.

Human history has witnessed the rise and fall of numerous civilizations. Many of the collapses were caused by environmental factors. Often solutions existed but the power elite refused to implement them as they would threaten their status. The climate crisis threatens the future of our present civilization, as rising tides, heat waves, droughts, and other extreme weather promotes widespread climate migration and conflicts over access to land, water, and food. Even in the US, vulnerable residents are often displaced by extreme weather events while the rebuilding promotes gentrification.

While the Governor likes to defend the state’s poor performance on climate by noting that things have changed since the climate law was adopted – itself based on a 2009 Executive Order – the biggest change is that global warming and extreme weather is happening faster than predicted.

As the Secretary-General of the United Nations has noted, we have run out of time for effective climate action and the slow response by elected officials has opened up the Gates of Hell. A new report, led by the nonprofit research group Stockholm Environment Institute, shows countries plan to produce more than twice the amount of fossil fuels in 2030 that would be consistent with limiting global heating to 1.5 degrees Celsius.

As numerous climate scientists have repeatedly pointed out, our failure to deal with climate change is not due to a lack of technological solutions but rather a lack of political will. We need political leadership comparable to what FDR provided after Pearl Harbor. That is not reflected in the energy plan.

At a minimum, the Master Plan needs to comply with the state’s climate law (CLCPA) and incorporate all of the scoping document adopted by the Climate Action Council. The Executive Summary of the Master Plan has a single sentence noting that the update is supposed to be informed by the Scoping Document that the Climate action Council took 3 years to development. It then downgrades the pivotal role of the scoping documenting by listing other “studies and reports” that should inform the energy plan.

The state energy master plan needs to a real plan to guide the state in meeting the climate goals of the CLCPA. It needs to provide a clear path with short term targets, timelines and steps to meet the CLCPA’s rather tepid goals, such as reducing greenhouse gas emissions by 40% by 2030 and 70% of the state’s electricity by renewables. It needs to incorporate all the recommendations of the scoping document adopted by the Climate Action Council pursuant to the CLCPA.

GELF urges the energy master plan to adopt stronger goals than the CLCPA. President Biden for instance had set a national goal of reducing greenhouse gas emissions by 50 to 52% by 2030; to achieve that goal nationally, New York would realistically need to reduce emissions even further. GELF supports a goal of zero greenhouse gas emissions by 2035.

In 2015, GELF drafted legislation that sought to implement the study done by Cornell and Stanford professors showing that we did not need more fossil fuels or nuclear to meet 100% of our energy needs by 2030. The state needs to conduct a detailed study on how to meet the CLCPA goals through clean, renewable energy.

One area which the state has moved far too slowly – which is now unfortunately impeded by the Trump administration – is the development of offshore wind, which should meet 40% of our electric needs according to the study.

GELF strongly opposes the master plan’s promotion of nuclear power. It is not credible to say that nuclear is zero emissions, even for just greenhouse gas emission, especially when the life cycle of the plant is analyzed as well as the mining and processing of the fuel. It is far too expensive, it will take far too long to develop to have an impact on prevent climate chaos, and it has the enormous problem of dealing with the radioactive waste.

Even more important than saying yes to renewable energy, battery storage, energy efficiency and conservation is saying no to fossil fuels. This includes natural gas. The state energy master plan should oppose new or upgraded gas pipelines, prevent the expanded use of natural gas, and phase out existing natural gas uses.

At a minimum, the final State Energy Plan must recommend a pathway that reflects more closely the ambition of the Net Zero A scenario. This scenario more accurately matches the ambition and leadership the Climate Act demands from the State. Net Zero A scenario has greater absolute and net benefits. The State’s proposed “Additional Action” scenario reflects minimal action beyond existing policies and leaves New York far off track to achieve the Climate Act’s emissions mandates.

Enact an Ecosocialist Green New Deal

The Green Party first called for a Green New Deal in the 2010 gubernatorial race of Howie Hawkins (the European Greens were the first to issues such a call, in 2008, in response to the global financial meltdown). The GND calls for an immediate halt to the development of more fossil fuels and a rapid phaseout of existing ones. A ten-year transition to 100% clean, renewable energy, with zero emissions. An Economic Bill of Rights with universal single pay health care; a guaranteed living wage and job for all; affordable housing; and free public education including college (abolition of student debt). Implement a Just Transition that empowers those communities and workers most impacted by climate change and the transition to a green economy. Ensure that any worker displaced by the shift away from fossil fuels will receive full income and benefits for five years as they transition to alternative work. Commit at 70% of climate funding to direct benefit environmental justice communities and low- and moderate-income residents. A public jobs initiative to provide full employment through a sustainable, publicly controlled economy.

Both Pope Francies and the Intergovernmental Panel on Climate Change have acknowledged that capitalism is a major cause of global warming and is incompatible to solving the climate crisis. A major problem is that capitalism requires continued growth rather than sustainability. Capitalism also believes that the most efficient way to allocate resources is by the drive to maximize profits. Capitalism also fails to requires companies to take financial responsibility for the external damages caused by their operations (e.g., pollution). Solving the climate crisis will require an economic and political systems that prioritizes the well-being of all individuals, not just the wealthy, and will require democratic control over energy.

The State Energy Master Plant Must Raise At Least $10 Billion Annually for the Climate Transition – Make Polluters Pay

The Draft State Energy Plan critically contains no mechanism for funding the clean energy transition. In drafting the scoping document, the state estimated the cost of the clean energy transition would be $2.7 trillion dollars over 30 years. Based on the state’s apparent assumption that 90% of the cost would be met by reallocating 90% of the existing energy expenditures in the state, the state estimated that it needed to raise an additional $10 billion annually in climate funding. In reality, significantly more is needed given how dire the present situation is.

The plan needs to embrace the concept of Make Polluters Pay. The recent Climate Superfund Act was a small step in the right direction but grossly undercharges polluters for the damage they have caused. Assemblymember Steck has introduced legislation to stop the rebate of the Stock Transfer Tax, which brings in as much as $15 billion a year. The legislation would devote a portion of the tax – a very small sales tax on financial transactions – to climate programs. GELF also supports raising taxes on the very wealthy – who have benefited most from and driven global warming.

Enact a Carbon Tax, Not Cap, Trade and Invest

It is essential that the state energy plan enact a robust carbon pricing that reflect the true social cost of burning fossil fuels.

GELF supports a robust carbon tax, not the Governor’s cap and trade proposal which most climate groups nationally have repeatedly opposed due to its negative impact on environmental justice communities. The International Monetary Fund estimates that the world’s governments provide an annual subsidy of $7 trillion to fossil fuel companies. The vast majority of this comes from the failure to hold polluters financially accountable for the damage their emissions cause.

Back in 2015, GELF helped write a carbon tax bill for NY, a better solution to the cap-and-trade proposal the Governor is now running away from. The price of the carbon permits should reflect the social cost of carbon, which DEC estimates is $121 a ton (EPA $190 a ton). The revenues need to be invested in helping people decarbonize their homes and communities while protecting them from price shock. We must make polluters pay, stopping the present practice of paying for renewable energy and ZECS as a surcharge on utility bills. New York State needs to end its massive subsidy to four old nuclear power plants, while it underfunds renewable energy. Instead, the Governor is proposing to extend the subsidy for two decades at a potential cost of $30 billion.

A carbon tax is the most efficient means to instill crucial price signals that spur carbon-reducing investment. A carbon tax can also be used to recapture some of the costs pushed on to taxpayers and consumers from burning fossil fuels, such as the $50 billion added annual health costs in NYS to deal with air pollution and fossil fuels and the tens of billions of dollars of damage from climate change (e.g., severe weather)

Unlike cap-and-trade, carbon taxes do not create complex and easily gamed “carbon markets” with allowances, trading and offsets. An upstream carbon tax levies a tax according to the amount of carbon dioxide emitted by each fossil fuel. The cost of the tax is then passed along to consumers and producers as fossil fuels and energy intensive goods and services become more costly. If the carbon tax is effective, goods and services which are less energy intensive will become more affordable than those which release larger quantities of carbon dioxide into the atmosphere.

GELF continues to oppose a cap-and-trade program, which even Pope Francis warns has been manipulated by various Wall Street schemers and often has had a negative impact on EJ communities. Cap-and-trade programs historically have failed to achieve the stated emission reduction goals. A key reason is the usually at the last moment state officials appease the fossil fuel polluters by weakening the emission reduction standards. What is unusual in New York is that the Governor has been continually weaking such goals, including prices, years before the proposal is finally adopted. For instance, she has further reduced the proposed floor for carbon pricing to $14 per ton.

As New York focus reported, “New York, by contrast, wants to set a price ceiling that is lower than the floor in its peer states. At an initial price of $14 or less per ton, the state is almost certain to sell out of allowances and be forced to issue more, taking the “cap” out of cap and invest. Regulators’ own modeling found that this would lead to emissions at least 15 percent higher than the state’s legal limit in 2030.”

A cap and invest program will only benefit New Yorkers if it is implemented in a just way. GELF supports the cap-and-invest proposals made by NY Renews:

Pollution limits must decline every year in every sector, including the electric sector, and these limits must be strongly enforced.

Facility-specific caps on greenhouse gas and co-pollutant emissions must be non-tradable, with aggressive penalties for exceeding cap levels. Do not allow permit trading to game the system. Permits should not include trading after purchase, double allowances, offsets, and banking of unused permits year-to-year.

Revenue collection must be tailored not to harm vulnerable New Yorkers. The cost burden for New Yorkers who can least afford it must not be made worse. The cap and invest program must include rebates and targeted relief for low- and moderate-income households to ensure energy bills go down. We believe the strongest approach is to create a Climate and Community Protection Fund and direct any funds raised to that fund.

Any cap and invest system must be part of a broader regulatory approach to reducing pollution and must ensure that New York can achieve the greenhouse gas reduction mandates in the CLCPA.

Pollution reduction mandates for overburdened communities by agencies including the NYS Department of Environmental Conservation, and the Attorney General’s office. In addition to a C&I system, we need a broad array of effective regulations and enforcement to reduce pollution.

Permits must avoid loopholes. Cap and invest must avoid loopholes that have weakened or undermined other efforts, including permitting banking, offsets, and exemptions. Permit holders should not be allowed to play games with trading after purchase, exemptions, double allowances, offsets, and banking of unused permits year-to-year.

Permits should have a clear and escalating price, not set by auction. If the final program auctions the permits, we must ensure a price floor sufficient to support spending and drive emissions reductions and weigh in pricing towards Disadvantaged Communities and environmental justice areas. The price and regulations must be based on the CLCPA’s current 20-year cost accounting.

Public Ownership of the Transmission Grid

One of the biggest barriers to renewable energy is the challenge of hooking up to the transmission grid. When NY Energy Czar Richard Kaufman years ago told GELF that this was the main reason for the state’s failure in developing renewable energy, we point out to him that the common sense solution to save money, speed up renewables and increase coordination was to have the state take over the statewide grid through eminent domain.

The US Department of Energy reports that proposed renewable generation and energy storage projects face lengthy delays and high costs to interconnect them to the transmission grid. Without reforms, interconnection is likely to remain a major obstacle to meeting clean energy deployment and decarbonization goals.

Grid connection requests are more than double the total installed capacity of the US power plant fleet (2,600 vs. 1,280 GW). The time required to secure a connection has increased by 70% over the last decade, and withdrawal rates remain high at 80%. Connection costs have more than doubled over the last decade.

The American Public Power Association says “The case for public ownership is supported by the need for strategic coordination and the scale of investment required to build a decarbonized electricity system. Public ownership can help overcome the challenges of underinvestment and fragmentation in the regulated private monopoly model of grid ownership and governance.”

A study of this issue in the UK found “that underinvestment is a feature, rather than a bug, of the regulated private monopoly model of grid ownership and governance, which is unable to deliver the scale of investment and strategic coordination of deployment needed at the pace required. This model of ownership is ill-suited to the operation of this vital infrastructure and is incapable of meeting the urgent challenge of building a decarbonized electricity system. We argue that this problem is not incidental but structural — a mechanical outcome of organizing the ownership and operation of the grid around a fragmented set of privately owned monopolies whose ultimate mandate is to maximize profit for shareholders.”

At the same time, the grid must be strengthened against the growing risks of climate change. Extreme weather events such as heat waves, hurricanes, and flooding are placing increasing stress on existing infrastructure. Future investments should be required to meet climate-resilient design standards that account for forward-looking risks rather than historical averages. The deployment of microgrids and local resiliency hubs in vulnerable communities, as well as targeted undergrounding of critical lines in storm-prone regions, would help safeguard both public safety and energy reliability.

Under the present system, permitting remains a major obstacle to timely grid improvements. A more coordinated permitting framework is needed, one that includes binding timelines and clear conservation and equity standards. Such a system would reduce duplication between DEC, PSC, and other regulators, while ensuring that grid expansion does not compromise ecosystems or burden disadvantaged communities.

Beyond large-scale infrastructure, distributed energy resources (DERs) offer a critical opportunity to enhance flexibility and resilience. Demand response, battery storage, and rooftop solar can reduce peak loads and defer costly grid upgrades, but their deployment has been uneven. The agency should strengthen incentives for DER adoption through dynamic pricing, expanded credit programs, and wider deployment of advanced metering infrastructure. By giving customers the tools to participate actively in grid management, New York can build a more flexible and resilient system. The reliance on natural gas for reliability, particularly in New York City and Long Island, highlights a further vulnerability in the State’s grid strategy. To achieve a zero-emissions grid by 2040, New York must focus investment in clean firm resources and long-duration storage. These investments would help address renewable intermittency and provide the reliability backbone for a decarbonized grid and create pathways for long-duration energy storage.

Recommendations related to the present transmission system:

Grid Strengthening: require new transmission and distribution projects to meet forward-looking climate resilience standards, accounting for sea-level rise, flooding, hurricanes, and extreme heat. Further expand microgrids and resilience hubs in vulnerable and disadvantaged communities to safeguard public safety and provide localized backup power during outages. Implement targeted undergrounding of critical lines in storm-prone regions to improve reliability and reduce disaster vulnerability.

Accelerate transmission and distribution upgrades: Prioritize accelerated investment in new high-voltage transmission corridors to connect upstate renewables with downstate load centers. Focus on modernizing distribution networks with smart technologies and undergrounding where feasible, to improve efficiency and reliability. Introduce a state-led fast-track program for strategic transmission corridors, balancing environmental protection with the urgency of renewable integration.

Expand DERs: Strengthen incentives for rooftop solar, demand response, and battery storage by adopting dynamic pricing models and expanded energy credit programs. Require utilities to deploy advanced metering infrastructure statewide to support customer participation in grid flexibility programs. Expand upon the successful NY-Sun program with a goal of 20 gigawatts of new distributed solar by 2035. Recognize DERs as a formal part of system planning, with procurement targets tied to peak load reduction and resilience outcomes.

Invest in long-duration storage and clean firm resources: Establish procurement mandates for long-duration storage to address renewable intermittency and reduce reliance on fossil gas. As well as align procurement and R&D funding with CLCPA targets to ensure firm resources scale in time for 2040 reliability needs.

Electric Sector – Build and Fund More Renewables

New York has struggled to build out renewable energy resources at the pace necessary to achieve the Climate Act’s important clean power mandate of 70 percent renewable energy by 2030. While recent federal actions to restrict renewable energy development are exacerbating this challenge, New York’s struggles predate the current federal administration, and there remain actions the state can take to improve siting, permitting, and contracting. The Draft State Energy Plan’s failure to articulate a strong vision for advancing solar, wind, and both short- and long-duration storage is dismaying.

While the pace of renewable energy development has been slower than planned, the shortfall of clean energy has been exacerbated by increased load growth forecasts. To some extent, these forecasts are influenced by planned electrification of buildings and vehicles, but they also reflect new cryptocurrency mining facilities, data centers, artificial intelligence (AI) training facilities, and other large loads such as Micron’s enormous proposed semiconductor chip fabrication plant in Oneida County. The Micron facility alone would increase New York’s total statewide electrical demand by more than 11 percent!

The state should not prioritize or subsidize cryptocurrency or data centers. Large energy users should pay their fair share for the energy and grid infrastructure they require, ensure the energy they consume is clean and compliant with New York’s climate and clean energy mandates, and ensure that they are not siphoning clean energy that would otherwise be delivered to other New York ratepayers.

A central tension in the plan lies in the balance between renewable expansion and demand. This section does not have a plan for demand while also pursuing ambitious source recommendations and targets. Despite the ambitious CLCPA target, the siting and permitting standards overseen by DEC and the PSC remain slow, fragmented, and often contested. While these standards aim to safeguard ecosystems and communities, their inefficiencies risk delaying renewable

Further, while DACs are acknowledged as particularly vulnerable; the standards often reduce protections to technical compliance measures—such as noise thresholds, visual impact assessments, or wetlands regulations. These narrow requirements do not guarantee that benefits and burdens from renewable energy projects are distributed equitably.

Expand Public Power

GELF is a strong proponent of public power combined with democratic control. There are presently more than fifty municipal utilities in NYS, and the energy plan should seek to increase their role in providing clean, affordable energy to New Yorkers.

Publicly controlled energy is the most effective way to ensure a transition to affordable, renewable power in a way that supports workers and prioritizes well-being for all individuals. Across the board, public power is greener, safer, and cheaper. There are many reasons to consider public power:

Energy bills under public utilities are on average 14% cheaper for households
Public power is more reliable, and outages last less than half as long as the national average
Public utilities have a track record of reinvesting profits back into communities.

By relying on investor-owned utilities and not challenging the regulatory structure as it currently operates, the Plan maintains the profit-driven, corporate, expansionist fossil fuel system. It fails on reliability, emphasizing continued usage of the dangerous and accident-prone fossil fuel system far into the future. NYPA should be the main driver in building the distributed and utility scale solar, thermal energy systems, on-shore wind, battery storage, and transmission projects that are required to keep the homes of working families warm (and cool) and to stop polluting their air.

NYPA should commit to at least 15 GW of public power by 2030. This buildout, in addition to wind and solar, should include large scale thermal energy systems, which shave peak electricity and gas loads and reduce the demand peaks that are responsible for the expensive expansion of those systems.

The climate legislation that GELF drafted in 2015 was significantly stronger than the CLCPA. One key difference was a much stronger and faster planning process at the state and local level, with counties and municipalities with greater than 50,000 residents also required to develop a climate action plan. Local municipalities should be required to identify their preferred sites for renewable energy projects so that local residents rather than private developers drive that decision. The state through NYPA should also provide the upfront financing to any local government who wants to build a publicly owned energy system.

GELF’s recommendations for NYPA include:

Increase the planned capacity to at least 15 gigawatts of new, publicly owned renewables by That means 25,000 green union jobs, the end of “Peaker” plants polluting black and brown neighborhoods, and the kind of leadership that will carry this whole country’s climate forward.
Ramp up their pace of adding projects and beginning construction to take advantage of Federal solar and wind tax credits prior to their expiration
Commit to developing alternative ﬁnancing methods to bring more renewables online, regardless of federal tax credits, such as expanded bond ﬁnancing.
Plan at least 5 GW for the Hudson Valley and downstate New York, with more attention to distributed energy resources.
Fully decarbonize our public schools by siting utility-scale and distributed generation on SUNY and CUNY campuses and K-12 schools statewide, building enough capacity to meet their energy demands.
Substantially increase the number of such projects sited on public lands, in partnership with the Department of Education, MTA, and
Ensure that enough capacity is built to create and sustain a pipeline of green union jobs for New Yorkers
Redirect economic development funds from large corporations and towards renewable energy development, REACH funding, and Indian nations
Plan additional projects on brownﬁeld sites to turn polluted land to a positive
Make all projects REACH

Draft Energy Plan Fails to Adequately Address the CLCPA Mandate to Ensure 35% of Climate Fund Benefits Disadvantaged Communities (DAC)

DACs are acknowledged as disproportionately vulnerable to climate impacts, and initiatives such as the Extreme Heat Action Plan aim to provide targeted protection. However, many of these measures are framed as recommendations rather than enforceable requirements. Without stronger accountability mechanisms, DACs and EJ communities will continue to face systemic inequities in access to affordable energy, resilient housing, and long-term adaptation resources.

Equity commitments within the plan remain aspirational rather than enforceable. While DACs are correctly recognized as disproportionately vulnerable to climate impacts, the measures proposed—such as cooling centers and weatherization programs—lack binding requirements or guaranteed funding. To close this gap, conservation standards should embed enforceable equity mandates that align with the CLCPA, with measurable metrics to track the delivery of benefits. This would ensure that DACs receive more than symbolic recognition and instead gain meaningful, equitable protection.

Do More to Cut Emissions From Buildings

As the federal government is in the process of eliminating incentives for clean energy and freezing, reducing, or eliminating funding for energy assistance that millions of New Yorkers rely on, it is more important than ever for New York to provide energy assistance, reduce climate pollution, and sustain and grow the clean energy industry.

The master plan should commit to decarbonize all buildings by 2035, with the state and the utility companies being responsible for upfront financing, as was provided in the Green Jobs Green Home law. A faster timeline should be established for all government owned buildings (see section below re decarbonization of the Capitol complex).

Buildings are the largest source of greenhouse gas emissions in New York State. Improving the energy efficiency of our buildings and transitioning buildings off of fossil fuels means better health, safety and comfort for the people living in them. The State Energy Plan must include an ambitious and thoughtful roadmap for transitioning buildings to heat pumps and efficient appliances while ensuring affordability and reliability. With these goals in mind, Governor Hochul should sign A.8888/S.8417 immediately to eliminate the 100-foot rule, which adds an extra charge to everyone’s gas bills and keeps us stuck on gas instead of transitioning to cleaner, more efficient heating and cooling systems.

Some positive elements in the draft State Energy Plan:

a commitment to new all-electric construction
a commitment to integrated gas-electric planning, including thermal energy networks (TENs)
clearly rejecting costly, dangerous and impractical false solutions for building decarbonization: hydrogen, so-called “renewable natural gas,” “certified natural gas,” and “synthetic natural gas” should not be included in any plan for decarbonizing buildings.

Some of the biggest deficiencies in the Draft State Energy Plan pertain to natural gas and the buildings sector, which is the largest sector of greenhouse gas emissions in the state. The Draft State Energy Plan walks back critical recommendations from the Scoping Plan and punts meaningful decarbonization planning to a future strategic gas transition plan despite having already dragged stakeholders through years of gas planning proceedings.

The plan itself acknowledges that its level of ambition is far below what is requisite based on the Climate Leadership and Community Protection Act’s mandates. On page 13 of the Buildings chapter, it states that: “…the themes and recommendations discussed in the remainder of this chapter reflect…a path of achievement that resembles the Steady Progress scenario…”. “However, full realization of the Climate Act targets by 2050, as portrayed in the Net Zero Scenarios, will require significant additional investment and market adoption for efficient electrification, backed by strong policy commitments such as new regulatory mandates, early retirement of existing fossil fuel equipment, as well as substantial technical progress…”

To enable cost-effective decarbonization of the buildings sector, the State Energy Plan must recommend elimination of the gas utility obligation to serve. The Draft State Energy Plan’s recommendations for promoting alternatives to gas pipeline investments will not work if the obligation to serve gas remains unchanged.

To facilitate cost-efficient gas utility planning, the State Energy Plan must establish a sectoral target for emission reductions from gas delivered to buildings in the buildings sector.

GELF strongly supports the recommendation to prioritize support for energy upgrades in Low to Moderate Income (LMI) housing. However, efforts to assist LMI households transitioning to cleaner and safer electric appliances must be part of a holistic effort to shrink the state’s sprawling, dangerous, and costly gas pipeline system.

The State Energy Plan must incorporate the Scoping Plan’s recommendation to adopt zero emission appliance emission standards. The Scoping Plan included concrete recommendations for zero-emission standards for appliances with years and appliance types. The State Energy Plan must incorporate these recommendations, which are critical.

The final State Energy Plan must not only ban dangerous and wasteful hydrogen blending into the gas pipeline system but must establish clearer limitations on use of other alternative fuels such as “renewable” natural gas (RNG). Clean and more efficient options exist to decarbonize buildings, and limited supplies of less climate harmful RNG must be targeted to truly difficult-to-electrify sectors and end-uses.

Enact the Renewable Capitol Act; Immediately Start Converting the State Capitol to Use Geothermal

The Renewable Capitol Act (S2689/A5633: 2024 numbers) mandates the conversion of the Capitol and Empire State Plaza to renewable energy. GELF supports an initial appropriation of up to $150 million in the 2026-27 state budget for the first year for planning and construction costs as identified by the Empire State Plaza Energy Infrastructure Master Plan (May 2024, Ramboll), for a geothermal system for the buildings connected to the Sheridan Avenue Steam Plant.

While the CLCPA requires New York to cut greenhouse gas emissions by 40% by 2030, the state’s current plans to decarbonize the state’s properties will not meet this goal. After years of delay, this May the Office of General Services (OGS) released its long-awaited Empire State Plaza Energy Infrastructure Master Plan (May 2024, Ramboll). The Ramboll plan specified that $150 million is the cost for a thermal energy network, however, it calls for the network to begin in Phase 3 starting in ten years. According to geothermal experts, work on the thermal energy network could be done in conjunction with the maintenance work being done in Phase 1 of the plan. There is no reason to delay geothermal for the Capitol.

Three states presently use geothermal to power their capitol – Colorado, Oklahoma, and Michigan. Michigan was the most recent to convert, completing the project within 18 months after first studying it while providing 500 construction jobs. The geothermal system at the Michigan State Capitol is expected to pay for itself in about 10 years. The system was installed in 2017 as part of a $70 million project to improve the building’s facilities.

The Capitol and Plaza should be a priority due to their symbolic significance as the house of New York’s government. In addition, the continued operation of the Sheridan Avenue Steam Plant (SASP) which has polluted a low-income people of color neighborhood for over a hundred years to heat and cool the Capitol Complex is contrary to New York’s environmental justice policy. The plant has burnt coal, oil, trash and now gas. Department of Health statistics show that the area around the SASP is one of three cancer clusters in Albany County. The state is literally poisoning its neighbors in order to heat and cool the Capitol and Plaza.

Work has begun to decarbonize the Plaza. In 2019 the state legislature rejected a proposed $88 million appropriation to add new fracked gas turbines on Sheridan Avenue and redirected the funding for renewable energy projects. Energy efficient lighting and an electric chiller have been installed to replace one using fossil fuels. In 2023 the legislature appropriated $30 million to study the decarbonization of the top fifteen greenhouse gas emitting state owned facilities of which the Capitol Complex is among the top three. The next clear step for decarbonizing the Complex is installing a thermal energy network which includes geothermal.

Work on the Capitol will provide state policymakers and state agency staff with the ability to see for themselves how the transition to renewables can be done and provide a roadmap on how to build a workforce that is ready to take on the necessary buildout of thermal networks to transition our state buildings to renewable energy.

Stronger reductions in role of gas utilities

As New York’s highest emitting sector, buildings are responsible for at least 33% of all greenhouse gas emissions statewide, which is driven by the burning of fossil fuels, predominantly methane gas, for space and water heating. A specific emissions limit must be set for the gas system. The Scoping Plan’s Integration Analysis calculates that in order to meet our emissions reductions targets, emissions from buildings must go down by at least 85%. The State Energy Plan should recommend amending the gas utility obligation to serve and eliminating subsidies for new gas interconnections.

The recommendation for state agencies to conduct a gas system transition plan must be strengthened substantially. At the very least, the plan should include two or more gas utilities, including Con Edison and National Grid, in order to capture a meaningful portion of the state’s gas distribution network.

Lower Energy Bills

Low- and middle-income households and seniors on fixed incomes are struggling to afford rising energy costs to keep their homes warm in the winter and cool in the summer. The State Energy Plan must direct investments and include policy measures to address energy insecurity, which is experienced by a significant percentage of New Yorkers.

The State Energy Plan should:

direct state agencies to conduct a comprehensive plan for energy affordability to keep energy costs at or below 6% of household income.
ensure that low- and moderate-income energy programs such as EmPower+ are fully funded to sustain current levels and meet future growth.
ensure that the Energy Affordability Program (EAP) is fully funded and fully enrolled.
ensure that robust Green Affordable Pre-electrification (GAP) funding is provided to upgrade homes that would not otherwise qualify for energy efficiency measures.
ensure that no- or low-interest loans are available for home energy upgrades.
include recommendations for discounted electricity rates for buildings or households that electrify.

Transportation Sector

While the White House is attempting to halt all progress on reducing greenhouse gas pollution from motor vehicles, New York state must stay focused on turn key solutions within its control such as the Clean Deliveries Act, a warehouse Indirect Source Rule that cuts pollution from the rapidly growing ecommerce industry, and utility support for transportation electrification.

The State Energy Plan should recommend accelerating the Public Service Commission’s (PSC’s) medium- and heavy-duty vehicle docket to create avenues of financial support for charging these vehicles. In addition, the Plan should support rapid resolution of the PSC’s Proactive Planning docket to ensure that grid upgrades required to support transportation electrification can move forward in a timely manner. We must prioritize the rapid acceleration of deployment of charging infrastructure across New York State with both medium-heavy duty vehicles and light duty vehicles.

The State Energy Plan should recommend that New York takes all reasonable steps to ensure that it is able to access and deploy sources of federal funding for clean transportation such as National Electric Vehicle Infrastructure (NEVI) funds and Charging and Fueling Infrastructure funds. These pots of federal funding can reduce the cost burden on New Yorkers to support transportation electrification.

The Plan’s Low Carbon Fuel Alternatives are Primarily False Climate Solutions

The plan’s conservation standards in this section fall short by overlooking full lifecycle impacts of biofuels, providing limited ecological safeguards for hydrogen, failing to robustly integrate equity considerations, and lacking strong adaptive monitoring and enforcement mechanisms.

The plan’s approach to biofuels highlights several shortcomings towards our climate mandates. Renewable natural gas (RNG) and biomass are positioned as important contributors to decarbonization, but the ecological safeguards around their production and use are underdeveloped. RNG production, for instance, does not lay out a concrete plan and is not cohesive. While it is mentioned as an option in the pathway to decarbonization, the plan also proposes to pursue options such as looking outside of New York State to import RNG – an expensive and unsustainable method to “fuel phase out.” The push for these fuels could undermine conservation goals even as it reduces emissions.

Additionally, while the section places some measures to stop hydrogen blending but there is no consideration as to the infrastructure challenges of hydrogen production and has no clear guidance on resource use, leakage prevention, and ecological safeguards, the State risks building a hydrogen system that solves one environmental problem while creating others – similar to the previous Electricity and Nuclear sections.

Climate activists generally oppose “blue hydrogen” which is produced mainly from natural gas. The controversial carbon capture technology seeks to capture the carbon used in making hydrogen. Many climate activists, within limits, support green hydrogen, which is produced by splitting water into hydrogen and oxygen using renewable electricity. But there are other environmental concerns with green hydrogen, and most groups support a limit on the use of green hydrogen (e.g., for local use, certain industrial and transportation uses.)

Food & Water Watch is one of the strongest opponents of hydrogen, with significant concerns about even green hydrogen. It argues that “Hydrogen entrenches fossil fuel use and infrastructure, as well as the resulting pollution in frontline communities.” It notes that hydrogen production would consume the annual equivalent of water used by thirty-four million Americans. Jasmin Vargas, a Food & Water Watch organizer, called hydrogen “fundamentally racist and inequitable,” due to the potential nitrogen oxide pollution it could cause. Opponents argue that nitrogen oxide, which can damage lungs, poses more of a threat than current natural gas technology.

Hydrogen’s main climate benefit is to reduce the carbon intensity of on-site industrial production processes (such as in cement manufacture), which require the high temperatures of burning fossil fuels. More than one quarter of global emissions come from on-site industrial processes involving fossil fuels. The problem is that hydrogen production in itself is carbon intensive since almost all of it is presently produced from fossil fuels.

There’s controversy over blue hydrogen because natural gas production inevitably results in methane emissions from leaks of methane from the drilling, extraction, and transportation process. Cornell and Stanford University researchers found that the use of blue hydrogen is more harmful than once thought due to the high amounts of natural gas needed to fuel the process, combined with the escape of “fugitive” carbon dioxide and methane emissions produced from extraction. The study found that blue hydrogen utilizes inefficient carbon capture and storage technologies.

Another weakness in the draft plan lies in the treatment of lifecycle impacts. Conservation measures are framed primarily around end-use emissions without robust safeguards, with less emphasis on the environmental consequences of the full supply chain. Biofuels and RNG may reduce carbon intensity at the point of use, but their production often results in upstream and production stage hazards and contributions to air pollutants like Nitrogen Oxides. Furthermore, low-carbon fuels require long-term monitoring of their environmental and social impacts, yet enforcement provisions are vague, raising concerns that mitigation commitments will be nominal and inconsistently applied. Without adaptive oversight, the State risks advancing alternative fuels at the expense of ecosystems and communities. Therefore, it is not a source that should be further pursued as a low carbon fuel option.

NY Renews notes that “the promotion of renewable gas is a strategic bid to buffer the fossil gas industry from policy and market changes that threaten its very existence. Further, such an effort raises serious concerns about the expansion of carbon-intensive land-uses to grow feedstocks necessary to ‘green’ the fossil gas system, as existing feedstock capacity is only sufficient to replace between 6 and 13 percent of current gas demand. Biomethane and fossil gas have virtually the same chemical composition and both emit similar levels of nitrogen oxides upon combustion and thus is not considered any cleaner from an environmental justice perspective. Like other biofuels, biomethane must be blended with other fossil fuels and thus depending on the continued existence, and indeed expansion, of the pipelines and other infrastructure of the larger fossil gas supply chain.”

RNG is not as low carbon as the industry claims, and its local air and water impacts are concentrated in vulnerable communities. While RNG can prevent methane from escaping from the initial source of the biogas, it does not eliminate the significant leakage of methane from biogas capture and processing, pipelines, building hookups, and appliances. There is not enough of it to substitute for more than a small fraction of natural gas. RNG will also cost significantly more than fossil gas, in the range of 3 to 15 times higher compared to current prices by 2040.

Biofuels create other problems that compound climate and energy problems. NY Renews notes that problems arise from the “cultivation of their feedstocks and related land-use changes, displacement of food production, soil and water contamination, carbon-intensive fuel processing methods, and non-greenhouse gas pollutants and local pollution.” Biofuels have some levels of carbon emissions upon combustion and in their production process and contain non-GHG pollutants that are released. Biofuel production from vegetable oils is a net contributor to GHG emissions due to direct and indirect land-use changes. Only biodiesel made from waste fats appears to be less carbon intensive than fossil fuels.

While the industry promotes biofuels as an environmental justice measure since they could reduce emissions from trucks in low-income communities, they are not commercially viable and have had insignificant impact on improving air quality in truck-clogged communities and high exposure workplaces.

Ethanol emissions are associated with higher rates of ozone formation, a major source of respiratory illness, particularly in low-income communities of color. It is also no better than gasoline in terms of carcinogenic potential.

The integration of environmental justice into conservation standards is also incomplete. Although DACs are acknowledged, the standards are largely technical in focus—emissions thresholds, siting requirements, or safety rules. They do not fully address how DACs might be disproportionately affected by new hydrogen hubs, biomass facilities, or RNG plants. Localized air pollution, land-use conflicts, and cumulative environmental burdens remain insufficiently covered, leaving vulnerable communities at risk of carrying a greater share of the costs of decarbonization.

Nuclear is a False Climate Solution and Should Not be Pursued

Nuclear energy is a false climate solution. The extreme length of time needed to design, permit, build, and operate nuclear power plants means that they will come online far too late to enable NY and the world to keep global warming below the 1.5 C degree target.

Nuclear energy, which is not a renewable energy source, presents a range of significant challenges that undermine its role as a sustainable energy source. Safety risks remain a core concern demonstrating the potential for long-term contamination of land, water, and communities. Even under normal operation, reactors release small amounts of radioactive material, while uranium mining has historically harmed Indigenous peoples through exposure to radiation and environmental degradation. The problem of radioactive waste remains unresolved, as spent fuel is stored on-site in dry casks that last a century while the waste itself remains hazardous for millennia, leaving future generations with an unfair burden.

Economically, nuclear power is the most expensive form of electricity, requiring massive subsidies and bailouts to keep aging reactors online while cheaper renewables go underfunded. Finally, issues of equity and justice persist with communities being disproportionately exposed to nuclear facilities and waste storage and Indigenous sovereignty is routinely violated through mining and waste siting.

As Amory Lovin notes: “An intensive influence campaign seeks to resurrect a “nuclear renaissance” from the industry’s slow-motion collapse as documented in the independent annual World Nuclear Industry Status Report. Claims that past failures will not recur have convinced many politicians that socializing nuclear investments rejected by private capital markets, weakening or bypassing rigorous safety regulation, suppressing market competition, and commanding military reactors and data-center projects as a national-security imperative will restore nuclear expansion and transform the economy. This illusion neatly fits the industry’s business-model shift from selling products to harvesting subsidies.

“Even the most skilled firms and nations keep delivering big reactors with several times the promised cost and construction time. A swarm of startup firms that have never built a reactor are dubiously rebranding their inexperience as a winning advantage. New designs are said to be so safe they do not need normal precautions (though not safe enough to waive nuclear energy’s unique exemption from accident liability).” The previous “nuclear renaissance” in the US several decades ago resulted in one new nuclear plant coming online.

Recommendations: Plan for reactor phase out: The plan should have a comprehensive retirement roadmap for existing nuclear plants, with specific timelines, workforce transition programs, and replacement renewable capacity. This should include replacement planning so that future electricity needs are met with sustainable alternatives rather than indefinite nuclear extension

Realign subsidies: Instead of the plan proposing to relying on ZECs and other bailout subsidies to keep aging reactors online, redirect the funds towards Tier 1 renewable energy credits and distributed clean energy programs that directly benefit disadvantaged communities – alongside a required periodic subsidy review and adjustment tied to actual market conditions and comparative health, climate, and equity benefits.

Nuclear power is not carbon free when the lifecycle of the plants is considered, with carbon emissions occurring during construction; mining, processing and transportation of the uranium fuel; and the storage of the dangerous radioactive wastes for tens of thousands of years. Nuclear power continues to have significant safety problems. While the industry likes to portray the 1.5% rate of major accidents such as core meltdown as “minor,” such incidents in fact have caused tremendous harm. The industry has been plagued by long construction delays and massive cost overruns

Renewables are cheaper. By 2050, the Levelized Cost of Energy for utility-scale solar PV is expected to be around $25/MWh and for onshore wind around $35/MWh, while advanced nuclear power is projected to remain at $110/MWh, according to the U.S. Energy Information Administration. the 2023 Renewable Power Generation Costs indicated that the global weighted average levelized cost of electricity for newly commissioned utility-scale solar photovoltaic, onshore wind, offshore wind, and hydropower projects experienced a downward trend.

Cost estimates for nuclear power generally do not include the cost of the major nuclear meltdowns that have taken place. Lazard’s cost estimate does not include the cost of the major nuclear meltdowns in history. For example, the estimated cost to clean up the damage from three Fukushima Daiichi nuclear reactor core meltdowns, is $460 to $640 billion. Such cost figures also ignore the $500 million spent yearly to safeguard high-level waste from about ninety-two civilian nuclear reactors. (And smaller, experimental small reactors are likely to be more expensive due to less economies of scale.)

NYSERDA Finds Astronomical Costs to Ratepayers & Taxpayers: The Governor directed NYSERDA to conduct a 2024 Financial Assessment Report on Advanced Nuclear Technologies. NYSERDA has refused to admit that they conducted this assessment, though the PSC in response to an FOI request admitted it exists. Their findings were that new nuclear would result in astronomical costs to ratepayers and taxpayers and pose enormous liability risks to the state.

Recently, sources reported that NYPA’s Boston Consulting Group 2025 report and NYSERDA’s Brattle Group 2025 report assessing the financial impact of nuclear energy technologies also found that it poses sky-high costs to ratepayers. (NYSERDA whistleblowers)

Former NRC Commissioner States Enormous Sums of Money Wasted on Nuclear: “The 2025 Atlantic Partnership for Advanced Nuclear Energy between the US and UK is a pointless PR effort … None of it will bring down the cost of electricity for consumers and provide sustainable, clean electricity for the future. The future of nuclear power in both nations can be summarized simply by the enormous sums of money wasted … No amount of handshakes or pledges will change the fundamental challenges of building cost effective, timely nuclear power.” (Former Nuclear Regulatory Commissioner Gregory Jaczko, 9/17/2025 Statement)

Nuclear has a History of Dramatic Cost Overruns: “The history of the U.S. nuclear industry is one of dramatic cost and schedule overruns. For example, a 1986 DOE study compared the estimated versus actual overnight costs of seventy-five reactors that started construction between the years of 1967 and 1977. This study found that the actual cost of building these reactors was, on average, triple the cost that had been estimated when construction began.” (David Schlissel, Schlissel Technical Consulting, 4/18/2025 Testimony before Colorado Public Utilities Commission)

Last US Reactors Were Built 157% Over Budget: “In the first decade of this century, over 20 new reactor projects were proposed around the U.S., but only two reactors were constructed at the Vogtle Nuclear Project in Georgia. The Vogtle project was 157% higher than initially estimated with a cost overrun of about $22 billion and a schedule overrun of ~6 years. Westinghouse declared bankruptcy due to problems with the project and the dramatically rising costs.” (David Schlissel, Schlissel Technical Consulting, 4/18/2025 Testimony before Colorado Public Utilities Commission)

Small Modular Reactors are not cheaper, safer or cleaner. Small Modular Reactors (SMRs) face problems with higher costs, extended timelines, greater nuclear waste challenges, potential safety vulnerabilities due to less containment than traditional plants, increased security risks, and significant technical and regulatory hurdles. The promised benefits of faster construction and lower costs are not being realized, as regulatory approval, the development of the supply chain for parts and fuel, and the management of waste and security all present significant challenges.

Renewable Energy Can Deal with the Intermittent Issue. Nuclear advocates claim it is still needed because wind and solar are intermittent and need natural gas for backup. However, nuclear power itself never matches power demand, so it needs backup. Dozens of independent scientific groups have further found that it is possible to match intermittent power demand with clean, renewable supply and storage, without nuclear or fossil fuels, at low cost. Military and industrial installations already prefer 100% renewables for their most critical applications, including Apple’s data centers in four states. Ten kinds of carbon-free resources can balance variable (but highly predictable) renewables, keeping the grid stable – as is done in a number of other countries.

Around the World Renewable Energy Far Outpaces Nuclear Energy

Renewables Far Outpace Nuclear on Costs & Energy Performance: Recent international report found renewable energy far outpaces nuclear energy on both costs and energy performance. The nuclear “industry won’t likely be able to sustain growth in the face of limited investment, aging power plants, continuing project delays, and overwhelming competition from cleaner, more affordable renewable energy …” (World Nuclear Industry Status Report (WINIS), 9/2025)

Renewables Generate 3 Times More Global Electricity Than Nuclear: “Each year, nuclear adds as much net global capacity as renewables add every two days. Soaring renewables generate three times more global electricity than stagnant nuclear power, whose 9% world and 18% U.S. shares keep shrinking. In 2023-24, China added 197 times more solar and wind than nuclear capacity, at half the cost. In May, China added 93 GW of solar, or 3 GW per day.” Amory Lovins, Stanford University Engineering Professor, RMI Chair Emeritus, Utility Dive, 9/5/2025.

Conservative Cato Institute: New Nuclear Will Not Work: The Cato Institute’s Fall 2025 status report on “The Next Nuclear Renaissance?” concluded: “The mystery is why the nuclear industry retains any credibility. Throughout its history, nuclear proponents have made rosy claims about the safety and economics of the next generation of nuclear projects, but they have all gone unfulfilled. However, after repeated failures to produce the forecasted results, why are renewed claims of this type being taken seriously now? The problem is not so much that money will be wasted on large numbers of uneconomic facilities. Rather, it is the opportunity costs of the time and human resources that are consumed by nuclear power and not available to other, quicker, more cost-effective and less financially risky options. We appear now to be facing serious risks from climate change, and there will not be a second chance if we fail to tackle it because too many resources are being consumed by an option—new nuclear—that will not work. (Cato Institute, 9/2025) https://www.cato.org/regulation/fall-2025/next-nuclear-renaissance#readings

Military & Industry Prefer Renewables: “Military and industrial installations already prefer 100% renewables for their most critical applications, including Apple’s data centers in four states. Ten kinds of carbon-free resources can balance variable (but highly predictable) renewables, keeping the grid stable. Using a small subset, power systems with modest or no hydropower already sustain such annual renewable fractions of electricity use as Denmark 88+%, South Australia 74% (expecting 100% in two years), and Germany 54%.” Amory Lovins, Stanford University Engineering Professor, RMI Chair Emeritus, Utility Dive, 9/5/2025.

Nuclear Makes Climate Crisis Worse: “Since a nuclear (kilowatt/hour) kWh costs several to many times more than a renewable or saved kWh — even more if nuclear load-follows to “complement” rather than curtail renewables — nuclear displaces less fossil fuel per dollar (or year), making climate change worse.” Amory Lovins, Stanford University Engineering Professor, RMI Chair Emeritus, Utility Dive, 9/5/2025.

Huge Strides on Solar & Wind in Texas: “Texas has increased annual wind and solar generation by huge strides … to 22,833,960 MWh increase in 2022. These increases are well more than a 1,000 MW nuclear plant can produce. In total, Texas has increased renewable energy generation by nearly 103 million MWh from 2015-2023. In the 16 years since 2007, the increase was over 138 million MWh – more than three times the total amount of nuclear generation in the state.” NIRS/AGREE Blueprint Draft Comments, 2024. Source: U.S. Energy Information Administration.

Solar Soars in California: “California increased utility-scale solar generation by 26,186,585 MWh from 2015-2023, and it has deployed 13,000 MW of battery storage capacity. A recent analysis of California’s electricity system performance … concludes that the large deployments of solar and storage in the last two years have already had a demonstrable effect in improving grid reliability, despite record levels of heat this year.” NIRS/AGREE Blueprint Draft Comments, 2024. Sources: GridStatus, 9/13/2024; Energy Storage News,10/18/2024.

AI Energy Demand Can Be Fully Addressed With Renewables & Storage: “Investments in residential heat pumps, batteries and solar arrays could meet 100% of projected electricity demand growth from AI data centers through 2029, according to a report from Rewiring America. The large tech and infrastructure companies behind the U.S. AI boom could unlock more than 93 GW of grid capacity at costs comparable to building a new fleet of gas power plants by paying 50% of the cost of heat pump upgrades and 30% of the cost of onsite solar and storage” Utility Dive, 9/24/2025

Nuclear is Heavily Dependent on Government Welfare

Taxpayers & Ratepayers Exposed to Major Risks: “Nuclear power plant projects with their specific risk profile largely only become bankable with governments de-risking the investment, thereby exposing taxpayers or ratepayers to the project risks.” (Copenhagen School of Energy Infrastructure 2024 report.)

Congress Provides Tens of Billions in Subsidies: “Nuclear electricity loses in open auctions, so only Congressional bailouts — $27 billion ($15 billion paid out) in 2005, $133 billion in 2021-22, tens of billions more in 2025 — saved most existing U.S. reactors from closure.” (Amory Lovins, Stanford University Engineering Professor, RMI Chair Emeritus, Utility Dive, 9/5/2025.)

$28 Billion Bill for NYS Ratepayers in the Past: NYS ratepayers provided an estimated $28 billion in subsidies, financing and bailouts for the state’s seven reactors, plus the Shoreham reactor. For list, go to https://docs.google.com/document/d/1m0IIa5kzqfG1uXzDKUQbm4uhq1D2LWc2qvDQAnUfK_A/edit?tab=t.0

PSC Proposes up to $33 Billion in Massive New Subsidies: The PSC proposes up to an additional $33 billion in ratepayer subsidies for four aging reactors to extend their operation by a risky 20 years. Aging nuclear reactors pose safety hazards due to accelerated material degradation from corrosion, embrittlement, and fatigue, increasing the risk of structural failures like reactor vessel cracks. This degradation can compromise safety functions, leading to potential radioactive releases, especially when combined with aging infrastructure and components that are harder to replace. (PSC Proceedings Proposal, 10/31/2025 comment deadline)

Nuclear Steals Billions of Dollars from Solar & Wind

Undermines Renewable Energy: Nuclear energy proposals are stealing funds and undermining the transition to renewable energy as required by the CLCPA. Nuclear energy’s requirement for large government subsidies undermines and delays needed rapid scale-up of benign renewable energy.

Trump Cuts Estimated to Cost NYS $60 Billion in Renewable Energy Funding: The NYS Department of Public Service estimates that the full gamut of Trump’s policy changes will cost New York $60 billion in renewable energy investment. Instead, the Trump Administration is moving aggressively to pursue new nuclear power on many fronts, providing massive amounts of money in grants and loans. (NY Focus, 9/18/2025) https://nysfocus.com/2025/09/18/new-york-energy-bill-hikes

32 Times More Ratepayer Funds go to Nuclear: Under the Zero-Emission Credit program, ratepayers in 2023 were forced by the state to invest thirty-two times more for nuclear power than renewable energy. NIRS/AGREE Draft Blueprint Comments, 2024.

PSC Cuts Millions in Solar: PSC cut or “redirected” $271 million for solar energy programs in 2025–and then proposed a few months later up to $33 billion in ratepayer subsidies for four old reactors over 20 years.

Nuclear is Inherently Dangerous

The Horror of a Nuclear Meltdown: The Chernobyl and Fukushima Daiichi nuclear disasters demonstrate how one accident causes widespread massive long-term pollution, cancer and other illnesses and serious social and economic disruption. For instance, “at the site of the 2011 Fukushima nuclear disaster in Japan, ‘onsite and offsite challenges remain overwhelming, with an initial removal of fuel debris amounting to around a billionth of the total. A focus on food safety monitoring finds an opaque system that makes it challenging for the government to convince observers it has control over the situation.”(World Nuclear Industry Status Report, 9/2025)

218 Reactors Leave Legacy of Pollution, Few Cleanups: “Of the 218 nuclear reactors that have been shut down worldwide, only 23 have been fully decontaminated, and only nine have been released by regulators and declared safe.” (World Nuclear Industry Status Report, 9/2025)

Cancer-causing Radioactive Contamination & GHG Emissions: Nuclear energy plants release radioactive substances and GHG emissions into air, water and land at every stage of its lifecycle—mining, fuel production and processing, operation, decommissioning, and the long-term storage of spent nuclear fuel, lasting centuries.

Insurance Companies Refuse to Provide Coverage, So Federal Law Caps Insurance at $660 Million Per Reactor, Yet Fukushima Reactor Cleanups Cost Up to $213 Billion: When nuclear energy technologies were first promoted in the 1950’s, insurance companies refused to insure plants due to the risks of a catastrophic accident. So, Congress passed the Price-Anderson Act. Each nuclear plant is capped at $660 million for liability insurance and damages to public. Cleanup costs for the Fukushima meltdown are estimated to cost up to $213 billion per reactor. The cost difference poses an enormous potential liability burden to New York State ratepayers and taxpayers

Nuclear Energy Produces Long-Lived Highly Radioactive Waste

Texas Governor: Radioactive Waste Has Capacity to Outlast Human Civilization:

“The proposed Interim Storage Partners facility imperils America’s energy security because it would be a prime target for attacks by terrorists, saboteurs, and other enemies … Radioactive waste has the capacity to outlast human civilization as we know it … In light of the grave risks associated with the proposed facility … and the importance of the Permian Basin to the country’s energy security and economy, I respectfully and emphatically request that the NRC deny ISP’s license application.” Governor of Texas Greg Abbott, Letter to US NRC, 11/30/2020.

$35 Million a Year for NYS High-Level Waste Storage: The current costs are $35 million a year to store 5,000 metric tons of high-level radioactive waste at New York State’s seven reactors.

Half of Uranium-235 Radioactivity Decays in 700 Million Years: A key component of a reactor’s waste is Uranium-235 which has a half-life of 700 million years (only half of the radiation decays). Once a reactor shuts down, there is no revenue to pay for the storage costs. Inevitably those storage costs, for millions of years, will be borne by future ratepayers and taxpayers.

An Overview of Some Key Climate Legislation that Should be Included in the State Energy Plan

NY Heat Act (A4870 Simon / S4158 Krueger)

Mandates that the Public Service Commission (PSC) make its regulation of electric and gas service in our homes and businesses consistent with the CLCPA, including through modifying the present mandate to provide gas service to all customers upon request, known as the “obligation to serve,” and mandating regular greenhouse gas emissions reduction targets for each gas utility. Promotes affordability by limiting low- and moderate-income residential customers’ bills to 6% of their household income. (Note that the 100-foot rule was passed though the Governor has not yet signed)

Stop Climate Polluter Handout Act (A3675 Simon / S3606 Krueger)

Eliminates over $330 million in tax handouts to the fossil fuel industry, targeting the highest polluting fuels and their most unreasonable uses, including commercial airline fuel, low-grade “bunker” fuel and the operation of fracked gas infrastructure. Tax breaks that benefit the public such as home heating are not eliminated

Packaging Reduction Act (A1749 Glick / S1464 Harckham)

Requires companies to reduce their product packaging by 30% in 12 years, including petroleum-based plastics, and bans seventeen priority toxic chemicals in packaging materials.

Accelerate Solar for Affordable Power (ASAP) (A8758 Barrett / S6570 Harckham)

Increases the New York State distributed solar goal, streamlines regulations, and directs the public service commission to advance reforms to the utility interconnection process. ASAP will help New York achieve the renewable energy mandates in the 2019 Climate Act.

GAP Fund (A2101 Kelles / S3315 Gonzalez)

Establishes a green affordable pre-electrification (GAP) program to fund and provide technical assistance for homes and buildings in need of a wide range of currently unfunded retrofits that are necessary for healthy buildings and achievement of New York’s climate mandates.

Affordable Climate-Ready Homes Act (ACRHA) (bill awaiting introduction)

Mandates funding of thousands of projects for homeowners, nonprofits and landlords (with rent increase protections) to electrify homes and appliances to meet the requirements of the CLCPA. The program would prioritize projects in “disadvantaged communities” which benefit low- and moderate-income households at no cost to the building owner. The bill would supplement the funding already available from existing state programs like Empower + and take steps to make it easier for building owners to access multiple state electrification and pre-electrification programs.
Bucks for Boilers (A6489 Stirpe / S3476-Rivera)

Starting in 2030 for smaller buildings and 2035 for larger ones, provides necessary subsidies to households to repair and weatherize their homes and upgrade to higher efficiency and clean heat pumps, phasing out old gas-fueled boilers when the system needs replacement. Authorizes $50,000 per household and offers upfront full-coverage subsidies to low and moderate-income households.

Invest in Our New York (IONY)

A package of bills focused on tax fairness and raising revenue through taxes on the wealthiest New Yorkers and large corporations. Revenue would go to the general fund for priorities including housing, climate and education. This package is particularly important now that we expect to lose federal aid.

Intervention in Utility Rate Cases (A836 Solages / S2477 Parker)

Permits non-profits representing consumers to receive reimbursement for participation in formal proceedings before the Public Service Commission (PSC). Permits consumers and environmentalists to retain lawyers and experts, allowing them to have a more meaningful say in technical PSC proceedings that vitally affect state climate policies and our utility bills.