Response to RFI Supplying NYC with Renewable Power (#85616RF1001)
Green Education and Legal Fund, PCM NY, 350NYC
Ms. Susan Cohen, Assistant Commissioner
Department of Citywide Administrative Services, Energy Management
1 Centre St., 17th Floor South
NY NY 10007
September 10, 2015
Dear Ms. Cohen:
We are writing to strongly support the City of New York’s Request for Information (“RFI”) to supply 100% of the City’s government electricity needs with new renewable sources. Transitioning to 100% renewable generation would make the City a global leader in the fight against climate change, setting the City and State on a path toward a cleaner, more resilient and affordable energy future.
Going to clean renewable energy sources rather than the continued burning of fossil fuels, will also end the several thousand annual excess deaths in NYC due to the air pollution from such fuels, and dramatically reduce associated health care costs. It will reduce air related health problems such as asthma. We support a goal of NYC going to 100% renewable energy for all energy needs in the city by 2030.
We have signed on to a joint letter with Sierra Club and other groups concerning the RFI. (Portions of that letter are copied below and underlined). We write here to highlight a few points and to make some additional comments.
As one of the three large cities on the planet most vulnerable to rising sea levels, it is critical that New York be a national and international leader in transitioning to 100% clean energy as soon as possible. New York’s leadership in moving its own electricity needs to 100% renewables may also provide opportunities for the rest of the city’s electric supply to do the same. We hope that in the future the city will explore initiatives such as Community Choice Aggregation and community shared renewables that will aid residential, business and institutional customers in making a similar transition to 100% clean energy. We support efforts to energy retrofit all city buildings to net zero carbon emissions which will require new energy conservation and efficiency initiatives, on-site renewable sources for electricity, heating, and cooling, and the purchase of electricity from solar and/or wind farms from within and outside of NYC.
Increasing the City’s deployment of renewable energy will boost the local economy with new jobs and investment, reduce electricity prices for New Yorkers, and mitigate the adverse environmental and economic effects of climate change.
We urge New York to become the national leader in the development of offshore wind projects (“OSW”). “OSW is the only large scale renewable (LSR) technology at the scale and location necessary to achieve the City’s 100% renewable target and essential reductions in greenhouse gas emissions As the City noted in its LSR comments, “[OSW] presents one of the only opportunities to construct utility-scale renewable generation in the downstate region.”
We urge NYC to issue an RFP for an OSW project and to commit to a large Power Purchasing Agreement for OSW (e.g., in excess of 1,000 MW, larger if done in conjunction with NYS.)
A January 2015 Oceana report  found that New York has 11.6 gigawatts of offshore wind potential. That’s enough energy to power over 9 million households. They also found that 134 GW of off-shore wind off of the East Coast is possible through a gradual and modest development over the next 20 years.
A March 2015 report from NYSERDA and the University of Delaware, the New York Offshore Wind Cost Reduction Study,  concluded that OSW could become the most viable option for delivering large-scale renewable electricity generation to New York City and Long Island. The report outlined the key steps necessary for reducing the costs of offshore wind power in New York State. The costs could be reduced by as much as 50% during this time period via the combined actions of: specific actions taken by New York State and/or other states, ongoing technological improvements, and continuing industry advances; according to the new study/report. One of the key conclusions is that support of offshore wind energy development at scale, rather than on a project-by-project basis, would have the greatest effect on costs amongst the economical options.
Off shore wind will reduce electricity prices for New Yorkers because it is the only LSR resource at the scale necessary to produce electricity to the New York City and Long Island suburbs during times of peak demand. By producing power when demand is highest, OSW will also defer the need for peaking fossil-fuel plants, which disproportionately harm the surrounding communities with dirty air and water.
Off Shore Wind will Create Jobs and Economic Benefits
We urge the city to make a large, long-term commitment to purchase off-shore wind.
Investments in renewable energy are the path to full employment. The Jacobson report by Cornell and Stanford professors showing that NYS could transition to 100% renewable energy by 2030 estimated that 4.5 million jobs would be created during the transition (an estimated 270,000 so-called 40 years jobs in just construction and operation). The Oceana report estimated that NYS could create about 16,000 lifelong jobs from off-shore wind.
Off shore wind is especially ripe as an economic development tool. There is presently no off-shore wind farm in the US, though a small project recently broke ground in Block Island. The first large scale project (e.g., at least 700 MW) will provide the critical mass not only to reduce overall construction costs but lead to the infrastructure investment to support that project (e.g., ports, turbine factories, shipping, platform, supplies, etc.). Whichever community initiates the first large scale off-shore wind farm will be ideally positioned to build out other off-shore wind projects along the East Coast.
Studies commissioned by NYPA have shown that a single OSW project could generate total economic activity of $1 billion in sales, 8,700 job-years and $610 million in wages for New York State. A 2014 study by Stony Brook University looking at OSW potential off Long Island found that a “single 250 MW offshore wind project is estimated to result in 2,864 construction and 13 operations phase jobs on Long Island, as well as approximately $645 million in Long Island economic output during construction and operations. If Long Island were to capture 2,500 MW of the potential offshore wind development, the JEDI model projects that Long Island would benefit from 58,457 construction and operations phase jobs, as well as approximately $12.9 billion in local economic output.”
The City Needs to Urge the Governor to Reject the Pt. Ambrose LNG Facility
LIPA, NYPA and Con Ed submitted a proposal to federal regulators in September, 2011 for off shore wind. They wanted to construct 200 3.6-megawatt wind turbines 13 miles off the Rockaway Peninsula. Described as what could be the largest offshore wind farm in the United States, the Long Island – New York City Offshore Wind Project is working its way through a multi-year federal review process. The wind farm could yield as much as 700 MW of energy—enough electricity to power an estimated 245,000 homes.
This project however is in the same general area of the Port Ambrose Liquefied Natural Gas facility. The Bureau of Ocean Energy Management controls the development of such projects and once the Pt. Ambrose project was submitted, all other projects (off shore wind) were put on hold until the Pt. Ambrose project is decided. So defeating Pt. Ambrose (e.g., having Governor Cuomo veto it) would allow off shore wind to go forward.
New York City Should Work with the State to Establish Goals of 5,000 MW of off-shore wind by 2025 and 10,000 MW by 2030.
New York State is presently developing its proposals for Large Scale Renewables. So far NYS has been reluctant to make a major commitment to off-shore wind. In December, LIPA unexpectedly rejected a proposal for a major off-shore wind farm that it had solicited.
The leadership of NYC will be critical in convincing the state to agree to a long term PPA for off-shore wind.
The City endorsed an OSW tier in the emerging LSR program, stating that “NYSERDA should advance programs that support offshore wind under both the Clean Energy Fund and a dedicated LSR procurement tier so that necessary market development activities are advanced in a comprehensive and holistic manner.”
A City/State OSW tier with a 10-year, 5000 MW goal and a 15-year goal of 10,000 MW would contribute to the achievement of the City’s and State’s goals of a major reduction of greenhouse gas emissions. It would help the city survive climate change. We recognize that such goals are ambitious and a number of operational, supply and labor barriers would need to be overcome. It would require a full-scale commitment by both the city and state. Studies have shown that the problem in achieving such goals is not the technology but rather the political and economic will. Unfortunately, it is not clear how much of the city will survive the rising tides from climate change if such goals are not achieved.
We applaud Mayor de Blasio for his leadership in committing to 100% renewable generation for the City’s electricity needs. The development of off-shore wind is critical to meet the Mayor’s climate change related goals
Mark A. Dunlea
315 Greene Ave. #2B
Brooklyn NY 11238
 City of New York Comments, 22.
 Economic Impact Assessment: Long Island – New York City Offshore Wind Project. Prepared for NYPA by AWS Truepower and Camion Associates. Contract No. 4500191884. at 10 (November 1, 2010.)
 New York Energy and Policy Institute- Stony Brook University, “Offshore Wind Energy and Potential Economic Impacts in Long Island”, 12-13 (Nov. 24, 2014).
 LIPA decided against making a Power Purchasing Agreement for electricity from this wind farm. Another utility company could enter into a PPA with the developers of the wind farm.
 City of New York Comments, 23.