Testimony of the Green Education and Legal Fund
on the New York Power Authority Renewables Strategic Plan
November 18, 2024
Albany NY
I am Mark Dunlea, chair of the Green Education and Legal Fund, a nonprofit organization promoting ecology, grassroots democracy, social and economic justice, and non-violence. I am also the convenor of PAUSE (People of Albany United for Safe Energy), the 350.org affiliate in the Capital District.
With life on the planet facing an existential crisis due to climate change, we urge the New York Power Authority (NYPA) to dramatically increase and speed up its plans to build additional renewable energy systems in New York that are publicly owned and democratically controlled. Not only is extreme weather accelerating, but for the last year global temperature increases have exceeded the target of 1.5-degree C.
New York State is falling far behind the inadequate climate goals mandated by the Climate Leadership and Community Protection Act of 2019. To help solve this problem, New Yorkers passed the Build Public Renewables Act, which directs NYPA to build enough public renewables to ensure that we meet the CLCPA targets of 70% renewable electricity by 2030 and 100% by 2040. NYPA’s draft strategic plan for renewables is unacceptable as it proposes to build only 3.5 GW – nowhere near the capacity needed to meet CLCPA goals. Moreover, by NYPA’s own admission, likely, the majority of these projects will never get built.
To meet CLCPA goals, NYPA must lead the way and build at least 15 GW of renewable energy by 2030.
The Renewables Strategic Plan is an abrogation of NYPA’s responsibility to ensure that the state reaches 100% renewables by 2040, and their duty to New Yorkers to build a better future for future generations. In 2019, just 4% of New York’s energy came from wind and solar power. That percentage has failed to move appreciably in the five years since. In the past decade, 70% of New York’s privately-owned renewable projects have been abandoned or canceled, including 4 gigawatts worth of offshore wind just this past April.
The 3.5 gigawatts proposal is undermined by a number of factors:
- NYPA expects that we could see an 80-85% attrition rate for early stage projects and a 30-60% rate for more developed projects.
- By the state’s own estimation, without new NYPA projects New York will only reach 44% renewable generation by 2030, falling short of the state’s legal mandate for 70% renewable generation by 2030. The draft plan does not go far enough to get New York to 70%.
New York’s transition to renewable energy is at a crossroads. Private power producers are facing a series of headwinds such as protracted interconnection processes, rising inflation, and increased interest rates. These factors diminish the profitability of their projects, and result in a poor track record for delivering on promised energy projects at projected costs. We also have a president elect who is a climate denier and wishes to rescind federal efforts to promote renewable energy
Recent cancellations of projects, and expensive rebids, have shown cracks at the heart of the State’s approach to utilizing private developers to guide renewable energy development. Rising raw material prices, renewable energy and electrification component supply chain constraints, and high borrowing costs have made projects appear too risky, and therefore too financially unsustainable to undertake, to private investors primarily concerned about profits not the future of humanity.
NYPA has had over a year to plan for these contingencies and should have planned to build enough capacity to account for attrition. By only proposing 3.5 gigawatts, NYPA is setting the stage to fail to meet their own inadequate targets.
This projected failure has real consequences for everyday New Yorkers. Thanks to the Build Public Renewables Act, renewable projects built by NYPA are mandated to use union labor through prevailing wage and project labor agreements. That means an ambitious buildout of projects would create thousands of well-paid green jobs. The law also directs NYPA to shutter their super-polluting peaker plants by 2030, while also providing electric bill credits for low-income electric ratepayers based on revenue from renewable generation. All of these benefits will be diminished without a robust public renewable buildout.
Building at least 15 gigawatts of public renewable energy by 2030. Such a plan would create between 20,000 and 30,000 green union jobs, keep the retirement and conversion of NYPA’s highly polluting peaker plants on schedule for 2030, and ensure electricity stays affordable for New Yorkers.
Public sector entities like NYPA need to play a proactive role in renewable energy deployment, prioritizing emission reductions and benefits to people over profit for developers and investors. NYPA can also take advantage of its tax-exempt status, low-cost financing mechanisms, and access to Federal tax credits under the Inflation Reduction Act to lower project costs. NYPA needs to use its full toolkit to champion the transition to renewable energy by coordinating the construction of the electric grid and renewable energy, and partnering with state institutions to accelerate the transition. Historically, these are precisely the moments in which states can utilize their unique capacity to economically organize markets to facilitate the development of technology.
The United States is no stranger to this approach. During the Great Depression, NYPA and the Tennessee Valley Authority were established as public alternatives to for-profit utilities. Public power facilitated a massive buildout of public hydropower across the US. The Rural Electrification Administration led the rapid electrification of the United States, anchoring decades of social and economic development. In the 1950s, the Federal government deliberately placed pressure on market developers of nuclear energy by proposing to build their own.
With years of stagnation, and market actors yet to deliver on their promise to lead the transition to clean energy, the state can kickstart a competitive environment by developing its own renewable energy. To do so, we need an all-hands-on-deck approach at NYPA. We need to use its full breadth as a public agency to facilitate the development of renewable energy.
NYPA is well-placed to anchor New York’s energy transition. It is a steward of the state’s important hydropower baseload, has a rich history of relationships with its institutional public customers, and has successfully built transmission in the state, enabling it to help solve transmission and interconnection bottlenecks to renewable energy development. It is also the only institution in the state that can both build renewable energy generation and transmission, giving it a unique place in the anticipatory planning of the New York Independent System Operator and Public Service Commission.
Through its Economic Development funds, NYPA has the opportunity to coordinate renewable energy supply chains in the state, bringing a wide variety of jobs and economic activity to the state. In replacing its downstate peaker plants NYPA can show how fossil fuel plants can be decommissioned to meet environmental justice concerns without jeopardizing grid reliability. With its public mandate, NYPA can lead a transition process that builds democratic consent on renewables planning and peaker plant decommissioning.
Beyond the total capacity to be built, the draft strategic plan falls short in a number of crucial areas:
- There are very few projects planned for the Hudson Valley and downstate New York, where electricity demand is greatest. Communities in these areas deserve to benefit from reduced pollution, green jobs, and reduced utility bills via the REACH program. These are often disadvantaged communities that are required by law to receive the benefits of NY’s Climate Act.
- There are NO projects planned for addressing the renewable energy needs of CUNY or SUNY campuses or public schools. Millions of teachers, students, and staff will be working and learning in dirty and unhealthy conditions.
- There is no detailed plan for shutting down NYPA’s peaker plants by 2030 as required by law. Peaker plants are a public health disaster for host communities, which are already heavily burdened by other polluting infrastructure.
- Less than 6% of proposed capacity is to be sited on public land or institutions. Public institutions throughout New York would benefit from decarbonization through NYPA renewables and related retrofits. CUNY, SUNY, and public schools are in great need of changing their energy systems and cleaning up their dirty buildings, which harm the health and safety of faculty, staff, students, and communities surrounding our schools and campuses.
- The draft plan does not incorporate feedback from important labor organizations through the conferral process. The AFL-CIO and Building Trades Council, who together represent 2.5 million workers in New York State, call for a buildout of 15 GW by 2030. IBEW, which represents workers directly impacted by our energy transition, calls for a large-scale buildout to guarantee job stability in the future for its members.
- In its assessment of NYPA’s financial situation, the draft does not consider the Authority’s economic development operations, which currently provide massive energy discounts to multinational corporations like Citibank, Amazon, and Lockheed Martin. Some of these discounts could be redirected to capitalize renewable energy projects or reduce New Yorkers’ skyrocketing energy bills.
- While the draft plan indicates an intention to partner with communities to develop distributed energy resources, there are no plans or timelines for these projects. Communities should not have to wait for a revised plan a year from now to benefit from distributed energy projects. NYPA should request local communities to propose sites for such local projects. The state’s 52 municipal companies should also be invited to participate in this effort.
- There is insufficient information about proposed projects. The draft plan does not indicate precisely where projects will be sited or what they are estimated to cost. Without this information it is not possible to provide complete feedback on the plan, including its financial assumptions, business strategy, and impact on communities hosting projects.
To address the above shortcomings in the draft strategic plan, we urge you to make the following revisions:
- Increase the total planned capacity to at least 15 GW
- Include a detailed plan for phaseout of NYPA’s peaker plants
- Fully decarbonize our public schools by siting utility scale and distributed generation on SUNY and CUNY campuses and building enough capacity to meet their energy demands
- 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.
We especially urge NYPA to play a leadership role in building offshore wind, which could supply up to 40% of the state’s electricity needs. NY and the US have lagged far behind Europe in developing this critical resource. Many of the best offshore wind locations on the planet are just off of Long Island and NYC, reducing the need for long transmission lines.
We have long urged that the transmission lines and systems in New York be publicly owned by an entity like NYPA in order to reduce costs to consumers, reduce coordination bottlenecks, and to speed up the process of bringing new renewable energy sources online.
We also urge NYPA to develop publicly owned geothermal systems, starting with the need to rapidly decarbonize the state capitol complex. Texas is the nation’s leader in geothermal development, and they are using much of it to generate electricity.
The proposed Renewable Capitol Act would require the state to transition the Capitol complex (including the Empire State Plaza) to zero greenhouse gas emissions in 3 years. NYPA and OGS recently proposed taking ten years to cut emissions just at the Empire State Plaza only by 50%. After a decade, it would then consider installing a geothermal system.
The Capitol Complex is one of the 15 largest state buildings emitting greenhouse gases that NYPA has been charged with decarbonizing. We urge NYPA to adopt a much faster timeline to zero emissions and to immediately begin developing geothermal for the project, starting at least at the Capitol. NYPA and OGS also need to commit to finally shutting down the Sheridan Avenue Steam Plant, which for more than a century has polluted a low-income community of color with pollution from burning coal, oil, garbage, and now gas.
The Sheridan Hollow Alliance for Renewable Energy (SHARE), which PAUSE helped organize back in 2017, has been very disappointed by the lack of NYPA’s progress over the last five years in developing a renewable electrical energy source for the Capitol as they were directed to do in the budget amendment that climate and community groups were able to win to stop NYPA’s proposal to build fracked gas turbines for the Capitol Complex. From the start, we suggested that NYPA look for a renewable energy source in the Capital District rather than from the Oneida project that NYPA pursued. We hope that building a local renewable electric source for the Plaza will now become a priority for NYPA. We have long suggested that the state examine meeting the electric needs of the Capitol complex by supporting the expansion of the Green Island hydro facility, for which permission was granted more than a decade ago to expand from 6 MW to 48 MW.