GELF Comments on NYPA, Public Power, Nuclear - Green Education and Legal Fund

Comments of the Green Education and Legal Fund to the|
New York Power Authority Renewable Energy Strategic Plan
September 11, 2025

Pursuant to the Build Public Renewables Act, NYPA must build at least 15 GW of public renewables (wind, solar, geothermal) by 2030 so New York can lead the ﬁght for our future.

As we face life-threatening heat waves, flash floods, skyrocketing energy bills, and an attack on climate action from the federal government, we need NYPA to lead the nation on building public renewables that will slash pollution, make energy more affordable, and protect our planet now.

We have the technology needed to build a clean renewable energy future, what we lack is the political will. We need a mobilization of all the state’s resources comparable to what FDR did after Pearl Harbor. The Secretary-General of the United Nations has pointed out that the slow action by governments on climate change has opened up the Gates of Hell. For much of the last 2 years, global warming has already breached the 1.5 °C cap set by COP in France.

Building 15 GW will protect our climate, create green union jobs, cut life-threatening pollution, and make New Yorkers’ energy bills more affordable.

NYPA must build at least 15 GW of renewables by 2030 to:

Ensure that we meet our climate goals (70% renewable by 2030)
Lower utility bills for New Yorkers who need relief the most
Create 25,000 green union jobs
Close super-polluting Peaker plants on the timeline required by law

NYPA needs to implement the authorization provided in prior state budgets to provide electricity to Community Choice Aggregation (CCAs) by building at least 5 GW of new renewables dedicated to supplying CCAs.

NYPA should take over ownership and control of the transmission grid through eminent domain to reduce barriers to renewable energy projects to connect to the grid and to lower costs for consumers

NYPA should not build new nuclear power plants as they are too expensive, take too long to build, are not carbon free, and produce significant amounts of radioactive waste that must be safely stored for tens of thousands of years. GELF is a member of the Alliance for a Nuclear Free New York.

Shortcomings of the Draft Plan

The 7 GW of proposed capacity in the strategic plan is still inadequate to meet CLCPA goals. According to NYPA’s own report, New York is currently on track for just 44% renewable electricity by 2030, vs. the 70% required by the CLCPA. NYPA must build at least 15 GW to get us back on track. NYPA, in their strategic report, also states that they expect “attrition,” meaning that even fewer projects than are being proposed will actually be built.
Not enough projects planned for the Hudson Valley and downstate New York: though this plan is an improvement, there still needs to be more downstate generation where electricity demand is greatest. Communities in these areas deserve to beneﬁt from reduced pollution, green jobs, and lower utility bills via the REACH program. And congested electricity transmission is a problem that siting close to demand can help solve.
There is no detailed plan for shutting down NYPA’s Peaker plants by 2030 as required by law. Gas-ﬁred Peaker plants are a public health disaster for host communities, which are already heavily burdened by other polluting infrastructure.
Less than 5% of proposed projects are to be sited on public land or institutions. Public institutions throughout New York would beneﬁt from decarbonization through NYPA renewables, thermal energy networks, and related retroﬁts.
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 presentation of NYPA’s ﬁnancial situation, the draft does not assess the impact of 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 NYPA’s 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 distributed energy should include geothermal energy systems, not just solar and storage.

NYPA Must Build More Renewable Energy

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
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 eligible.

Speed up the Shutdown of Peaker Plants

For too long, New York’s energy has come at the expense of the health of our communities and our planet. It’s time for a change. We need to shut down these smokestacks and replace them with clean public power that ﬁghts climate change, cleans our air, and puts money back in our pockets.
The gas-ﬁred Peaker plants are a clear symbol of the climate crisis and the ways New York’s polluting energy system hurts our communities. For decades, these Peaker plants have spewed toxic fossil fuels pollutants into our air, burning the planet, and sending asthma rates sky-high in communities like the South Bronx, Williamsburg, Sunset Park, LIC & more. In communities like the South Bronx, Peaker plants like this have degraded our air and helped drive up asthma rates as much as 8 times the national average.
The neighborhoods that suffer the pollution of Peaker plants don’t see the beneﬁts: wealthy areas and corporations get reliable energy, Black and brown communities get blackouts and dirty air.

No nuclear

Nuclear power is far too expensive, it will take far too long to develop to prevent climate chaos, and it has the enormous problem of dealing with the radioactive waste. It is not credible to say that nuclear is zero emissions, especially when the life cycle of the plant is analyzed as well as the mining and processing of the fuel.

According to the U.S. Energy Information Administration, the LCOE for advanced nuclear power was estimated at $110/MWh in 2023 and forecasted to remain the same up to 2050, while solar PV estimated to be $55/MWh in 2023 and expected to decline to $25/MWh in 2050. Onshore wind was $40/MWh in 2023 and expected to decline to $35/MWh in 2050 making renewables significantly cheaper in many cases. Similar trends were observed in the report for EU, China and India.

Similarly, 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. The most notable drop occurred in utility-scale solar PV, which saw a 12% decrease from 2022. Onshore wind projects also saw a reduction in LCOE, dropping by 3% year-on-year, while the LCOE for offshore wind projects decreased by 7% compared to the previous year. Meanwhile, the cost of battery storage projects experienced a significant decline, falling by 89% from 2010 to 2023.

In contrast, nuclear power continues to face cost overruns and long construction timelines. According to the 2023 World Nuclear Industry Status Report as of 2023, 58 nuclear reactors are under construction globally, with an average of 6 years having passed since construction began—slightly lower than the mid-2022 average of 6.8 years. Despite this, many reactors remain far from completion. In fact, all reactors being built in at least 10 of the 16 countries involved have faced significant delays, often lasting a year or more. Of the 24 reactors clearly documented as behind schedule, at least nine have seen additional delays, and one has reported delays for the first time in the past year. https://www.worldnuclearreport.org/Power-Play-The-Economics-Of-Nuclear-Vs-Renewables

In the Governor’s June 23, 2025, news release, she directed NYPA to build one new nuclear energy facility with a combined capacity of at least 1 GW of electricity. Then the Public Service Commission (PSC) proposed that up to $33 billion in ratepayer subsidies continue from 2029 to 2049 for the four existing aging reactors upstate, as estimated by the Nuclear Information & Resource Service (NIRS). This is in addition to the $7.6 billion ratepayer subsidy bailout under Governor Cuomo of the upstate nuclear plants that ratepayers are still paying for. Additionally, the seven reactors in the state are storing 5,000 metric tons of high-level radioactive waste on-site at a cost of $35 million a year. Uranium-235, a key component of this waste, has a half-life of 700 million years. There is no long-term plan on how this waste storage will be funded, outside of the ratepayers. NYPA should follow the CLCPA and communicate with Governor Hochul that nuclear power is a fiscally and environmentally irresponsible source of energy and should be phased out, not restarted.

The definition of renewable energy should never include nuclear power. Nuclear power facilities emit GHG during the milling and mining of poisonous uranium and facility construction and the long-lived storage of high-level nuclear waste.

Instead of spending billions of dollars on nuclear energy the state must invest in renewable energy and get it distributed. Renewable energy installations are taking over the market and are quick and relatively inexpensive to build. NYSERDA programs allow low-income ratepayers to receive much needed assistance on their utility bills. As we write this, federal money and credits are being clawed back as President Trump terminates Inflation Reduction Act tax credits and stops offshore wind projects in federal waters. New York State must fight back. We cannot afford attrition – resources must be deployed now.

As NYPA knows, NYSERDA conducted a 2024 Financial Assessment on Advanced Nuclear Technologies that found it would result in astronomical costs to ratepayers and huge risks to the state. While NYSERDA claims this assessment does not exist, the PSC in response to an FOI request acknowledged that it has a copy but claims that as an interagency communication it cannot release it.

NYSERDA recommended that the state should not invest or act on any new nuclear energy facility. The Governor’s obsession with nuclear energy is irresponsible. The state can have a clean, green climate-disaster fighting machine with renewable energy, battery storage and energy reduction through geothermal heat pumps. Instead of spending billions of dollars on nuclear energy we should be investing all our funding into renewable energy projects. NYPA should ramp up their pace of adding projects and beginning construction to take advantage of Federal solar and wind tax credits prior to their expiration and commit to developing alternative financing methods to bring more renewables online regardless of federal tax credits such as expanded bond financing.