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18 October 2024

New York State Solicits Comments On The Proposed Scope Of The 2025 State Energy Plan

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In September 2024, the New York State Energy Planning Board released a Draft Scope of the New York State Energy Plan (the "Draft Scope") for public comment.
United States New York Energy and Natural Resources

In September 2024, the New York State Energy Planning Board released a Draft Scope of the New York State Energy Plan (the "Draft Scope") for public comment.

The State Energy Plan, originally published in 2015, is guided by the provisions of Article 6 of the New York State Energy law and by objectives including energy systems reliability, minimizing overall system costs, supporting economic development, and minimizing public health and environmental impacts, including those related to climate change. Notably, Article 6 of the Energy Law grants the State Energy Planning Board the power to direct action by State agencies and to issue rules and regulations, and requires that "[any] energy-related action or decision of a state agency, board, commission or authority shall be reasonably consistent with the forecasts and the policies and long-range energy planning objectives and strategies contained in the [State Energy Plan]," unless a determination is made by that entity that such consistency is no longer reasonable.

The State Energy Plan was last updated in 2020 to reflect the objectives of the Climate Leadership and Community Protection Act of 2019 ("CLCPA"). The update process now underway will refresh the State Energy Plan for the first time in five years—a period during which the industry landscape has markedly changed, with the State lagging on its decarbonization goals and load-serving entities projecting increasing demand growth.

The Draft Scope is intended "to elicit feedback about the focus and direction" of the State Energy Plan. Notable topic areas suggested for the State Energy Plan include:

  • Resiliency and adaptation. Exploring measures to increase climate change resiliency and adaptation.
  • Clean energy jobs. Assessing progress toward establishing a clean energy economy and a just energy transition.
  • Renewable energy and energy storage capacity. Identifying policies and funding mechanisms to stimulate energy research and the development of clean energy industries and facilities, including renewable generation and energy storage. Evaluating progress toward renewable energy targets and zero emission goals and assessing paths forward to drive progress.
  • System reliability. Examining possible generation portfolios, the state of transmission and distribution infrastructure and needed upgrades and investments.
  • Nuclear energy. Assessing the contribution of the existing nuclear fleet, examining the implications of decommissioning, and exploring the potential role of advanced nuclear technologies in the power sector, including small-scale and modular units, as well as in producing clean hydrogen.
  • Natural gas and petroleum fuels. Studying the current contributions of fossil fuels to State energy systems and analyzing necessary improvements to the State's petroleum and delivered fuels systems.
  • Alternative fuels. Assessing emerging trends in alternative fuels and developing guidelines to prioritize utilization of such fuels.
  • Buildings and industry. Discussing opportunities and challenges for energy efficiency, load management, and end-use electrification across building sectors.
  • Transportation. Assess the impact of increased electrification of transport on system demand and usage; explore opportunities and challenges in facilitating electric vehicle adoption.

Prior State Energy Plans have formed the basis for significant policymaking initiatives; indeed, New York's original Clean Energy Standard order of 2016 was put in place in part to meet the SEP's requirement at the time of meeting a 50% renewable energy consumption goal. With the State behind on its renewable energy and climate protection goals, all eyes on costs, and with the ravages of climate change worsening by the day, the baselines set in this State Energy Plan—which will be a reference for the state regulatory and contracting actions for years to come—will likely be significantly consequential.

Public comments on the Draft Scope are due by November 25, 2024.

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