Comments from Donna L. DeCarolis, President of National Fuel Gas Distribution Corporation & Climate Action Council member, on her vote

The work of the Climate Action Council (CAC) since its inception has been extensive, involving not only the CAC members and New York State Agency staff but also significant contributions from advisory panels and working groups. Despite the efforts of many, however, overall public awareness of this proposed energy transformation — along with its potential impacts – remains largely unknown by most New Yorkers. And a one-size-fits all approach cannot work in New York with climate and economic conditions that vary so widely throughout the state. I support many of the recommendations in the Scoping Plan, including the adoption of accelerated energy efficiency measures, efforts to ensure power system reliability, research and development initiatives to pursue emissions reduction solutions, the evaluation of the use of the natural gas distribution system to deliver renewable natural gas (RNG) and hydrogen, and the increased emphasis on the development of thermal energy networks. Even with these positive inclusions, however, the Scoping Plan does not go far enough with many of these initiatives to ensure a responsible energy transformation for New York. In its current form, the Plan fails to adequately address the serious reliability and affordability concerns shared by New York citizens during this process. Throughout my CAC tenure, I have continued to strongly voice the need to consider the Plan’s consumer impacts and to offer perspectives and alternatives that will allow us to meet the requirements of the Climate Leadership & Community Protection Act (Climate Act) while preserving reliability, energy system resiliency and an affordable transition for consumers.  The final Scoping Plan falls short, with significant concerns remaining that may jeopardize reliable, resilient and affordable energy delivery for the state’s residents and businesses. I believe the Scoping Plan:

• Relies too heavily on a single energy source that is prone to weather-related disruption:
  • Given the significant reliability and resiliency concerns raised by the NYISO and others, the state is placing undue risk on consumers by relying so heavily on a single form of energy and energy delivery system, especially one that is prone to disruption by extreme weather events.
  • Mandating dates forcing the electrification of heat beginning in 2025 for new residential construction and in 2030 for existing residential buildings, without the assurance of system resiliency and delivery certainty is unacceptable.
• Fails to ensure grid reliability for consumers:
  • The Plan’s undue reliance on electrification to achieve the state’s emissions reduction goals may push the state and consumers squarely into the sort of reliability shortfall the NYISO has repeatedly warned about, “thinning reliability margins over the next decade present increased challenges with even the slightest deviation from expected conditions.”
• Does not include a full assessment of impacts on consumer energy affordability:
  • A thorough quantitative analysis of all costs associated with the emissions reduction initiatives identified in the Scoping Plan should be performed and shared with the public.
  • This long-overdue analysis is critical to an understanding of cost impacts on New York’s residents and businesses and to the identification of initiatives that will ensure energy affordability.
  • The current Plan is not responsive to the primary concern about the cost to average New York residents and
• Overlooks the use of the natural gas delivery system for decarbonizaton:
  • Rather than forgo opportunities to fully leverage the extensive, existing natural gas system, more emphasis should be placed on utilizing a dual or hybrid heating system pathway, especially in Upstate NY where the climate is significantly colder.
  • Consistent with their treatment in other areas, the value of alternative fuels as decarbonization tools should be recognized and incentivized, especially RNG which can offer near-term emissions reduction benefits.
  • Leveraging existing energy networks with a coordinated gas and electric decarbonization strategy would better manage the affordability and feasibility risks of the state’s plan.

As most New Yorkers know, weather patterns across New York State are vastly different and these policies will likely be even more burdensome for colder climate regions. Western New York is 45% colder than downstate and 94% of all energy used in this part of the state on the coldest winter day is natural gas.  Nearly 90% of the western New York region heats with natural gas. Building an electric network capable of electrifying all heating load is not practical or cost-effective.

These same concerns were raised in the thousands of comments received on the draft Scoping Plan and have not been adequately addressed in the final document. As a result of these shortfalls, and because I believe there is a more responsible emissions reduction path that the Scoping Plan fails to fully consider and include, I am unable to vote in favor of approving and adopting the final Scoping Plan. Donna’s comprehensive remarks, that have been filed with the CAC, are available within the attached document. Read Donna’s Remarks Here