The Real Estate Board of New York to The Public Service Commission on Proposed Changes to the Climate Leadership and Community Protection Act

The Real Estate Board of New York to The Public Service Commission on Proposed Changes to the Climate Leadership and Community Protection Act

REBNY is the City's leading real estate trade association. Founded in 1896, REBNY represents commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. We are pleased to submit comments on the Coalition for Safe and Reliable Energy's request that the Commission hold a hearing to evaluate whether to temporarily suspend or modify the targets or provisions under the Renewable Energy Program established as part of the Climate Leadership and Community Protection Act (CLCPA).

REBNY strongly supports the renewable energy goals of the CLCPA. Our members include many of the nation's leading sustainable developers, operators, and managers who are committed to reducing greenhouse gas emissions, using clean power, and eliminating New York State's reliance on fossil fuels.

Our members are acutely aware of the impact of global climate change on New York's real estate market. We were on the front lines of Hurricane Sandy's devastating effect on our city's coastal communities, we have invested billions of dollars making New York's building stock sustainable and resilient, and we are primarily responsible for the implementation of New York City's ambitious climate change and energy policies, including Local Law 97.

The unfortunate reality is New York State will not meet the CLCPA's 2030 emission goals. Renewable generation has not materialized at the scope or speed as anticipated. In the interim, New York City is relying on an aging fleet of power plants that burn fossil fuels that is straining the reliability of the New York City grid and producing more greenhouse gas emissions. While federal policy changes and global economic forces have slowed the transition to renewable energy, the closure of Indian Point eliminated 25% of New York City's dispatchable and clean electricity.

Furthermore, energy prices are rising, and building owners, tenants, and consumers are facing significant and unaffordable increases in their electrical bills. For example, since 2019, electricity delivery rates have increased 44% since and are projected to increase by nearly 100% by 2030.

There are also clear indications our grid is straining under the current regulatory framework and modification is necessary. The New York Independent System Operator ( NYISO) has consistently raised alarms about energy reliability in the very near term. In fact, last June's heat wave included multiple "close calls" where demand nearly outpaced supply, and New York's aging generation fleet could not provide the necessary reliability to keep the lights on. As a result, on June 24th, NYISO was forced to purchase, on an emergency basis and at great expense, electrical capacity from a coal-burning power plant in Ohio. This winter's cold snap forced our members to institute a record number of Demand Response events as renewable energy production and temperatures simultaneously plummeted and natural gas supplies dwindled.

Meeting the overall goals of decarbonizing New York's electrical grid and removing other global warming pollutants is still critical and achievable, but not in the timeframe that CLCPA envisioned. For these reasons, it is prudent for the Commission to hold a hearing requested by the Coalition for Safe and Reliable Energy. New York State's energy policy needs to reflect the absolute importance of reliability and affordability while continuing to call for decarbonizing the energy supply in a reasonable and achievable timeframe.

CONTACT:
Daniel Avery
Director of Policy
Real Estate Board of New York
[email protected]