Harlem’s WE ACT Recommends Changes To NYS Solar Roadmap To Comply With CLCPA

WE ACT for Environmental Justice submitted a letter to the New York State Public Service Commission (PSC) yesterday.

The letter was submitted with detailed recommendations to ensure that the New York State Energy Research and Development Authority’s (NYSERDA) 10 GW Distributed Solar Roadmap is compliant with the Climate Leadership & Community Protection Act (CLCPA).

NYSERDA released its Roadmap in December 2021 as a plan to meet New York State Governor Kathy Hochul’s goal of developing 10 gigawatts of local solar by 2030.

WE ACT supports many aspects of NYSERDA’s Solar Roadmap, such as a $1.474 billion budget to extend NY-Sun, the state’s solar incentive program.

However, much of the plan falls far short of meeting the statutory requirements set forth in the CLCPA to deliver 35-40 percent of the overall benefits of clean energy investments to low-income communities and communities of color, offering only a 10-percent discount on the utility bills of customers in these communities.

“Lower utility bills are certainly welcome by the residents of these communities, who spend a greater percentage of their household income on energy bills, and often live in energy inefficient homes that require greater energy use,” said Jasmine Graham, Energy Justice Policy Manager at WE ACT for Environmental Justice. “But that alone does not do them justice, nor does it fulfill the statutory requirements set forth in the CLCPA to provide 35-40 percent of the overall benefits of clean energy investments to disadvantaged communities. We need a more equitable roadmap for this transition.”

As a leading voice on environmental justice in the state and nationally, WE ACT urges NYSERDA and the PSC to comprehensively review our equity concerns and recommendations and then revise the proposed roadmap to ensure that low-income communities and communities of color across the state are not unjustly left behind in our clean energy transition.

WE ACT highlighted 10 overarching recommendations to increase diversity, equity, inclusion, and justice in the Roadmap and to bring NYSERDA’s plan in line with CLCPA mandates.

Among the recommendations outlined by WE ACT are: restructuring incentive blocks to increase equitable outcomes, increasing the funding for the Solar Energy Equity Framework and Inclusive Community Solar Adder, and bringing more attention to energy affordability and fossil fuel displacement in Con Edison’s downstate service territory.

To incentivize ownership, arguably the most beneficial of the benefits of clean energy investments, WE ACT recommends that low-income households and low-income community-owned projects be exempt from the Customer Benefit Contribution (CBC) charge; that NYSERDA develop a $100 million development fund to assist residents of these communities in owning and operating their own solar projects; a 400 MW carveout be set-up for community-owned solar projects in these communities; minority and women-owned business enterprises (M/WBE) participation in the solar energy economy be tracked, funded, and prioritized; and incentivizing the use of community benefit agreements to transfer ownership to communities, cooperatives, land trusts, or other socially just entities.

“These communities have borne the brunt of air pollution and the impacts of climate change resulting from fossil fuel power plants and other environmental hazards that have been forced upon their communities over the years,” added Graham. “Take the South Bronx, for example, which has been home to two ‘temporary’ peaker plants for the past 20 years, contributing to some of the highest rates of childhood asthma in the nation. These communities deserve to be made whole from the disproportionate burdens they have endured for generations. That is why we are calling for these revisions to NYSERDA’s Roadmap, including the creation of a $100 million development fund to assist low-income community members in disadvantaged communities in owning and operating their own solar projects.”

Other advocates weighed in with similar recommendations for the plan, including the Alliance for a Green Economy, the New York Energy Democracy Alliance, and Vote Solar.

Now that the public comment phase is closed, the PSC will either recommend changes to NYSERDA’s plan or simply adopt it as is, despite the fact that it is not compliant with the CLCPA.

WE ACT for Environmental Justice is a Northern Manhattan membership-based organization whose mission is to build healthy communities by ensuring that people of color and/or low-income residents participate meaningfully in the creation of sound and fair environmental health and protection policies and practices.

WE ACT has offices in New York City and Washington, D.C. Visit us at weact.org and follow us on Facebook, Twitter, and Instagram.