“While NYCI will find a way to cost optimize between sectors, so it’ll avoid a high cost reduction in one sector in favor of a low cost reduction in another, the command and control scenario will not do this,” Gutman-Britten said. NYSERDA plans to model a “command and control” scenario that would require each sector to reduce their emissions a set amount rather than allow trading. The group also supports sector-specific declining caps on emissions. That would effectively eliminate the market mechanism cap-and-trade programs are intended to create to incentivize emissions reductions, and be closer to a straight fee on emissions. NY Renews continues to push for “cap-and-no-trade” with facility specific limits on pollution and a ban on trading the allowances polluters will purchase. As a baseline, the NYSERDA team is updating its emissions analysis from the state’s climate plan to incorporate recently enacted state and federal policies including the Inflation Reduction Act and the state’s new zero-emissions building code requirement. It’s capable of testing a variety of designs around price controls, free allowances for energy intensive industries, various investment plans for the revenue raised. The modeled outcomes will depend on policy decisions that are yet to be made about the program by state staff. “These kinds of inputs are going to help us how successfully the policy design choices we’re making deliver on the governor’s five priorities, hold faithful to the climate act’s requirements, as well as the guidance set forth to us by the scoping plan,” he said. Modeling will provide information about health and air quality impacts, job impacts, benefits of investments and - importantly - cost impacts for different types of households, NYSERDA’s Vlad Gutman-Britten said during the June 20 webinar. They’ve retained McKinsey and Company’s Vivid Economics team to assist. Draft regulations are expected to be formally issued by the end of the year, missing the climate law’s statutory deadline.ĭEC and NYSERDA also provided some insight on how they’ll analyze the costs and impacts of the proposed program as it moves forward. The agencies plan another round of public input after developing draft regulations but before formal issuance for official public comment on those regulations. That’s a key issue as upstream emissions are a significant driver of the higher costs the Hochul administration warned of under New York’s accounting method versus that used in most other states. Some of the questions included asking how emissions factors for upstream emissions, or out-of-state emissions from the production and transportation of fuels that get burned in New York, should be calculated under the program. The Department of Environmental Conservation and NYSERDA wrapped up a series of webinars posing more than 200 different questions for industry, environmental advocates and anyone else who has the time last month. NY Renews, the broad coalition which spearheaded the push for what became the state’s landmark climate law, has now dubbed the program - which Hochul officials have started shortening from New York “cap and invest” to “NYCI” (pronounced, that’s right, “Nicky”) - “cap-trade-and-invest.” (The term has been used before, including by environmental justice groups to describe the ill-fated framework for a multi-state cap-and-trade program for transportation emissions.) Kathy Hochul’s administration is still exploring how to implement the East Coast’s first economy-wide cap-and-trade program for greenhouse gas emissions, with an eye to moderating costs to consumers while satisfying major concerns from environmental justice advocates about localized pollution impacts of the proposal.
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