Hudson River Sloop Clearwater, Inc.
Comments and Recommendations on the Climate Action Council’s Draft Scoping Plan

To: Climate Action Council, State of New York scopingplan@nyserda.ny.gov

Summary: Several of the important recommendations contained in Clearwater’s full comments are summarized here. Click HERE for more information contained in the full set of comments.

  • Low-to-Moderate Income (LMI) and Black, Indigenous, and People of Color (BIPOC) communities must be prioritized in the outreach and implementation of renewable energy alternatives and their incentives, particularly on the banks of the Hudson River. Climate Justice [DSP 6]

  • As stated in the Climate Act, ensure that at least 35 – 40% of the benefits of clean energy investments are directed to priority disadvantaged communities, as envisioned. [DSP 3.2]

  • SEQRA must be expanded to specify how each action actively meets the goals of the Climate Act. [DSP 21]

  • Foster adaptive reuse of closed nuclear and fossil fuel sites such as Danskammer and Indian Point for renewable energy generation and/or storage [DSP 7.5, 13.1]

  • Reduce transportation emissions by providing funding for electric vehicles, including buses and trucks, and charging stations to accelerate the transition to fossil fuel-free transit. [DSP 11.1]

  • Building energy retrofits: superinsulation with careful air-sealing employing healthy building practices are a major source of energy savings and should be incentivized. [DSP 12]

  • Utilities’ lowering rebates on air-source heat pumps slows their implementation; geothermal rebates were maintained. Heat pump rebates should be restored. [DSP 12]

  • Stop subsidizing polluters: The Scoping Plan should end the longstanding practice of giving taxpayer subsidies to the fossil fuel and nuclear industry. Public money should not be going to industries that pollute our air and water and are primarily responsible for the climate crisis. The current DSP goal to eliminate “embedded subsidies for fossil fuels” by 2050 must be implemented even sooner. [DSP 12]

  • Consumer Benefit Charge (CBC) net-metering surcharge significantly hinders solar development in NY and should be repealed. [DSP 13]

  • Ensure renewable energy (RE) infrastructure with storage and energy efficiency retrofits precedes beneficial electrification to avoid burning more fossil fuel are not burned to meet the increased demand.[DSP 13, E2]

  • Require equitable sharing of the costs of much needed grid upgrades between developer and utility and NY State, including applying any federal funding available to do so. [DSP 13,.E9]

  • Nuclear is not clean energy or zero emission, and should not be included in the incentives provided. Funds channeled to nuclear power operators are funds which are not available for renewable energy infrastructure, storage, energy efficiency retrofits or other climate solutions, where they are needed. [DSP 13, E10]

  • Invest instead in our collective future by providing adequate state funding to invest in infrastructure for renewables, storage, grid upgrades and beneficial electrification. The Scoping Plan also should include a $15 billion infusion of state funds to implement the Climate Action Plan. [DSP 17.2]

  • Ensure responsible materials management and prioritize data collection for fugitive emissions in waste and treatment facilities. More research is required to effectively mitigate emissions from this sector. However, waste management can be tackled now through production restrictions and sustainable materials and recycling practices.[DSP 16.2]

  • Utilities should be prohibited from building new gas lines, which carry fracked “natural” gas. [DSP 18: Gas System Transition]