RESPONSE OF TWENTY-FIVE ORGANIZATIONS TO THE PETITION OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC., NEW YORK STATE BUILDING AND CONSTRUCTION TRADES COUNCIL AND NEW YORK STATE AFL-CIO FOR THE ESTABLISHMENT OF A SO-CALLED “ZERO” EMISSIONS ENERGY SYSTEMS PROGRAM UNDER THE CLEAN ENERGY STANDARD

A coalition of twenty-five environmental and justice organizations argues that the IPPNY petition would improperly subsidize fossil fuel-based technologies that are not truly zero-emissions. The commenters contend that the proposed definition of "zero emissions" contradicts the Climate Leadership and Community Protection Act (CLCPA), threatens disadvantaged communities with continued pollution, and ignores the recommendations of the Power Generation Advisory Panel. They urge the Commission to focus instead on energy storage and the phase-down of fossil fuel generation.

• The proposed definition of "zero emissions energy systems" as technologies that "do not lead to a net increase in greenhouse gas emissions" is incompatible with the CLCPA because it ignores non-GHG hazardous air pollutants and would allow fossil fuel-fired resources to qualify if they displace higher-emitting units.
• Hydrogen combustion is not a zero-emissions technology because it produces nitrogen oxide (NOx) emissions, which contribute to ground-level ozone and fine particulate matter, disproportionately impacting disadvantaged communities.
• Pure hydrogen combustion turbines are not commercially available today, and existing gas pipelines cannot be safely transitioned to deliver pure hydrogen by 2030 due to material embrittlement and safety risks.
• Renewable Natural Gas (RNG) is not a zero-emissions fuel as it is chemically methane and emits the same CO2 and conventional air pollutants (NOx, CO, VOCs) when burned as other methane gas.
• Current RNG production levels are insufficient to support a new Clean Energy Standard tier; a single 437 MW combustion turbine would require more than half of the total US RNG production if operated at a 100 percent capacity factor.
• Carbon Capture and Storage (CCS) is not a zero-emissions technology because it does not eliminate all direct GHG emissions, does nothing for upstream emissions, and does not target conventional pollutants like NOx.
• The IPPNY petition would likely exacerbate environmental injustices by incentivizing the construction of non-zero-emitting resources in disadvantaged communities that already host most of New York's power generation infrastructure.
• The petition conflicts with the Power Generation Advisory Panel's recommendations, which state that further research is needed on the feasibility and health impacts of advanced fuels before infrastructure investment.
• The Commission should prioritize the Power Generation Advisory Panel's recommendations to increase funding for energy storage and establish a planning process to phase down reliance on fossil fuel generation.

APA

Earthjustice (n.d.). RESPONSE OF TWENTY-FIVE ORGANIZATIONS TO THE PETITION OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC., NEW YORK STATE BUILDING AND CONSTRUCTION TRADES COUNCIL AND NEW YORK STATE AFL-CIO FOR THE ESTABLISHMENT OF A SO-CALLED “ZERO” EMISSIONS ENERGY SYSTEMS PROGRAM UNDER THE CLEAN ENERGY STANDARD. https://earthjustice.org/wp-content/uploads/2021_11_response_of_25_groups_to_ippny_petition.pdf

Chicago

Earthjustice. RESPONSE OF TWENTY-FIVE ORGANIZATIONS TO THE PETITION OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC., NEW YORK STATE BUILDING AND CONSTRUCTION TRADES COUNCIL AND NEW YORK STATE AFL-CIO FOR THE ESTABLISHMENT OF A SO-CALLED “ZERO” EMISSIONS ENERGY SYSTEMS PROGRAM UNDER THE CLEAN ENERGY STANDARD. n.d. https://earthjustice.org/wp-content/uploads/2021_11_response_of_25_groups_to_ippny_petition.pdf.

Wikipedia

{{cite report |author=Earthjustice |title=RESPONSE OF TWENTY-FIVE ORGANIZATIONS TO THE PETITION OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC., NEW YORK STATE BUILDING AND CONSTRUCTION TRADES COUNCIL AND NEW YORK STATE AFL-CIO FOR THE ESTABLISHMENT OF A SO-CALLED “ZERO” EMISSIONS ENERGY SYSTEMS PROGRAM UNDER THE CLEAN ENERGY STANDARD |url=https://earthjustice.org/wp-content/uploads/2021_11_response_of_25_groups_to_ippny_petition.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{earthjusticendresponse, author = {{Earthjustice}}, title = {{RESPONSE OF TWENTY-FIVE ORGANIZATIONS TO THE PETITION OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC., NEW YORK STATE BUILDING AND CONSTRUCTION TRADES COUNCIL AND NEW YORK STATE AFL-CIO FOR THE ESTABLISHMENT OF A SO-CALLED “ZERO” EMISSIONS ENERGY SYSTEMS PROGRAM UNDER THE CLEAN ENERGY STANDARD}}, institution = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/2021_11_response_of_25_groups_to_ippny_petition.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }