The Real Estate Board of New York to The Energy Planning Board re: Draft Scope of the New York State Energy Plan

REBNY Formatted Comments - NYS Energy Plan

The Real Estate Board of New York (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. New York State's forthcoming energy plan, guided by the New York State Energy Research and Development Authority (NYSERDA) and the State Energy Planning Board, will build on the foundational goals of the 2019 Climate Leadership and Community Protection Act (CLCPA) Scoping Plan. The Draft Scope intends to elicit feedback about the focus and direction of the State Energy Plan.

This is a pivotal moment for our state's energy future and REBNY appreciates the opportunity to provide input as New York continues its journey toward a more resilient, equitable, and sustainable energy system. We must ensure that as we transform our energy landscape, we also foster economic growth, create opportunities for a skilled new workforce, and provide essential support to major industries impacted by this transition.

This 2025-2040 energy plan is particularly important since the state is currently falling short of key milestones in the electric sector at a time when the demands on that sector are only increasing. With the electrification of major sectors, including buildings and transportation, set to drastically increase energy demand in the coming years, our electricity system faces unprecedented pressure.

Creating a Balanced State Energy Plan that Ensures Appropriate Supply of Baseload Power

The Energy Plan needs to carefully balance the State's ambitious electric-sector targets with a realistic assessment of how they can cost-effectively be reached. On the one hand, we are just six years away from the 2030 target of requiring that 70% of our electricity be generated from renewable sources, yet only about 30% of New York's electricity(and 10% of New York City's electricity) is currently derived from renewables. This highlights the pressing need for accelerated action if we are to stay on course. At the same time, the Independent System Operator has reported that by the summer of 2025, we may face a gap between energy demand and available power, particularly as fossil fuel plants capable of providing firm generation retire faster than variable renewable energy comes online.

For this reason, the Energy Plan must be focused on finding solutions that will protect the short-term reliability of the electric system, transition the system to carbon free sources, and ensure that the system has an appropriate supply of baseload power. Significant attention should be paid to the challenge of matching future electricity needs with the intermittent nature of renewably powered system and explore the role that firm sources of generation, including nuclear and hydropower, can play in a reliable carbon free system. In addition, given the diversity in power needs across the state, the Energy Plan must consider how the needs of each region of the state can best be met, including in the downstate area, which has both the highest electric load in the state and the fewest locations to site new generation.

Identifying Cost-Effective Solutions The Energy Plan must proactively address these challenges by identifying cost-effective solutions. Rising offshore wind energy costs in New York, driven by higher material, labor, and transportation expenses, along with persistent supply chain disruptions, have led newly rebid contracts to exceed all prior cost expectations. Under the current model, these escalating costs are largely borne by ratepayers. To ensure fiscal responsibility and meet climate goals, the State should prioritize exploring carbon-free alternatives such as nuclear energy, with its stable cost profile, and energy storage, which mitigates intermittency challenges. Illinois, a leader in nuclear energy, has successfully integrated these technologies into its energy plan to diversify its grid and reduce financial burdens on consumers. New York should take similar action to strengthen its energy future.

Providing Direct and Regular Reporting about Data Trends

The Draft Scope intends to provide historical, current, and future data trends in electricity load, and REBNY supports this effort and hopes that electric grid data is communicated to stakeholders often and in a clear manner. REBNY also encourages the state to assess grid interconnection and where there are opportunities for transmission and distribution upgrades.

Exploring Benefits of Energy Storage and Diversifying New York's Energy Mix

REBNY encourages the plan to also focus on the role that energy storage can play in supporting grid reliability and managing extreme weather events or other unforeseen disasters. The Department of Public Service projects that New York will need 12 GW of storage by 2040 to support a decarbonized and reliable electric system and recently adopted an order to pursue 6 GW by 2030. The plan should identify a path to meeting the 2030 and 2040 goals.

While electrification will be a major strategy for building to eliminate onsite fossil fuel generation, it is not the only approach. Other opportunities include the use of thermal networks and other district systems such as Con Edison's District Steam system. The Energy Plan should consider the role that these systems can play in the state's energy mix.

Investing in Decarbonization

Finally, as the state develops a forward-looking energy plan, REBNY encourages NYSERDA to continue to provide support for residential and commercial buildings. The building sector, responsible for a large share of statewide emissions, faces substantial costs to decarbonize. To accelerate the transformation of the building sector, the state should continue to invest in proven initiatives like the Empire Building Challenge. Buildings urgently need robust financial and technical assistance through these types of programs to ensure that upgrades are achievable and economically viable.

REBNY looks forward to collaborating with the State Energy Planning Board, NYSERDA, and other key stakeholders to help shape an energy future that meets our shared goals of reliability, equity, and sustainability.

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