Preliminary Comment on New York Department of Public Service “Staff’s Responsive Proposal for Preserving Zero-Emissions Attributes”
Prepared for the New York State IBEW Utility Labor Council, Rochester Building & Construction Trades Council, and Central and Northern New York Building & Construction Trades Council
Electricity price effects must be considered when evaluating Staff’s proposed ZEC program. We found previously that electricity costs for New York consumers would average $1.7 billion per year higher without the upstate nuclear plants. The electricity cost savings that come from preserving these nuclear plants exceed the cap on ZEC costs, which is $482 million per year for the first two years. Thus Staff’s proposed program to preserve the upstate nuclear plants would actually save consumers money on power costs. The ZEC cost cap is below the estimated electricity cost savings that comes from preserving the upstate nuclear plants, and actual ZEC costs are expected to be below the cap in future years.
In addition to the electricity cost savings for New York consumers, preserving the upstate nuclear plants would prevent the release of about 15 million tons of CO2 per year into the atmosphere.
