Environmental Advocates of New York recently released a report, “RGGI at a Crossroads”, that details the allocation of funds raised by the Regional Greenhouse Gas Initiative (RGGI) in New York State. I have previously posted on New York State’s RGGI Operating Plan which is supposed to determine the best use of RGGI auction proceeds and thought it would be instructive to compare the two analyses.
This is another in a series of posts on RGGI (see my RGGI posts page). I have been involved in the RGGI program process since its inception. Before retirement I was actively analyzing air quality regulations that could affect electric generating company operations and was responsible for the emissions data used for compliance. As a result, I have a niche understanding of the information necessary to critique RGGI. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
The overview for RGGI at a Crossroads states:
For the past seven years, the Cuomo Administration has used funding made available to New York through the Regional Greenhouse Gas Initiative (RGGI) for some authentic climate mitigation purposes as well as some highly questionable ones. While programs like Green Jobs – Green New York, 76West, and the Drive Clean Rebate owe their success to RGGI funding; the Governor has also diverted RGGI funds to subsidize power rates for Long Islanders and plug budget holes. These diversions are bad policy precedents that squander the opportunity to better the environment. An upcoming revision to state regulations offers the Governor an opportunity to take his hand out of the cookie jar and invest RGGI proceeds in a way that will propel New York to the forefront of climate justice.
I agree with Environmental Advocates that the Cuomo Administration has used funding for some highly questionable purposes. The Administration claims that climate change is an existential threat but still is not above taking money to mitigate that alleged harm to further political goals. The Environmental Advocates analysis does a good job uncovering a number of areas where RGGI funding decisions have deviated from the original intent of the program. I concur with their conclusion that RGGI’s purpose has always been to supplement and not supplant the state’s existing clean energy initiatives.
In my previous analysis I showed that New York investments from the RGGI allowance auction revenues are expected to only reduce emissions 89,531 tons at an average investment rate of $81.5 million. It turns out that, based on historical results, the RGGI investments are only expected to provide about 10% of the needed future emissions reductions mandated by RGGI. This is important because it means that supplanting existing programs that also reduce CO2 emissions are further contributing to a potential future problem meeting the RGGI allowance cap.
In general I agree with the RGGI at a Crossroads recommendation that a priority for RGGI proceeds should be investments that directly benefit low-income communities. I am firmly convinced that Cuomo’s clean energy plans will significantly increase costs to all ratepayers and it is important that we protect those least able to afford those increases. Unfortunately, the recommendations developed through a collaborative process involving the New York City Environmental Justice Alliance, UPROSE, PUSH Buffalo, New York Lawyers for the Public Interest, New York Working Families, and Environmental Advocates of New York include program funding for programs that only peripherally impact low income ratepayer rates. In my opinion, especially considering the fact that RGGI funded CO2 mitigation has not been particularly effective, the emphasis should be on energy efficiency and energy conservation for lower income ratepayers. If higher rates occur, funding should also be provided for