This page was originally set up to consider the New York Independent System Operator (NYISO) Carbon Pricing Initiative but it now includes all my posts on carbon pricing including the Hochul Administration’s proposal to implement a cap and invest program.
New York has goals to substantially reduce CO2 emissions. The Climate Leadership and Community Protection Act has targets to reduce GHG emissions to 60 percent of 1990 emissions levels in 2030, generate zero GHG emissions from electricity production by 2040; and ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero. Historically Renewable Energy Credits (RECs) and Zero-Emission Credits (ZECs) have been used to subsidize non-CO2 emitting sources. However, these are difficult to implement so the NYISO has proposed a carbon-pricing initiative. The Brattle Group prepared an analysis to determine whether incorporating a state policy defined cost of carbon in the wholesale market would improve the overall efficiency of the New York Independent System Operator (NYISO) energy and capacity markets.
The theory of carbon pricing is discussed in a Brattle presentation. It could internalize environmental costs and foster competition to meet energy and environmental goals cost effectively by putting a price on carbon dioxide emissions in the wholesale market. The plan is to set a cost of carbon and add that charge to the wholesale price so that CO2 emitters pay for their societal impacts. However, the devil is in the details and there are few critical voices participating in the process.
I am motivated to submit comments and prepare these blog posts on the carbon pricing initiative so that there is at least one unaffiliated stakeholder whose primary interest is low rates that has an understanding of the basis of the rationale for a carbon price and understands some of the complexities associated with implementing such a program. New York State energy planning is trying to choose between many expensive policy options like pricing carbon in the electric sector while at the same time attempting to understand which one (or what mix) will be the least expensive and have the fewest negative impacts on the existing system. If they make a good pick then state ratepayers spend the least amount of a lot of money, but if they get it wrong we will be left with lots of negative outcomes and even higher costs for a long time.
2023 Cap and Invest Posts
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New York State Cap and Invest Politician Briefing March 23, 2023
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NY Climate Act Cap and Invest Plan Going Off the Rails March 19, 2023
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Climate Act Cap and Invest Program Numbers Do Not Add Up March 10, 2023
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Making Climate Policy Work, RGGI, and New York Cap and Invest February 17, 2023
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New York Annual Climate Act Cap and Invest Revenue Targets February 13, 2023
- Initial Impression of New York Cap and Invest Program January 17, 2023
Scoping Plan Economy-Wide Strategies Posts
- Climate Action Council Economywide Strategies Subgroup July 15, 2022
- Draft Scoping Plan Carbon Pricing Strategies Comment June 9, 2022
- CCIA Climate Pollution Fee April 13, 2021
General Carbon Pricing Articles
- CLCPA Simple Value of Carbon Reduction Benefits February 9, 2021
- NY Value of Carbon Cost Effectiveness February 8, 2021 – Warning long and wonky
- Response to My Comments on the New York Value of Carbon Guidance January 5, 2021
- Another Cautionary RGGI Tale from New York January 4, 2021
- My Comments on the New York Value of Carbon Guidance Document November 25, 2020
- My comments on the FERC Carbon Pricing Policy November, 18 2020
- September 2020 FERC Carbon Pricing Technical Conference October 8, 2020
- FERC Carbon Pricing Technical Conference Watts Up With That October 5, 2020
- New York Independent System Operator Siena College Carbon Pricing Poll September 29, 2020
- Carbon Price Needed to Fund Climate Leadership and Community Protection Act Reductions September 8, 2020
- NY Climate Leadership and Community Protection Act “Benefits” July 14, 2020
- Carbon Free New York May 26 2020 Letter to the Governor May 28 2020
- Carbon Free New York May 27, 2020
- Carbon Pricing is a Practical Dead End April 21, 2020 Note: Published at Watts Up With That
- NYISO Carbon Pricing Letter to the Editor February 14, 2020
- RGGI – A Cap and Tax Market Program January 4, 2020
- Not a Lot of People Know That on Carbon Taxes December 30, 2019
- Generic Carbon Pricing Issues December 13, 2019
- Analysis Group “Potential New Carbon Pricing in the NYISO Market” October 6, 2019
- Can Carbon Pricing Can Support the New York CLCPA September 30, 2019
- Layman’s Guide to My Rationale to Oppose the NYISO Carbon Pricing Concept Proposal, Dec. 27, 2018
- NYISO Carbon Pricing Concept Proposal Translation, December 18, 2018
- My November 2018 Comment on NYS Carbon Pricing, November 19, 2018
- Setting a Price for Carbon in the New York Wholesale Electric Market for the Layman, July 17,2018
- NYS Carbon Pricing Implications of Observed CO2 on Peak Hour of 2017, June 15, 2018
- NYS Carbon Pricing Initiative Discussion of Social Cost of Carbon, May 15, 2018
- Issues with the Social Cost of Carbon 2, March 29, 2018
- Problem with reducing emissions in only one sector, November 25 2017
- Issues with the Social Cost of Carbon 1, November 24 2017
- New York State Carbon Pricing, September 14, 2017
- New York State Carbon Pricing, September 14, 2017
- Issues with the Social Cost of Carbon 1, November 24 2017
- Problem with reducing emissions in only one sector, November 25 2017
- Issues with the Social Cost of Carbon 2, March 29, 2018
- NYS Carbon Pricing Initiative Discussion of Social Cost of Carbon, May 15, 2018
- NYS Carbon Pricing Implications of Observed CO2 on Peak Hour of 2017, June 15, 2018
- Setting a Price for Carbon in the New York Wholesale Electric Market for the Layman, July 17,2018
- My November 2018 Comment on NYS Carbon Pricing, November 19, 2018
- NYISO Carbon Pricing Concept Proposal Translation, December 18, 2018
- Layman’s Guide to My Rationale to Oppose the NYISO Carbon Pricing Concept Proposal, Dec. 27, 2018
- Can Carbon Pricing Can Support the New York CLCPA September 30, 2019
- Analysis Group “Potential New Carbon Pricing in the NYISO Market” October 6, 2019
- Generic Carbon Pricing Issues December 13, 2019
- Not a Lot of People Know That on Carbon Taxes December 30, 2019
- RGGI – A Cap and Tax Market Program January 4, 2020
- NYISO Carbon Pricing Letter to the Editor February 14, 2020
- Carbon Pricing is a Practical Dead End April 21, 2020 Note: Published at Watts Up With That
- Carbon Free New York May 27, 2020
- Carbon Free New York May 26 2020 Letter to the Governor May 28 2020
- NY Climate Leadership and Community Protection Act “Benefits” July 14, 2020
- Climate Leadership and Community Protection Act Value of Carbon July 21, 2020
- Court Decision: Interim Social Cost of Greenhouse Gas Metric July 28, 2020
- Carbon Price Needed to Fund Climate Leadership and Community Protection Act Reductions September 8, 2020
- New York Independent System Operator Siena College Carbon Pricing Poll September 29, 2020
- FERC Carbon Pricing Technical Conference Watts Up With That October 5, 2020
- September 2020 FERC Carbon Pricing Technical Conference October 8, 2020
- My comments on the FERC Carbon Pricing Policy November, 18 2020
- My Comments on the New York Value of Carbon Guidance Document November 25, 2020
- Another Cautionary RGGI Tale from New York January 4, 2021
- Response to My Comments on the New York Value of Carbon Guidance January 5, 2021
- NY Value of Carbon Cost Effectiveness February 8, 2021 – Warning long and wonky
- CLCPA Simple Value of Carbon Reduction Benefits February 9, 2021
- CCIA Climate Pollution Fee April 13, 2021