NY Needs Gas Utility Planning for Equitable Clean Energy Transition

NY Needs Gas Utility Planning for Equitable Clean Energy Transition

New York needs a gas utility planning process that can deliver on the equitable clean energy transition promised by its landmark climate and clean energy law—The New York Climate Leadership and Community Protection Act (CLCPA).

In recently filed comments and reply comments, Natural Resources Defense Council (NRDC) together with Sierra Club, the Regional Plan Association, Association for Energy Affordability, and New Yorkers for Clean Power presented a vision for a gas system planning process to identify the lowest-cost, least-risk path for equitably decarbonizing the State’s gas utility system.

Achieving the CLCPA Will Require Dramatic Reductions of Fossil Fuel Use and Contraction of the Gas System

The CLCPA calls for ambitious, economy-wide climate and clean energy targets that require all sectors of New York State’s economy to collectively achieve 85 percent emissions reductions from 1990 levels and net-zero greenhouse gas emissions by 2050.

The CLCPA also includes several important provisions to prioritize equity in fighting climate change and to ensure that disadvantaged communities are not left behind in the State’s clean energy transition.

To meet these bold climate and equity mandates, New York will need to drastically reduce fossil gas use, especially in our buildings and for generating electricity, because fossil gas is the State’s biggest source of greenhouse gas emissions. This poses a particular challenge for gas utilities because their business models are premised on expanding—not contracting—gas services.

Strategic gas utility planning starting now is critical for controlling customer bill impacts and ensuring an equitable clean energy transition as more customers leave the system and switch to clean sources of energy.

New York’s Proceeding to Modernize Gas Utility Planning

Last spring, the New York Public Service Commission (Commission) instituted a proceeding to establish planning and operational practices that best support customer needs and emissions objectives.  In doing so, the Commission tasked Department of Public Service Staff (Staff) with issuing a proposal for a modernized gas planning process.

On February 12, 2021, Staff issued a commendable, cutting-edge Gas Planning Proposal, which holds promise for making vast improvements over the existing planning process by seeking to improve gas planning, operational practices, transparency, consideration of alternatives to traditional gas infrastructure (known as non-pipeline alternatives or “NPAs”), and alignment with the State’s clean energy and climate policy.

But the Proposal also fell short of the Commission’s directive for a “process that is comprehensive, suited to forward-looking system and policy needs, designed to minimize total lifetime costs” because it lacks mechanisms for developing a cost-effective decarbonization strategy for gas utilities consistent with the requirements of the CLCPA, rigorous calculating and reporting of greenhouse gas emissions, and discussion and analysis of impacts on disadvantaged communities and low- and moderate-income customers.

Prudent Gas System Planning Must Prepare for the Transition Off of Fossil Gas Use

Gas system planning cannot ignore the vision and mandates of the CLCPA.

In our comments on Staff’s Gas Planning Proposal, we recommend that the Commission direct Staff and the New York State Energy Research and Development Authority to lead a stakeholder process to develop a statewide Transition Plan to identify an integrated, least-cost, least-risk path for decarbonizing the State’s gas system as a whole, as well as for decarbonizing each fossil gas utility’s system. 

In support of this recommendation, our comments included a trailblazing white paper from Synapse Energy Economics Inc., Long-Term Planning to Support the Transition of New York’s Gas Utility Industry, which articulates a comprehensive economic assessment that is needed to identify a long-term vision for how the New York fossil gas utilities should evolve to ensure that the State can meet the goals of the CLCPA, as well as other important objectives such as availability of service and customer equity (see this Synapse blog for more).

The different types of analyses that make up the comprehensive economic assessment are presented in the table below.

Overview of Comprehensive Economic Assessment

Synapse, Long-Term Planning to Support the Transition of New York’s Gas Utility Industry

Importantly, the statewide Transition Plan should be used to inform and guide the utility-specific Resource Plans described in Staff’s Gas Planning Proposal. To ensure they meet the requirements of the CLCPA and other important regulatory objectives, both the Transition Plan and the Resource Plans should adhere to the following principles and practices:

  • Design all scenarios to comply with the CLCPA: It’s critical that the planning process and all analyzed scenarios are consistent with CLCPA requirements. To facilitate this, the State should establish short-, medium-, and long-term greenhouse gas emission reduction targets for each gas utility. In addition, load forecasting practices should use the most up-to-date information, including the impacts of state and local decarbonization policies and market trends.
  • Integrate gas and electricity planning: The planning process should consider electric and gas consumption, technology options, prices, and sales in an integrated manner. Utility-specific Resource Plans should demonstrate how gas and electric utilities are working together. Planning should consider the relationship between electric and gas utility business models, an assessment of gas utilities’ obligation to serve customers, and the level of return on equity that should be applied to new business models given a potentially different risk profile.
  • Develop comprehensive non-pipeline alternatives screening frameworks: Alternatives to fossil gas infrastructure should be evaluated for cost-effectiveness from the societal perspective and at the portfolio level. The assessment should include impacts over the project’s useful life and should consider the value of flexibility associated with deferring new gas infrastructure investments.
  • Apply a high threshold for approving new gas infrastructure investments: Where a utility’s Resource Plan includes specific traditional gas infrastructure investments, the plan should fully document how those investments meet the standards set in the statewide Transition Plan. This should include a higher threshold for approving gas infrastructure that reflects appropriate asset lives and depreciation schedules, the risk of failing to meet the requirements of the CLCPA, and the cost associated with locking into large conventional investments (a negative option value).
  • A limited role for alternative fuels: Overreliance on alternative fuels, like biogas and synthetic methane, is a dead-end strategy for decarbonizing the gas distribution system because their potential supply is limited and dwarfed by the current levels of fossil gas use and because they can still have harmful environmental and public health impacts. To ensure environmental benefits, a robust regulatory framework and plan for handling the environmental attributes is a necessary precondition for a limited role for alternative fuels to fossil gas.  
  • Adopt practices for strategic asset retirement: Utilities should take a geotargeted approach to electrification, switching customers served by a particular gas distribution line, and retiring that line. Priority for retirement should be assigned to gas lines that are aging, leaking, or otherwise due to be replaced.
  • Consider equity implications: Planning should include several layers of geographically specific information focusing on targeted customer segments and community-level impacts in order to assess planning implications for equity issues such as energy burden, distributed energy resource participation rates, and environmental and health impacts. With this information, cost-effectiveness analyses can be better understood through an equity lens, which should lead to greater prioritization of NPA solutions that provide energy efficiency and electrification of affordable housing, including comprehensive retrofits.

Strategic Gas Planning Is Vital to NY’s Climate Leadership 

The importance of statewide planning to develop a vision and roadmap for the gas utility industry to achieve the CLCPA’s 2050 emission reduction mandates cannot be overstated. With less than 30 years until New York must become carbon neutral, it’s critical that strategic gas planning gets underway now to control customer bill impacts and ensure an equitable clean energy transition.

Identifying and prioritizing approaches to decarbonization that align with the State’s multiple objectives requires a robust, integrated planning framework that matches the scale and ambition of the CLCPA.

About The Author

Christopher Casey advocates to advance climate and clean energy policy priorities in New York as a member of NRDC's Eastern Energy and Sustainable FERC project teams. Currently, he focuses on NYISO wholesale electricity markets, power and gas system planning, increasing deployment of renewable and energy efficiency, and clean transportation. Prior to joining NRDC, Casey was an energy attorney at a boutique law firm in New Jersey, served as assistant attorney general for the Washington State Utilities and Transportation Commission, and worked at a consumer-owned utility. He holds a J.D. and a master's in environmental law from Vermont Law School and a bachelor's degree from Bates College.

Related Books

Drawdown: The Most Comprehensive Plan Ever Proposed to Reverse Global Warming

by Paul Hawken and Tom Steyer
9780143130444In the face of widespread fear and apathy, an international coalition of researchers, professionals, and scientists have come together to offer a set of realistic and bold solutions to climate change. One hundred techniques and practices are described here—some are well known; some you may have never heard of. They range from clean energy to educating girls in lower-income countries to land use practices that pull carbon out of the air. The solutions exist, are economically viable, and communities throughout the world are currently enacting them with skill and determination. Available On Amazon

Designing Climate Solutions: A Policy Guide for Low-Carbon Energy

by Hal Harvey, Robbie Orvis, Jeffrey Rissman
1610919564With the effects of climate change already upon us, the need to cut global greenhouse gas emissions is nothing less than urgent. It’s a daunting challenge, but the technologies and strategies to meet it exist today. A small set of energy policies, designed and implemented well, can put us on the path to a low carbon future. Energy systems are large and complex, so energy policy must be focused and cost-effective. One-size-fits-all approaches simply won’t get the job done. Policymakers need a clear, comprehensive resource that outlines the energy policies that will have the biggest impact on our climate future, and describes how to design these policies well. Available On Amazon

This Changes Everything: Capitalism vs. The Climate

by Naomi Klein
1451697392In This Changes Everything Naomi Klein argues that climate change isn’t just another issue to be neatly filed between taxes and health care. It’s an alarm that calls us to fix an economic system that is already failing us in many ways. Klein meticulously builds the case for how massively reducing our greenhouse emissions is our best chance to simultaneously reduce gaping inequalities, re-imagine our broken democracies, and rebuild our gutted local economies. She exposes the ideological desperation of the climate-change deniers, the messianic delusions of the would-be geoengineers, and the tragic defeatism of too many mainstream green initiatives. And she demonstrates precisely why the market has not—and cannot—fix the climate crisis but will instead make things worse, with ever more extreme and ecologically damaging extraction methods, accompanied by rampant disaster capitalism. Available On Amazon

From The Publisher:
Purchases on Amazon go to defray the cost of bringing you InnerSelf.comelf.com, MightyNatural.com, and ClimateImpactNews.com at no cost and without advertisers that track your browsing habits. Even if you click on a link but don't buy these selected products, anything else you buy in that same visit on Amazon pays us a small commission. There is no additional cost to you, so please contribute to the effort. You can also use this link to use to Amazon at any time so you can help support our efforts.


This article originally appeared on OnEarth


follow InnerSelf on

facebook icontwitter iconyoutube iconinstagram iconpintrest iconrss icon

 Get The Latest By Email

Weekly Magazine Daily Inspiration


The Great Climate Migration Has Begun
The Great Climate Migration Has Begun
by Super User
The climate crisis is forcing thousands around the world to flee as their homes become increasingly uninhabitable.
The Last Ice Age Tells Us Why We Need To Care About A 2℃ Change In Temperature
The Last Ice Age Tells Us Why We Need To Care About A 2℃ Change In Temperature
by Alan N Williams, et al
The latest report from the Intergovernmental Panel on Climate Change (IPCC) states that without a substantial decrease…
Earth Has Stayed Habitable For Billions Of Years – Exactly How Lucky Did We Get?
Earth Has Stayed Habitable For Billions Of Years – Exactly How Lucky Did We Get?
by Toby Tyrrell
It took evolution 3 or 4 billion years to produce Homo sapiens. If the climate had completely failed just once in that…
How Mapping The Weather 12,000 Years Ago Can Help Predict Future Climate Change
How Mapping The Weather 12,000 Years Ago Can Help Predict Future Climate Change
by Brice Rea
The end of the last ice age, around 12,000 years ago, was characterised by a final cold phase called the Younger Dryas.…
The Caspian Sea Is Set To Fall By 9 Metres Or More This Century
The Caspian Sea Is Set To Fall By 9 Metres Or More This Century
by Frank Wesselingh and Matteo Lattuada
Imagine you are on the coast, looking out to sea. In front of you lies 100 metres of barren sand that looks like a…
Venus Was Once More Earth-like, But Climate Change Made It Uninhabitable
Venus Was Once More Earth-like, But Climate Change Made It Uninhabitable
by Richard Ernst
We can learn a lot about climate change from Venus, our sister planet. Venus currently has a surface temperature of…
Five Climate Disbeliefs: A Crash Course In Climate Misinformation
The Five Climate Disbeliefs: A Crash Course In Climate Misinformation
by John Cook
This video is a crash course in climate misinformation, summarizing the key arguments used to cast doubt on the reality…
The Arctic Hasn't Been This Warm For 3 Million Years and That Means Big Changes For The Planet
The Arctic Hasn't Been This Warm For 3 Million Years and That Means Big Changes For The Planet
by Julie Brigham-Grette and Steve Petsch
Every year, sea ice cover in the Arctic Ocean shrinks to a low point in mid-September. This year it measures just 1.44…


trees to plant for climate2
Plant These Trees To Improve City Life
by Mike Williams-Rice
A new study establishes live oaks and American sycamores as champions among 17 “super trees” that will help make cities…
north sea sea bed
Why We Must Understand Seabed Geology To Harness The Winds
by Natasha Barlow, Associate Professor of Quaternary Environmental Change, University of Leeds
For any country blessed with easy access to the shallow and windy North Sea, offshore wind will be key to meeting net…
3 wildfire lessons for forest towns as Dixie Fire destroys historic Greenville, California
3 wildfire lessons for forest towns as Dixie Fire destroys historic Greenville, California
by Bart Johnson, Professor of Landscape Architecture, University of Oregon
A wildfire burning in hot, dry mountain forest swept through the Gold Rush town of Greenville, California, on Aug. 4,…
China Can Meet Energy and Climate Goals Capping Coal Power
China Can Meet Energy and Climate Goals Capping Coal Power
by Alvin Lin
At the Leader’s Climate Summit in April, Xi Jinping pledged that China will “strictly control coal-fired power…
Blue water surrounded by dead white grass
Map tracks 30 years of extreme snowmelt across US
by Mikayla Mace-Arizona
A new map of extreme snowmelt events over the last 30 years clarifies the processes that drive rapid melting.
A plane drops red fire retardant on to a forest fire as firefighters parked along a road look up into the orange sky
Model predicts 10-year burst of wildfire, then gradual decline
by Hannah Hickey-U. Washington
A look at the long-term future of wildfires predicts an initial roughly decade-long burst of wildfire activity,…
White sea ice in blue water with the sun setting reflected in the water
Earth’s frozen areas are shrinking 33K square miles a year
by Texas A&M University
The Earth’s cryosphere is shrinking by 33,000 square miles (87,000 square kilometers) per year.
A row of male and female speakers at microphones
234 scientists read 14,000+ research papers to write the upcoming IPCC climate report
by Stephanie Spera, Assistant Professor of Geography and the Environment, University of Richmond
This week, hundreds of scientists from around the world are finalizing a report that assesses the state of the global…

 Get The Latest By Email

Weekly Magazine Daily Inspiration

New Attitudes - New Possibilities

InnerSelf.comClimateImpactNews.com | InnerPower.net
MightyNatural.com | WholisticPolitics.com | InnerSelf Market
Copyright ©1985 - 2021 InnerSelf Publications. All Rights Reserved.