Greetings. My name is Walter L. T. Hang. I am a life-long resident of New York and have lived in Ithaca since 1988. Thank you for the opportunity to comment on Governor Andrew M. Cuomo's Proposed Clean Energy Standard in the State Energy Plan (SEP).

I am by no means an energy expert, but I have closely followed New York State energy policy proceedings since 2009 and believe my comments are useful to consider. I have nearly 40 years of experience in New York State environmental policy matters and worked as a public interest advocate for 12 years. Most recently I have been intensely involved with shale fracking and fossil fuel infrastructure concerns.

One need only read the SEP to appreciate how enormously complex energy issues are in New York. Nevertheless, I believe there can be no mistake that the proposed SEP is fatally flawed because it would allow our state's addiction to fossil fuels to be perpetuated instead of halted. That is why I believe major strategic revisions are urgently required. Please allow me to explain.

Proposed State Energy Plan

It is my understanding that the SEP states 50 percent of all electricity used in New York State by 2030 should be generated from renewable energy sources. I also understand that the SEP aims to achieve goals of 40% reduction in greenhouse gas emissions from 1990 levels by 2030 and 600 trillion Btu (British thermal units) in energy efficiency gains or a 23% reduction from 2012 in energy consumption in buildings. According to the SEP, these targets would allow the state to achieve its longer-term goal of decreasing carbon emissions 80% by 2050.

SEP's Fatal Flaw

However laudable these goals may be, the SEP has at least one huge shortcoming because, "Staff assumes that the incremental renewable target will be achieved through obtaining energy from new, large scale renewable, as well as BTM [behind the meter, not in the original] resources."

This strategy is highly unlikely to succeed due to two irrefutable realities. First, renewable energy resources simply cannot compete with less costly fossil fuels at this time, notably natural gas that is so abundant and cheap that the nation is literally awash in a shale gas glut produced by high-volume hydraulic fracking that has spread all over the country, but fortunately not to New York.

Second, Governor Cuomo has permitted many fossil fuel infrastructure projects to be built at gargantuan costs that will require literally decades to repay. His policy is perpetuating New York's addiction to fossil fuel consumption. Recent projects include the Spectra and AIM (Algonquin Incremental Market) natural gas pipelines and the Danskammer, CPV (Competitive Power Ventures) and Cricket Valley power plants designed to burn natural gas with oil back-up.

As a result, New York remains shockingly dependent on fossil fuels and has developed extremely limited wind, solar and geothermal energy alternatives. Virtually all of the renewable energy consumed in New York is generated by large-scale hydroelectric facilities built half a century ago. There are no plans to build more giant hydro plants. As a result, New York would have to increase its wind and solar energy production on a vast scale in order to meet the SEP goals.

According to Appendix B in the SEP, our State's 2014 fuel mix, using Environmental Disclosure Form and BTM resource data, is presented below. Wind and solar constitute only 2.8% of New York's electricity generation. Hydropower produces 22.5% of our electricity.

According to Power Trends 2015, New York's electricity generation is even more dependent on natural gas based on information newer than the SEP data. As illustrated below, natural gas and natural gas with oil back-up generates 56% of our state's electricity. Moreover, the Power Trends report notes that, "More than 70 percent of all proposed generating capacity in New York are natural gas or dual fuel power plants."

Proposed SEP Requires Fundamental Revision

Given these realities, it is highly unlikely that renewable energy alternatives can supplant fossil fuel consumption in order to generate 50% of New York's electricity by 2030.

In order to avoid environmental and public health hazards caused by power production, I believe New York must do everything feasible as a top priority to stop burning fossil fuels to generate electricity. Our state simply must minimize consumption of natural gas, oil and coal in two steps.

First and foremost, New York must impose an immediate moratorium on permitting any new large-scale fossil fuel infrastructure projects, including pipelines, compressor stations, power plants,

power plant conversions and gas storage facilities. This must apply to the proposed New Market project that recently received conditional approval from FERC (Federal Energy Regulatory Commission). New York will never end the burning of fossil fuels unless it stops expanding the costly infrastructure required to deliver and consume those highly polluting toxic materials.

In addition to their energy policy implications, fossil fuel facilities across New York are documented with the Department of Environmental Conservation's own data to have caused a total of 114 major explosions, fires, ruptures and toxic discharges that often were never cleaned up to state standards. These findings were recently confirmed by a Pipeline Safety Oversight Audit of the Public Service Commission conducted by the Office of the New York State Comptroller.

Given these well-documented problems, no new fossil fuel facilities should be permitted by New York authorities until it can be guaranteed that environmental hazards will be prevented and/or cleaned up on a comprehensive basis.

See: Natural Gas, Crude Oil and Petroleum Product Pipeline Fires, Explosions, Accidents, Ruptures and Spills

http://osc.state.ny.us/audits/allaudits/093016/15s31.pdf

Second, New York must maximize energy efficiency on a statewide basis through comprehensive insulation, weatherizing and retrofitting programs that should dwarf all existing efforts. These programs could create literally hundreds of thousands of desperately needed jobs.

For example, $57 million in funding was recently announced for a low-income housing energy efficiency improvement program. It was estimated that approximately 6,000 structures might be involved. This is insufficient to say the least. New York State has a total of more than eight million housing units.

I would like to underscore that my strategy is precisely what Governor Cuomo proposed in his Built to Lead 2016 Agenda, but failed to fund on a sufficient basis:

"The least expensive and most effective way to meet our state energy goals is simply to reduce the overall energy consumption of New York's homes, businesses, and institutions by making them more efficient. Increasing energy efficiency also lowers utility bills for customers and enables businesses to reduce their operating costs."

This strategy could dramatically transform New York's electricity generation system to renewable alternatives by halting the state's on-going addiction to fossil fuels. Equally importantly, this approach would help achieve the two other SEP goals: 40% reduction in greenhouse gas emissions from 1990 levels by 2030 and 600 trillion Btu (British thermal units) in energy efficiency gains or a 23% reduction from 2012 in energy consumption in buildings.

Conclusion

New York reportedly has more than enough electricity to meet its current needs with ample excess capacity to address emergencies. In addition, our state's electricity demand is predicted to be "flat" for the next decade. This presents an ideal scenario for implementing the plan outlined above.

This proposal has been presented to Governor Cuomo in a more detailed coalition letter with a total of 1,025 signatories as of today and has gained widespread local, regional, statewide and nationwide news coverage.

See: Coalition Letter Which Requests That Governor Cuomo End New York's Addiction to Fossil Fuels

Governor Cuomo earlier provided favorable replies to several similarly detailed coalition letters submitted by the same broad coalition of grassroots organizations, elected and appointed government officials, academic researchers, health professionals and concerned citizens.

As a result, the Governor prohibited high-volume hydrofracking of shale formations in New York and recently denied the Section 401 Water Quality Certification required for the proposed Constitution Pipeline to be built.

These landmark decisions have set the stage for implementing the innovative energy policies and programs I have proposed today. I believe these initiatives are crucial to safeguarding New York and its residents from fossil fuel pollution hazards that also contribute to global climate change. If implemented, they would provide a model of effective action that could be replicated throughout the rest of the nation.

I trust that you will find my comments self-explanatory, but please do not hesitate to ask me any questions that I might be able to answer. Thank you for your consideration