Comments

18 Oct 2018

Supplemental comments about PURPA



States: National,
Resource Type: Comments

Adoption Year: 2018
Abstract: Many states and utilities fail to comply with existing PURPA regulations. Is PURPA still relevant and necessary today? Calls to reform PURPA ignore the remaining barriers to market entry that qualifying facilities face and overstate the need for reform.
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27 Nov 2017

Energy Commission Investigation Regarding the State of Puerto Rico's Electric System after Hurricane Maria



States: National,
Resource Type: Comments

Adoption Year: 2017
Abstract: The tragic weather events that destroyed so much of the Commonwealth of Puerto Rico’s electricity infrastructure have sent a strong message about the brittle nature of central stationdominated electricity systems. The most important challenge facing the Commission is whether it will honor the grim lessons of recent hurricanes with actions to reduce the consequences of future severe weather events that are certain to follow.
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22 Aug 2016

Comments of Environmental Advocates, Natural Resources Defense Council, Pace Energy and Climate Center, and Riverkeeper on August 1, 2016 “Proposed Comprehensive Queue Reform Initiative


Topics: Climate,

States: New York,
Resource Type: Comments

Adoption Year: 2016
Abstract: none
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22 Aug 2016

Proposed Comprehensive Queue Reform Initiative


Topics: DER,

States: New York,
Resource Type: Comments

Adoption Year: 2016
Abstract: The key to an efficient interconnection process is timely commitment, reasonable study of costs and procedures and effective timelines. The Proposed Comprehensive Queue Reform Initiative is a proactive start in resolving inefficiencies, however in order to accomplish New York State’s 50% Renewable Energy Mandate, effective queue reform must be more robust and extensive.
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05 Aug 2016

Comments on Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation

Author: PECC Staff

Topics: Emissions,

States: Federal,
Resource Type: Comments

Adoption Year: 2016
Abstract: Comments submitted to Assistant Attorney General Cruden, pursuant to the Department of Justice Notice dated July 6, 2016, on Proposed Partial Consent Decree Under the Clean Air Act; In Re: Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation, Case No: MDL No. 2672 CRB (JSC).
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01 Jan 2016

Comments on Volkswagen

Author: PECC Staff


States: National,
Resource Type: Comments

Adoption Year: 2016
Abstract: VW ZEV investment program should include support of competitive markets, extended benefits to all communities, protected driver choice, preserve customer choice, encourage innovation, promote EV awareness & outreach, benefit all drivers, and provide process transparency.
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22 Sep 2014

Pace & supporters’ comments on the NYS Department of Public Service "Straw Proposal" in the landmark Reforming the Energy Vision case (14-M-0101)


Topics: REV,

States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: Comments filed to the NYS Public Service Commission by Pace and supporters (Columbia University’s Sabin Center for Climate Change Law, Environmental Advocates of New York, the Sierra Club, and the Vermont Energy Investment Corporation) in the landmark Reforming the Energy Vision case (14-M-0101). Filed September 22, 2014.
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22 Sep 2014

REV Track 1 Straw Proposal Comments



States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: This document revisits and builds upon many of the points raised in a filing submitted on July 18, 2014, by a similar coalition of national and state-based environmental groups, clean energy companies, two academic centers, and one of New York’s leading consumer groups. The Clean Energy Advocates support many aspects of the Proposal. The Proposal describes an ambitious vision that can transform New York’s electricity infrastructure. It encourages the greater deployment of distributed energy resources. The Proposal provides much needed detail about the implementation of REV. It recommends the development of new planning tools and recommends launching several new stakeholder processes. The Clean Energy Advocates are pleased to see signifi...
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18 Jul 2014

Pace & supporters' comments on the NYS Department of Public Service "Staff Report” in the landmark Reforming the Energy Vision case (14-M-0101) and the Clean Energy Fund case (14-M-0094)


Topics: REV,

States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: Comments filed to the NYS Public Service Commission by Pace and nine supporting organizations in the landmark Reforming the Energy Vision case (14-M-0101 and 14-M-0094). Filed July 18, 2014.
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18 Jul 2014

July 2014 Comments on REV and the Clean Energy Fund



States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: TThe range and complexity of the issues that the Commission will have to address as we embark on the Reforming the Energy Vision (REV) can seem daunting. The temptation to become "lost in trees" and to lose "sight of the forest" must be resisted. With that in mind, the Joint Commenters offer the following principles as a directional map to the Commission and DPS staff against which specific policies and programs should be evaluated: 1. Emissions reductions must remain central to REV's objectives and outcomes. 2. New York must preserve and affirm its commitments to energy efficiency and renewable energy. 3. Distributed energy resources (DER) should be fully valued to reflect the operational, environmental, and social benefits these resources...
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30 May 2014

Comments on the Draft State Energy Plan

Author: David Gahl


States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: We offer the following five recommendations. To improve the Final Plan, drafters should: 1) establish near-term, mid-term and long-term GHG reduction targets in straight tonnage terms, but also require GHG reporting in intensity terms; 2) establish aggressive statewide energy efficiency savings targets and renewable energy deployment targets as a way to meet the GHG reduction goals; 3) include more specific action items related to updating building codes, including setting training and outreach goals; 4) establish a statewide transportation emissions reduction goal, and eliminate barriers to electric vehicle deployment to help reduce GHG emissions; and 5) follow through on updating energy-related cost benefit analyses and begin development...
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30 May 2014

Pace Energy and Climate Center comments on the draft 2014 New York State Energy Plan


Topics: Markets,

States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: Comments filed to the New York State Energy Research and Development Authority and the State Energy Planning Board on the draft New York State Energy Plan. Filed May 30, 2014.
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01 Jan 2014

Comments on the REV Proceeding and the Clean Energy Fund



States: New York,
Resource Type: Comments

Adoption Year: 2014
Abstract: The Joint Commenters offer the following principles as a directional map to the Commission and DPS staff against which specific policies and programs should be evaluated: 1. Emissions reductions must remain central to REV’s objectives and outcomes. 2. New York must preserve and affirm its commitments to energy efficiency and renewable energy. 3. Distributed energy resources (DER) should be fully valued to reflect the operational, environmental, and social benefits these resources provide to both the energy system and the public. 4. Any compensation to a Distributed System Platform Provider (DSPP) should be commensurate with its performance in addressing clear public policy objectives established by the Commission, including greenhouse gas...
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08 Apr 2013

RPS Comments: Case 03-E-0188, NYSERDA Petition Regarding Unencumbered CST Funds

Author: Adam Cohn

Topics: Misc,

States: New York,
Resource Type: Comments

Adoption Year: 2013
Abstract: Pace comments submitted to the PSC in support of NYSERDA's proposal to reallocate CST funds
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08 Apr 2013

Support of NYSERDA's Proposal to Reallocate CST Funds

Author: Adam Cohn


States: New York,
Resource Type: Comments

Adoption Year: 2013
Abstract: NYSERDA's proposed reallocation will enlarge the Solar PV 2013 budget by more than 30%, an increase of $11.6 million. Pace agrees with this decision to use unencumbered funds to boost the Solar PV budget, as it will help meet the bold targets set forth in Governor Cuomo's NY-Sun initiative. The additional funding for Solar PV will also lead to increased stability in New York's solar market and is expected to result in 15 MW of additional installed solar capacity. At the same time, we recognize the importance of sustained, robust support for all of the CST technologies in order to ensure the state's RPS drives the adoption of a diverse universe of renewable resources. As proposed, we support the NYSERDA reallocation, as it successfully balan...
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07 Dec 2012

Pace Supports Increased Efficiency Budgets in the Wake of Hurricane Sandy



States: New York,
Resource Type: Comments

Adoption Year: 2012
Abstract: Comments filed to the New York PSC by Pace and supporters (NRDC, Sierra Club, Citizens Campaign for the Environment, Alliance for Clean Energy New York and Environmental Advocates of New York) following Hurricane Sandy, advocating for increased efficiency budgets in the wake of Sandy and future storms.
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07 Dec 2012

Pace and Supporters' Comments in Favor of Increased Efficiency Budgets in the Wake of Hurricane Sandy


Topics: Climate,

States: Northeast,
Resource Type: Comments

Adoption Year: 2012
Abstract: None
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08 Dec 2008

Reply Brief: Proceeding on Motion of the Commission as to the Rates, Charges, Rules, and Regulations of ConEd for Electric Services

Author: PECC Staff


States: New York,
Resource Type: Comments

Adoption Year: 2008
Abstract: Offering testimony on the issue of actions that ConEd can take to encourage development of DER and CHP within its service territory.
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17 Nov 2008

Initial Comments: Proceeding on Motion of the Commission as to the Rates, Charges, Rules, and Regulations of ConEd for electric Service


Topics: Solar,

States: New York,
Resource Type: Comments

Adoption Year: 2008
Abstract: Concerns proposed revisions that would increase the target level of photovoltaics and other on-peak resources in high-cost areas.
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