David Gahl

Comments on the Draft State Energy Plan

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 a real lifecycle carbon accounting system to inform future decisions. Attention to all of these items will help establish a better roadmap for reducing GHGs, protect New Yorker's from the dangers posed by climate change, build a clean energy future, and create jobs in the clean energy sector.

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