Letter to New York State Public Service Commission Re: Large Scale Renewable Program

August 27, 2020

Hon. Michelle M. Phillips, Secretary
New York State Public Service Commission
Three Empire State Plaza
Albany, NY 12223-1350

RE: Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard

Dear Secretary Phillips,

On behalf of New Yorkers for Affordable Energy (NYAE), a coalition of community, labor and business leaders from across the state who support efforts to take an “all of the above” approach to the State’s energy policy, I write to you regarding the proceeding to implement a Large-Scale Renewable Program and a Clean Energy Standard, and more specifically about the need to implement a full life-cycle analysis (LCA) of renewable energy sources.

It is absolutely essential to evaluate the upstream emissions/life cycle of our renewable energy sources, from the manufacturing site (many of which are produced in China using coal powered plants) to the final retirement of each solar panel and wind turbine. To apply a less rigorous emissions analysis to renewable power generators than the standard applied to more traditional power generators is misleading and prejudicial, and will lead to results contrary to New York’s stated environmental objectives.

There must be an equal examination of the impacts of technologies that our government has deemed “clean.” The natural gas industry, which has enabled dramatic drops in emissions in the United States, is asking only to be on equal footing. There is clear evidence of adverse environmental impacts of wind and solar and to ignore this is not sound government policy.

Recent studies show that solar panels have become one of the leading emitters of hexafluoroethane (C2F6), nitrogen trifluoride (NF3), and sulfur hexafluoride (SF6). According to the Intergovernmental Panel on Climate Change (IPCC) these harmful greenhouse gases are 12,000, 17,000 and 23,000 times more threatening respectively than carbon dioxide. Because of the rapidly growing solar photovoltaic industry, scientists have documented NF3 levels rising by 11 percent a year and exponential increases in SF6 in our atmosphere, according to the NOAA and a recent report from the Geophysical Research Letters.

A recent report by the Manhattan Institute highlights the significant environmental impacts of producing “clean technologies,” such as wind, solar, and electric cars and raises alarming questions. More to the point, as the study highlights, “Building wind turbines and solar panels to generate electricity, as well as batteries to fuel electric vehicles, requires, on average, more than 10 times the quantity of materials, compared with building machines using hydro-carbons to deliver the same amount of energy to society.”

We must also examine the impact of producing this “green technology” and what becomes of these technologies when they have reached the end of their useful life. Energy waste is a valid concern, as solar panels and wind turbines created in the early 2000s will soon end up in landfills around New York.

To be clear, we are not suggesting that New York abandon its efforts to grow its renewable portfolio. However, there must be an honest and factual assessment of the environmental impacts of all of our state’s energy resources to ensure our grid consists of the least environmentally impactful options available.

We respectfully ask the Public Service Commission (PSC) to implement, as part of these proceedings, a full life-cycle analysis, as has been insisted upon with other sources of energy, such as natural gas, to ensure that we truly protect our environment while meeting the energy needs of New Yorkers.


Michael Lawler
Director, New Yorkers for Affordable Energy

About New Yorkers for Affordable Energy

New Yorkers for Affordable Energy is a coalition of community, labor, business and industry leaders from across the state who support greater access to clean, reliable and affordable sources of energy for residential and business consumers. We understand the important role that natural gas plays in our everyday lives, from heating and cooling our homes to powering our communities. As demand for energy continues to grow, New Yorkers for Affordable Energy supports efforts to increase access to natural gas for manufacturing facilities, power production, transportation, and to serve as a catalyst for job growth and support New York’s economy and quality of life.

Coalition Members

The Business Council of New York State, Inc.
New York State Building & Construction Trades Council
Acoustic Clean Dennis
Albany Valve & Fitting Co. Inc.
Ambient Environmental, Inc.
BlueRock Energy
Buffalo Niagara Partnership
Capital Region Chamber of Commerce
Central Hudson
Chautauqua County Chamber of Commerce
Chemung County Chamber of Commerce
Constitution Pipeline
Cortland County Chamber of Commerce
D.A. Collins
Danskammer Energy
Delaware Engineering
Dominion Energy
Eastern NY District Council of Laborers
Energy Coalition New York
Energy Equipment and Infrastructure Alliance
EnergyMark, LLC
Engineers Labor-Employer Cooperative (ELEC 825)

General Contractors Association of NY
Hudson Valley Building & Construction Trades Council
Independent Oil & Gas Association of NY (IOGA-NY)
Independent Power Producers of NY (IPPNY)
International Union of Operating Engineers Local 825 (IOUE 825)
IUOE Local 825
Joint Landowners Coalition
Laborers District Council of Eastern NY
Laborers Local 17 LECET Fund
Manufacturers Association of the Southern Tier
Millennium Pipeline
National Fuel Gas Company
National Federation of Independent Business
North Country Chamber of Commerce
NYS Building & Construction Trades Council
NYS Conference of the International Union of Operating Engineers
NYS Economic Development Council
NYS LECET Fund (Laborers-Employers Cooperation & Education Trust)
NYS Pipe Trades Association
Orange County Partnership
Otsego County IDA
Penn-York Land Services Corp.
Unshackle Upstate
Upstate New York Laborers District Council
U.S. Chamber of Commerce’s Institute for 21st Century Energy
USA Compression
The Williams Companies