We are writing to express support of the New York State Department of Environmental Conservation’s (“DEC”) proposed rule establishing a mandatory greenhouse gas (“GHG”) reporting program to support New York’s Cap and Invest (“NYCI”) program.

RPA is an independent non-profit civic organization that develops and promotes ideas to improve the economic health, environmental resiliency, and quality of life of the New York metropolitan area. RPA conducts research and advises communities and public agencies on environmental, land use, and governance issues.

NYCI is the engine that will propel New York State forward in our transition to an economy that is fully powered by clean energy, bringing us cleaner air, homes with clean heat and air-conditioning, and better transportation options. NYCI will also enable New York to keep our energy dollars in the local economy and create tens of thousands of jobs as we upgrade our buildings, improve transit, and build out vehicle charging infrastructure.

The first step towards establishing the NYCI program is setting up mandatory annual GHG reporting. GHG reporting will set the framework for the NYCI program, offering insight on what entities are the largest emitters. The mandatory GHG reporting program has several benefits including:

• Data collection of GHG emissions, which allows us to identify the State’s primary emissions producers, offering regulators the ability to craft more effective and targeted legislation;
  
• Opportunity for organizations to voluntarily reduce their emissions and provide clear and accurate information to the general public and shareholders;
• Access to data which offers advocates a tool to hold polluters accountable and keep our air clean;
• And a chance for New York State to continue its strong track record of fighting climate change in a time where federal support is limited.

The NYCI program that this proposed rule would support offers additional benefits including:

• The reduction of carbon emissions and lower energy bills by committing to local clean energy instead of out-of-state producers;
• The availability of rebates to New Yorkers stemming from 30% of the cap-and-invest revenue;
• The generation of billions of dollars for our transit system and energy infrastructure, critical pieces in fighting climate change.

Outside of the financial benefits of the NYCI, there are numerous public health and quality of life benefits that come with reducing air pollution including reduced risk of asthma and cardiovascular disease.

Cap-and-Invest programs have a proven history reducing emission and bringing economic health benefits here in the United States.

In 2008, New York launched the first cap-and-invest program: the Regional Greenhouse Gas Initiative. Since RGGI’s inception, participating states have reduced CO2 emissions from power plants by 50% and increased investment in energy efficiency, solar and other clean energy solutions by $6.2 billion through the sale of emission allowances, with little discernible impact on electric rates - in fact, electricity rates have fallen by 3.2% in RGGI states since the program’s inception.

In 2013, California followed suit with its own cap-and-invest program, administered through the state’s Air Resources Board (ARB). The program covers entities in all sectors of the economy and has a declining cap on emissions from the 2012 baseline. Entities started reporting their emissions annually in 2008, with independent third-party verification. In total, the program covers around 80% of the State’s emissions. The program has been shown to reduce air pollution and greenhouse gas emissions in the state, and has resulted in $15 billion in energy bill credits and $32 billion for the Greenhouse Gas Reduction Fund, which the state has invested in high-speed rail, affordable housing and sustainable communities, low carbon transport, air quality, and forest health, among other programs.

Washington State established their Cap-and-Invest Program in 2023. Businesses with emissions covered by the cap must purchase allowances to cover those emissions, based on a compliance schedule that is tied to a cap that is designed to reduce carbon emissions 95% below 1990 levels by 2050, with milestones every decade. .

With increased risk and uncertainty facing the clean energy industry, the NYCI is the perfect opportunity to support investments that will improve New Yorker’s health and fully realize the promise of our state’s climate goals.