Comments to NYS DEC and NYSERDA re: Draft Investment Framework for NYCI Climate Investment Account

The Guarini Center submitted public comments to the New York State Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA) in response to the agencies’ request for comment on a draft investment framework for the state’s Climate Investment Account.  The Climate Investment Account is one of several components of the New York Climate Action Fund, which the State Legislature established in 2023 to receive proceeds from a proposed New York Cap-and-Invest Program (NYCI) to help fund the state’s transition to a carbon-neutral economy, in accordance with the Climate Leadership and Community Protection Act (CLCPA).

In the comments, the Guarini Center urged DEC and NYSERDA to:

• Align their recommendations for spending the Climate Investment Account’s funds with the overall framework of the state’s Scoping Plan, which contemplates a comprehensive and coherent state strategy to drive down New York’s GHG emissions at speed and scale, utilizing a combination of complementary regulatory, market-based, and financial investment policy levers;
• Model and disclose the impacts of different Climate Investment Account allocations, so that stakeholders can better understand how different funding allocations influence GHG and co-pollutant reductions across economic sectors, geographies, and the state economy as a whole;
• Allocate Climate Investment Account funds so that the benefits of those investments (including but not limited to benefits arising from co-pollutant reductions) accrue to disadvantaged communities in compliance with the CLCPA, and develop a clear rubric for understanding and tracking disadvantaged community benefits resulting from Climate Investment Account spending; and
• Give detailed consideration to how Climate Investment Account funds will be delivered to investment recipients, as well as how to address structural barriers that may impede private actors’ participation in investment programs, so as to ensure that GHG and co-pollutant reductions are achieved efficiently and equitably.