Clean Energy Standard – Zero-Emissions Credit (ZEC) Program

Economic Impact(s)

  1. Without the upstate nuclear fleet, New York energy consumers from across the state would pay almost $1.7 billion more annually – or $15 billion over the next decade – in electricity costs.

a. The study done by the Public Utility Law Project (PULP) that estimated the cost of the program at $7.6 billion over 12 years did not account for the forecasted increase in energy and capacity prices, added transmission upgrades or the closure of Indian Point- all of which will decrease the cost of the program or could potentially result in the elimination of the ZEC. The evaluation also did not capture the cost of expanding the renewable energy requirement to 50% by 2030.

  • In addition, the PULP report did not evaluate the energy, capacity and emission markets impacts if the facilities were prematurely retired. The Brattle and Navigant Reports did evaluate these impacts and determined maintenance of the existing resources provided substantial benefits.

Job Impacts

  1. Nuclear generation provides up to 25,000 direct and indirect New York jobs, $3 billion to the economy each year and $144 million in state and local taxes annually. In addition, the forecasted capital spending for the period 2017-2021 is approximately $750M for refueling outages. Refueling outages are conducted every 18-24 months for each unit.

Energy and Capacity Market Impacts

  1. During 2016, upstate nuclear provided over 19% of the energy produced in New York State. If they do not run, a higher cost, dirty emitting unit will replace them.


  1. Upstate Nuclear avoids 16 million tons of carbon emissions annually and over 180 million tons of carbon emissions over the 12 year bridge to more renewables. New York State and New York City has already experienced the wrath of climate change with Hurricanes Irene, Lee and Sandy, which amounted to $32 billion in damages in New York State.
  1. The facilities avoid 13,000 tons of nitrogen oxide annually, improving the air quality for our known non-attainment areas in southeastern New York, New York City and Long Island. Climate change and poor air quality have a disproportionate impact on low-income people, women, and workers. The recently released 2017 America Lung Association Report listed New York City as the ninth worst city for ozone pollution.

Reliability & Fuel Diversity

  1. The upstate nuclear fleet has a capacity factor of more than 90% and continued to run during Hurricanes Irene, Lee and Sandy and Polar Vortex.

Reasonableness of an Immediate 100% Renewable Pursuit

7. During the past decade, New York permitted and constructed 1700-1800 megawatts of new renewable resources which accounts for about 5% additional resources and 4,000,000 megawatt hours of production.  In order to achieve the 50% by 2030 standard, we need to add 25% more renewables or over 5X what we accomplished in the past decade.    In other words, adding 25% more renewables coupled with replacing existing upstate nuclear is not realistic and will increase our addiction to fossil fuel (natural gas, coal and oil)

Downstate Energy Needs provided by Upstate Resources

  1. NYC (Zone J), Long Island (Zone K) and Dunwoody (Zone I) provide 28.3% of the energy produced within New York State (137,531 GWh) but consumed over 50% of the energy consumed. Zones A-H generation produce almost 72% of all energy consumed. (see Table 5)

Facility Ownership

  1. Upstate nuclear plants are owned by multiple entities including Exelon, EDF and Long Island Power Authority.

Supporting Materials

Table 1

The following information is extracted from the 2017 Draft NYISO Gold Book released this week.  The table below outlines the actual generation by zone, percentage of total generation by zone, and 2016 actual load demand by zone within the NYISO.  As you can see, the NYC (Zone J), Long Island (Zone K) and Dunwoody (Zone I) provide 28.3% of the energy produced within New York State (137,531 GWh) but consumed over 50% of the energy consumed.  Zones A-H generation produce almost 72% of all energy consumed.

Zone 2016 Actual Generation By Zone (GWh) 2016 Percent of Total Generation By Zone 2016 Load Demand by Zone
A (Western New York) 17,786.9 12.9% 9.8%
B (Genesee) 5,455.3 4.0% 6.2%
C (Central) 29,454.8 21.4% 10.1%
D (North) 8,756.1 6.4% 2.7%
E (Mohawk Valley) 3,401.5 2.5% 4.9%
F (Capital) 16,339.4 11.9% 7.7%
G (Hudson Valley) 1,911.3 1.4% 6.2%
H (Millwood) 15,513.5 11.3% 1.8%
I (Dunwoody) 0 0% 3.8%
J (New York City) 27,229.5 19.8% 33.4%
K (Long Island) 11,683.2 8.5% 13.4%
Total In-State Generation 137,531.5

Table 2 –NYISO Draft 2017 Gold Book- Highest New York Generation Units by Zone & Fuel Type

The table below outlines the 2016 top 14 producing generation units in New York State by production, % of state production, zone location, and fuel type.  These fourteen facilities provide almost 72% of energy produced in New York State.  Further, 10 of the 14 facilities are located upstate in Zones A-H.

NYISO 2017 Gold Book – Top 14 Producing Facilities 2016 Production (GWh) % of State Production Zone Location Fuel Type
NMP 1 & 2 15,492 11.30% C Central NY nuclear
Entergy Indian Point 2 & 3 15,125 11.00% H Hudson Valley nuclear
Moses Niagara 14,631 10.60% A Western NY hydro
St. Lawrence 7,113 5.20% D Northern NY hydro
Astoria 2 & 3 6,260 4.60% J NYC fossil
Fitzpatrick 5,956 4.30% C Central NY nuclear
Ravenswood CC and 1-3 5,390 3.90% J NYC fossil
Bethlehem Energy 5,202 3.90% F Capital fossil
Ginna 5,062 3.70% B Western NY nuclear
Independence Station 4,734 3.40% C Central NY fossil
Athens 1-3 3,969 2.90% F Capital fossil
East Coast Power 3,602 2.60% J NYC fossil
Empire Generating 3,453 2.50% F Capital fossil
Astoria CC 2,722 2.00% J NYC fossil
Total Production Top 14   98,711 71.90% 10/14 Highest Producing Facilities located in upstate NY
Ginna, Fitzpatrick and NMP Production 26,510 19.30%  
Total Production In-State  (2017 Gold Book) 137, 531

Table 3 – Capacity Factors by Fuel Type

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Table 4 – NYISO Trends Report – Generation Statewide by Fuel Type

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Table 5 – Upstate Generation & Load Demand vs Downstate Generation & Load Demand

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