Explore PECC's advocacy work by reading about the comments submitted to regulatory agencies and decision makers. This page includes summaries of the comments PECC and its members have authored or endorsed, providing clear insight into the key issues, arguments, and recommendations presented.

On January 28, 2026, Executive Director Michael Hamersky submitted testimony on behalf of PECC regarding New York’s Fiscal Year 2027 Budget to help ensure that New York meets its statutory climate obligations, protects ratepayers with lower energy bills, and delivers a decarbonized energy future that benefits all New Yorkers. 

The testimony urges New York to continue to phase out fossil fuel and acknowledges PECC’s recognition that New York’s energy demand is expected to grow in the coming years. However, these challenges do not relieve New York of its statutorily mandated efforts to phase out fossil fuels and adopt policies consistent with achieving deep decarbonization under the Climate Leadership and Community Protection Act (“CLCPA”). As a national leader in clean energy policy, New York must not shirk its commitments to support renewable energy development. The Budget’s lack of explicit support for renewable energy development is unacceptable, and the Governor’s related statements endorsing an “all of the above” energy approach risk perpetuation continued investment in fossil fuel infrastructure. While PECC recognizes the complexity of New York’s current energy mix and the transmission constraints shaping near-term planning decisions, PECC urges New York not to use those constraints to justify retreating from the State’s role as a national climate leader. The CLCPA is enforceable law and failing to support renewable energy development in the Budget undermines the State’s ability to meet its statutory obligations. 

The testimony also calls for New York to renew the Sustainable Energy Future Program (“SFP”) at equal or increased funding levels. The creation of the SFP in the FY26 Enacted Budget was a meaningful step toward aligning State capital investment with New York’s climate and energy goals. The SFP was designed to advance high-impact, system-level decarbonization projects, particularly in sectors that have historically lacked stable and scalable capital pathways. By renewing the SFP at equal or increased funding levels, the State will send a strong signal of support for the phased nature of decarbonization and efficient system-level planning, and help ensure that New York’s climate, affordability, and equity goals are achieved in practice. Without renewal, the State risks slowing progress at a moment when sustained leadership is most needed. 

Finally, the testimony points out the necessity of prioritizing long-term affordability in New York. Long-term energy affordability requires explicit support for renewable energy. Decades of empirical data demonstrate that renewable energy resources, including wind, solar, and geothermal, provide long-term price stability and significantly lower lifecycle system costs. Continued reliance on fossil fuels, even for short-term price relief, exposes ratepayers to fuel price volatility and geopolitical risks. One need not look further than this past January to witness spikes in natural gas prices in response to extreme weather. Extreme weather, made worse by climate change, will continue to lead to volatile and rising natural gas prices, which increased costs will be felt by New York energy consumers. 

As noted in the testimony, New York stands at a critical juncture in its climate and energy future. The CLCPA and Energy Law §6-104 set forth legally binding mandates that require not only deep decarbonization but also an equitable, affordable, and reliable energy transition. PECC argues that the Budget must therefore support a durable framework that aligns with New York’s statutory mandates, strengthens public confidence, and delivers a decarbonized, equitable, and affordable energy future for all New Yorkers.

In collaboration with Sustainable Westchester, Pace Energy and Climate Center ("PECC") submitted a comment to the NYS Public Service Commission on Con Edison’s Stage 2 Design Plan for the City of Mount Vernon Utility Thermal Energy Network (“UTEN”) pilot in Case 22-M-0429. In this recent public comment submission, available below, PECC commended Con Edison and the City of Mount Vernon for advancing a first of its kind district thermal demonstration grounded in strong technical analysis, close municipal coordination, and meaningful customer protections. The Stage 2 filing outlines a technically feasible two pipe, single loop thermal network serving forty-two existing buildings and a new Energy Center, with design choices that support load diversification, coordination with other infrastructure investments, and long-term system scalability.

At the same time, PECC highlights several areas where additional Commission attention could strengthen the pilot’s value and transferability. These include greater transparency around key cost drivers and escalation decisions, sensitivity testing of alternative design pathways, and clearer guidance on cost recovery and regulatory asset treatment. PECC also encourages alignment with recent federal tax law changes under H.R. 1 that may help improve affordability for customers. Looking beyond the pilot period, the comment emphasizes the importance of stronger reporting on customer experience, workforce and equity outcomes, and a clear transition framework that prioritizes service continuity and explores post pilot ownership pathways, including municipal and other non-utility models, to ensure that public and ratepayer investments deliver durable benefits consistent with Climate Leadership and Community Protection Act goals.

The New York State Energy Plan is the central policy roadmap for achieving New York’s statutory climate goals, including a 100% zero-emission electricity system by 2040 and an 85% reduction in greenhouse gas emissions by 2050. In its recent public comment submission, available below, the Pace Energy and Climate Center commended the Draft Plan’s reaffirmation of reliability, equity, and affordability as guiding principles, while urging the New York State Energy Planning Board to adopt a more decisive, enforceable framework to meet the mandates of the Climate Leadership and Community Protection Act.

PECC’s recommendations emphasize five key priorities: (1) Phasing out fossil fuels by 2030, with limited reliability exceptions; (2) Accelerating clean energy deployment through coordinated planning and a stepped electrification strategy; (3) Establishing strict lifecycle-based standards for alternative fuels and supporting a Clean Transportation Standard focused on electrification; (4) Scaling up community-led thermal energy networks ("TENs") and recognizing thermal energy’s value in reducing grid costs and building emissions; and (5) Centering affordability by adopting a 6% energy burden benchmark, implementing durable funding mechanisms such as cap-and-invest, and ensuring disadvantaged communities benefit first.

Through these proposals, PECC aims to help transform the Final State Energy Plan into a bold, actionable blueprint for a decarbonized, equitable, and affordable energy future in New York.

On September 22, 2025, a group of 58 Haub Law students submitted a comment urging EPA to abandon its proposed rule, “Reconsideration of the 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards.” PECC joined as a signatory, demonstrating its strong support for the comment and the many students who worked on it. The comment advanced three primary arguments which were thoroughly flushed out over 21 pages.

First, despite EPA’s contention that it lacks statutory authority under Section 202(a) of the Clean Air Act to regulate greenhouse gas emissions, such authority has been well established since 2007. In Massachusetts v. EPA, the Supreme Court not only held that GHGs met the Act’s definition of “air pollutant” but also that the EPA has a non-discretionary duty to regulate such pollutants if they endanger public health and welfare.

Second, while EPA asserts unfounded claims that the 2009 Endangerment Finding was based on an unreasonable analysis of scientific data and that new developments cast doubt on such conclusions, the comment explains that the Agency’s reliance on the Department of Energy’s recent “Climate Working Group” report constitutes arbitrary and capricious decision-making in violation of Section 706(2)(a) of the Administrative Procedure Act.

Lastly, the comment addresses EPA’s claims that there is no available technology capable of addressing the identified climate concerns without exacerbating risks to public health and welfare, countering that the Agency is bluntly disregarding decades of regulatory experience, scientific data, proven emission control technologies, and existing enforcement infrastructures.

Hear from the students on our R.E.A.C.T. by PECC Podcast.

On September 23, 2025, PECC Executive Board member Kenneth Sumter J.D. '26 submitted a comment, with PECC's signature and full support, in response to New Jersey Department of Environmental Protection's ("NJDEP") review of the proposed Northeast Supply Enhancement ("NESE") project. The project calls for a 37.1-mile expansion of the existing Transco natural gas pipeline, stretching from Pennsylvania through New Jersey and into New York. The gas resulting from this expansion will serve New York customers, yet New Jersey is left shouldering the environmental consequences.

The comment urges NJDEP to deny the project and details the serious environmental, social, and economic risks it poses on New Jersey communities. In short, this is a short-term fossil fuel expansion benefiting New York with long-term consequences for New Jersey to face. Not only will this project compromise New Jersey's climate goals, but it will damage sensitive ecosystems, and undermine the well-being of New Jersey residents.

On June 2, 2025, the Pace Energy and Climate Center (PECC) filed a submission with the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC) in response to a call for inputs on the potential impacts of greenhouse gas reduction measures.  The PECC’s submission flows from a program under the UNFCCC and the Paris Agreement that examines the impacts of greenhouse gas mitigation measures, recognizing that sometimes such measures produce negative effects.

To better understand the impacts of greenhouse gas reduction actions, the parties to the UNFCCC and Paris Agreement (the Parties) created in 2018 the Katowice Committee of Experts on the Impacts of the Implementation of Response Measures (KCI), to assist them in sharing information, experience, and best practices on the impacts.  At COP28 in 2023, the Parties tasked the Secretariat (Decision 13/CP.28) to organize two-day global dialogues in 2024 and 2025 on the impact of greenhouse gas reduction measures, in conjunction with the KCI.

Non-party stakeholders, like the PECC, were invited to submit their views on possible topics for the global dialogues. The PECC’s submission, which was prepared by Joseph Siegel, PECC’s outgoing Interim Executive Director, with the assistance of Brooke Wood, PECC Legal Research Assistant, recommends that the Secretariat include, as a topic in the 2025 global dialogue, the potential for conflict to emerge from greenhouse gas reduction actions.

The submission provides examples of conflict and tensions stemming from greenhouse gas reduction actions, such as community opposition to solar installations, lawsuits against wind projects, and conflicts from mining minerals that are needed for decarbonization technologies.  The PECC’s submission also discusses the opportunities for broader use of conflict resolution, conflict prevention, and conflict management strategies, which can be effective in addressing greenhouse gas mitigation-related conflicts and tensions. It then suggests the benefit of using mediators and third-party impartial facilitators to design and implement processes for conflict resolution, prevention, and management.  Finally, the PECC makes recommendations to the Secretariat and KCI on designing the two-day dialogue to maximize its effectiveness.

PECC’s submission can be found here.

• Public Comment Due March 30, 2026 on Petition to Suspend or Modify Renewable Energy Program Targets: The PSC opened a formal comment period through March 30, 2026 on a petition seeking a hearing under Public Service Law §66-p to evaluate whether New York’s Renewable Energy Program should be temporarily suspended or modified in light of reliability concerns.