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April 29, 2011

Comments on the Draft Scope of the 2013 New York State Energy Plan

The Hudson Renewable Energy Institute, Inc.
9 Vassar Street, Suite 38, Poughkeepsie, NY 12601

Allan R. Page
Chairman and CEO

                                                                                          April 27, 2011
State Energy Master Plan
NYSERDA
17 Columbia Circle
Albany, New York 12203

Re: Comments on the Draft Scope of the 2013 New York State Energy Plan


The Hudson Renewable Energy Institute (THREI) is a non-profit 501 (c) 3 educational corporation established to encourage the development and use of renewable energy through open market mechanisms. Contained herein are comments from the Institute that hopefully will assist Plan developers in their scope of work.

First, under the heading of Renewable Resources the Plan Scope calls for a compendium of continuing actions impacting renewable resources. The compendium fails to mention the original intent in the establishment of the State Renewable Portfolio Standard, to wit: to have centralized procurement replaced by competitive market mechanisms. In appropriating almost $3 billion from state jurisdiction customers from 2006 to 2024 consideration should be given to a sustainable renewable energy program that is supported by the competitive market place.



Second, the scope of the Plan is becoming too broad to provide a feasible road map for future State energy direction. Workforce development, educational initiatives, economic development, environmental impacts, transportation, smart growth, health, environmental justice, collaboration, all have a bearing on energy planning but do not in the Institute’s opinion warrant section headlines and development. The focus should be on energy and the best ways to acquire and use energy to the overall benefit of the State’s citizens.

The Institute looks forward to the work of the Committee put in place to develop the 2013 Plan and the ultimate product of the planning process.


Sincerely,


Allan R. Page




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