13 February 2014 John B.

Rhodes President and CEO NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Re: Draft New York State Energy Plan and the Public Process Dear Mr. Rhodes: We, the undersigned organizations, represent New Yorkers concerned about New York State energy policy. We write to call your attention to some concerns we share about the public comment process for the newly released draft 2014 New York State Energy Plan. We hope we can work with you and the Energy Planning Board to facilitate a richer public comment process and a stronger final Energy Plan. The Energy Plan is an important public policy document that will help determine New York State energy policy for not just the next few years, but for decades. Infrastructure investments and public policy have inertia and are difficult to reverse. Decisions made today in these areas will affect New Yorkers for generations to come. We believe public involvement in these decisions is a critical element of the democratic process and in achieving sustainable energy policy. Meeting the state's climate goals will not just require major effort and initiative from the governmental agencies that have membership on the Energy Planning Board; the involvement and initiative of public interest organizations and members of the public will also be critical to achieving these goals. A process that facilitates public understanding of the draft plan and provides the public meaningful influence over the final plan is paramount to achieving climate, efficiency and renewable energy goals. We have identified some obstacles to public participation in the comment process. We ask that you work with us to address these issues with the goal of opening up the process to a greater number of New Yorkers. 1. At least one information session should be provided to allow members of the public to ask clarifying questions about the plan in addition to holding the public hearings. There are many questions about items in the Energy Plan that cannot be clarified without more information. There is precedence for this type of session. Such sessions have been held by federal and state agencies when inviting public participation on complex issues. Just recently, similar information sessions were held in Syracuse and Albany by DEC for the proposed regulations on liquefied natural gas facilities. In October, the PSC held a technical conference, open to the public, to review and receive comments on three proposals affecting New Yorks portfolio of clean energy programs (the Green Bank, EEPs, and RPS), prior to the deadline for public comment. 2. Key documents that are essential to the Energy Plan are not currently available and are described as forthcoming. These include the Greenhouse Gas Inventory and the Draft Energy Efficiency and Renewable Resource Potential in New York (Potential Study). Both of these reports are essential to energy planning, Article 6, and the original scope for the Energy Plan. We request these documents be made available immediately.

3. The public comment period should be extended to allow members of the public more time to read, understand and comment on the Plan. The Plan is lengthy and complex. Pending the public release of the missing documents described above, we request a 90-day extension to the comment period so that we can jointly review the draft Energy Plan in connection with those documents. The original public comment period for this Energy Plan, published in the October 26, 2011 Energy Planning Board meeting notes, was to be Fall - Winter 2012. Though exact dates were not defined, this indicates an intention for a comment period of about 6 months. We understand that this draft Energy Plan is late and that the Energy Planning Board is eager to complete the process, but we do not think it is fair for the public comment period to be shortened so dramatically. 4. The public hearing times should be changed to provide for evening hours so that working New Yorkers have the opportunity to attend the hearings. The daytime hearings will be inaccessible to most working New Yorkers. It is common practice for government agencies to hold public hearings in the evening to accommodate people who work during the day. We suggest that all of the hearings should start between 5:00 pm and 7:00 pm. 5. Another hearing location should be added that is more accessible to people living in the Hudson Valley. The Energy Planning law requires at least 6 public hearings across the state, and it was the initial intention of the Energy Planning Board, as stated in the notes from the July 9, 2012 meeting, to hold "ten hearings across the State, ideally within each of the ten Regional Economic Development Council areas. 6. A printer-friendly version of the Energy Plan should be posted on the website to allow members of the public to print the document without the large photos. The current format requires large amounts of ink and paper for printing. Hard-copies of the Plan should be made available upon request for those without access to printers or to the website, at reasonable locations distributed throughout the state. 7. Please identify on the website the public members of the Energy Planning Board appointed by the Governor and the Legislature. We look forward to hearing from you about these requests. We hope you will work with us to facilitate a meaningful public comment process about the draft 2014 New York State Energy Plan. Sincerely, 350 NYC Lyna Hinkel Member Alliance for a Green Economy Jessica Azulay Program Director Catskill Citizens for Safe Energy Jill Wiener Member Catskill Mountainkeeper

Wes Gillingham Program Director Center for Working Families Anthony Ng Green & Equitable Economies Strategist Citizen Action of NY Kristina Andreotta Campaign Manager Citizens Awareness Network Deb Katz Executive Director Citizens' Environmental Coalition Barbara Warren Executive Director Citizens for Local Power (CLP) Susan H. Gillespie Representative Citizens for Water Joe Levine Director City Solar Tracy Fitz, LEED AP Founder & Director Clean Air: Organizing for Health and Justice Erin Heaney Executive Director Coalition Against the Rockaway Pipeline (CARP) Edie Kantrowitz Co-Coordinator Community Watersheds Clean Water Coalition Suzannah Glidden Treasurer Concerned Citizens of Montauk Rav Freidel Director Damascus Citizens for Sustainability Barbara Arrindell Director

Delaware Action Group Caroline Martin Founder Delaware Riverkeeper Network Tracy Carluccio Deputy Director Environmental Justice Action Group of WNY Eric Walker Chair ESF Fossil Fuel Divestment Campaign Erin Carr Representative Food & Water Watch Alex Beauchamp Northeast Region Director Frack Action Julia Walsh Campaign Director Gas Drilling Awareness for Cortland County Sheila Cohen Representative Gas Free Seneca Yvonne Taylor Co-Founder Granny Peace Brigade-NYC Barbara Harris Member Grassroots Environmental Education Patti Wood Executive Director Hudson River Sloop Clearwater, Inc. Manna Jo Greene Environmental Director Indian Point Safe Energy Coalition Michel Lee Member Marbletown Citizens for Sustainable Energy

Jill Obrig Co-Founder New Yorkers Against Fracking Renee Vogelsang Upstate Regional Director New Yorkers for Clean Water Inc. Susan Chew Chairwoman New York Environmental Law and Justice Project Annie Wilson Senior Energy Policy Advisor New York Public Interest Research Group (NYPIRG) Laura Haight Senior Environmental Associate New York Solar Energy Society Wyldon King Fishman Founder and President Nuclear Information and Resource Service (NIRS) Tim Judson Executive Director Otsego 2000, Inc. Nicole Dillingham Board President Otsego Neighbors Julie Huntsman Representative Peace Action New York State (PANYS) Alicia Godsberg Executive Director Pepacton Institute LLC Jannette Barth Managing Director and Senior Economist Protect Orange County Pramilla Malick Founder Re-ENERGIZE Buffalo David Kowalski Founder

Sane Energy Project Clare Donahue Founding Member Save the Southern Tier Isaac Silberman-Gorn Co-Founder Shaleshock CNY Sharon Osika-Michales Member Sierra Club Atlantic Chapter Jeff Bohner Chair Stop the Algonquin Pipeline Expansion Suzannah Glidden Co-founder Sustainable Otsego Adrian Kuzminski Moderator Syracuse Peace Council Ursula Rozum Organizer Unitarian Church of Staten Island Raffaella Iosue Vice President United for Action Meredith Dillon Member Westchester for Change Susan Van Dolsen Co-organizer Western New York Drilling Defense Rita Yelda Founder Western New York Peace Center, Inc. Charley Bowman Renewable Energy Task Force