2024 Agency Filings


  • Battery Storage

    Comments and Attachment B Recommendations on the Interagency Fire Safety Working Group Fire Code Recommendations, submitted by ACE NY and NY-BEST, March 5, 2024.

  • Renewables Taxation

    Comments to the Department of Taxation and Finance on the draft 2024 Solar and Wind Appraisal Model, submitted by ACE NY and NYSEIA, February 27, 2024.

2023 Agency Filings


  • Potential Reliability Rule #151

    Comments to the New York State Reliability Council on Potential Reliability Rule # 151 - Establish minimum interconnection standards for Large Inverter Based Resource (IBR) Generating Facilities based on IEEE Standard 2800™ - 2022. Submitted by ACE NY, December 21, 2023.

  • Energy Efficiency

    Comments to NYSERDA on the Inflation Reduction Act (IRA) Home Energy Rebate Programs. Submitted by ACE NY, December 20, 2023.

  • Cap-and-Invest

    Letter to Governor Hochul with 9 organizations urging the release of an outline of a strong Cap-and-Invest program, December 7, 2023.

  • Agrivoltaics

    Comments in response to NYSERDA’s Agrivoltaics Research and Demonstration Request for Information, submitted by ACE NY, November 15, 2023.

  • Energy Efficiency

    Comments to NYSERDA on proposed Evaluation Criteria for Determining Cost-Effectiveness of Updates to the Energy Conservation Codes submitted by ACE NY, November 3, 2023.

  • Energy Efficiency

    Letter to the New York State Building Code Council with 35 organizations requesting an update in the building code to bring it in alignment with the Climate Law and electrification laws, September 1, 2023.

  • Cap-and-Invest

    Comments filed to the Department of Environmental Conservation and NYSERDA on the proposed New York Cap-and-Invest program, as proposed by the CLCPA, submitted by ACE NY, August, 9, 2023.

  • Energy Storage

    Joint Comments to NYSERDA on the need for differentiated incentive levels for solar-plus-storage and standalone storage projects upstate. Filed by ACE NY and NY-BEST regarding the 6 GW Energy Storage Roadmap, June 29, 2023.

  • Solar Panel Recycling

    Joint Comments to the Department of Environmental Conservation on the State’s Draft Solid Waste Management Plan, submitted by ACE NY, NYSEIA and SEIA, June 28, 2023.

  • Zoning for Renewables

    Letter to City Planning Commission in support of the proposed City of Yes for Carbon Neutrality amendment to modernize New York City’s zoning rules, submitted by ACE NY, June 9, 2023.

  • Potential Reliability Rule #151

    Joint Comments to the New York State Reliability Council on Potential Reliability Rule # 151 - Establish minimum interconnection standards for Large Inverter Based Resource (IBR) Generating Facilities based on IEEE Standard 2800™ - 2022. Submitted by ACE NY and American Clean Power Association (ACP), April 27, 2023.

  • Tier 2 Renewables

    Letter to Empire State Development in response to the agency’s recently issued proposals to modify its Excelsior regulations to incorporate Green CHIPS, submitted by ACE NY, March 10, 2023.

  • Electric Vehicles

    Joint Comments to the Department of Environmental Conservation on the Adoption of Advanced Clean Cars II and Heavy Duty Low NOx and Phase 2 Greenhouse Gas Standards, submitted by ACE NY and Advanced Energy United, March 6, 2023.

  • Tier 1 and OSW Contracts

    Comments on the NYSERDA Request for Information (LSRRFI23-1) regarding the modification of Tier 1 and Offshore Wind Contracts to account for NYISO capacity accreditation rule changes, submitted by ACE NY, Advanced Energy United, and NYOWA, February 17, 2023.

  • Energy Efficiency

    Letter to the New York State Building Code Council with 21 organizations requesting an update in the building code to bring it in alignment with the Climate Law, February 3, 2023.

  • Tier 2 Renewables

    Letter to NYSERDA in response to the agency’s 2022 Tier 2 Request For Information (RFI), submitted by ACE NY, January 20, 2023.

2022 Agency Filings


  • Stormwater Management Design

    Letter to the NYS Department of Environmental Conservation on its Draft Stormwater Management Design Manual, submitted by ACE NY, December 18, 2022.

  • Transmission

    Letter to the Transmission Owners offering recommendations on their Coordinated Grid Planning Process (CGPP) filing with the PSC, submitted by ACE NY, December 8, 2022.

  • Renewables Taxation

    Letter to the Department of Taxation and Finance Acting Commissioner Amanda Hiller urging action on the Solar and Wind Appraisal Model, submitted by ACE NY and NYSEIA, November 4, 2022.

  • Large-Scale Renewables

    Comments on the 2022 RES Solicitation Request for Information (RESRFI22-1) for proposed modifications to the annual Tier 1 Solicitation submitted by ACE NY, July 28, 2022.

  • Transportation and Climate

    Comments on the Draft Climate Action Plan to include the direct sales of zero-emission vehicles in the final Climate Action Plan submitted by ACE NY and 22 other organizations and companies, July 1, 2022.

2021 Agency Filings


  • Energy Storage

    Letter to Governor Hochul Urging Support for Energy Storage Policies, submitted by NY-BEST, ACE NY, and 20 Other Organizations to Governor Hochul, November 19, 2021.

  • Zero Emissions Trucks

    Comments in Support of DEC’s Proposed Medium-and Heavy-Duty Zero Emission Truck Annual Sales Requirements and Large Entity Reporting, submitted by ACE NY and 31 Other Organizations to NY DEC, ID No. ENV-36-21-00004-P, November 17, 2021.

  • Clean Fuel Standard

    Letter to Commissioner Seggos on How a Clean Fuel Standard Can Support the Advanced Clean Truck Rule, submitted by ACE NY and 13 Other Organizations to Commissioner Seggos, November 17, 2021.

  • Building Energy Efficiency

    Letter to Governor Hochul on Building Electrification Equity, submitted by ACE NY and 205 Other Organizations to Governor Hochul, October 20, 2021.

  • Renewables Taxation

    Second Set of Comments on NYS Department of Taxation and Finance’s Proposed Appraisal Methodology for Solar and Wind Energy Projects, submitted by ACE NY and NYSEIA to the NYS Department of Taxation and Finance, October 1, 2021.

  • Renewables Taxation

    Comments on NYS Department of Taxation and Finance Proposed Appraisal Methodology for Solar and Wind Energy Project, submitted by ACE NY and NYESIA to the NYS Department of Taxation and Finance, September 3, 2021.

  • Vehicle Emissions Standards

    Comments to Northeast States Coordinated Air Use Management on California’s Medium- Heavy-Duty Vehicle Emission Standards, submitted by ACE NY and 35 other Environmental Organizations to Northeast States for Coordinated Air Use Management, August 18, 2021.

  • Transportation Climate Investments

    Comments on TCI Draft Public Engagement Framework, Model Implementation Plan and Proposed Strategies for Regional Collaboration, submitted by ACE NY to Secretary Theoharides and Commissioner Seggos, August 13, 2021.

  • Carbon Neutral Buildings

    Comments on NYSERDA’s Carbon Neutral Building Roadmap, submitted by ACE NY to Advisor for Energy Efficient Markets and Finance, August 6, 2021.

  • Local Solar Law

    Letter to the Fenner Town Board: Town of Fenner’s Proposed Solar Law, submitted by ACE NY to Town of Fenner Board, June 25, 2021.

  • Clean Truck Rules

    Comments on New York’s Adoption of the Advanced Clean Truck and Heavy Duty-Omnibus Rules, submitted by ACE NY to NY DEC Commissioner Seggos, June 25, 2021.

  • Renewables Taxation

    Recommendations Regarding Establishing a Standard Tax Methodology for Wind and Solar Projects, submitted by ACE NY and NYSEIA to NYS Department of Taxation and Finance Commissioner Hiller and NYSERDA President Harris, May 11, 2021.

  • Clean Fuel Standard

    Recommendations to Include a Clean Fuel Standard in NY’s Climate Action Plan, submitted by the Clean Fuel NY Coalition to NY Climate Action Council, May 4, 2021.

  • Solar and Agriculture

    Request for Representation to the Farmland Protection Working Group, submitted by ACE NY to NY Department of Agriculture and Markets Commissioner Ball, May 4, 2021.

  • Transportation Climate Investments

    Comments on TCI Draft Model Rule and Public Engagement Plan, submitted by ACE NY to Secretary Theoharides and NY DEC Commissioner Seggos, April 21, 2021.

  • Clean Transportation

    Recommendations to the Transportation Advisory Panel Members of The Climate Action Council, submitted by ACE NY to Transportation Advisory Panel Members, March 23, 2021.

  • Clean Truck Rules

    Letter on Adopting the Advanced Clean Truck and Heavy-Duty Omnibus Rules, submitted by ACE NY to NY DEC Commissioner Seggos and CCE Deputy Commissioner Snyder, March 12, 2021.

  • Climate and Electricity

    Policy Recommendations to the Power Generation Advisory Panel of The Climate Action Council, submitted by ACE NY to Members of the Power Generation Advisory Panel of the Climate Action Council, March 8, 2021.

  • Building Energy Efficiency

    Policy Recommendations to the Energy Efficiency and Housing Advisory Panel of The Climate Action Council, submitted by ACE NY to the Energy Efficiency and Housing Advisory Panel, February 18, 2021.

  • Transportation and Climate

    Policy Recommendations to the Transportation Advisory Panel of The Climate Action Council, submitted by ACE NY and AEE to the Transportation Advisory Panel, February 1, 2021.

2020 Agency Filings


  • December 7, 2020

    Comments on the Office of Renewable Energy Siting Proposed Regulations for the Review and Permitting of Renewable Energy Projects, submitted by ACE NY, AWEA, and SEIA to ORES.

  • December 7, 2020

    Comments on the Sound Components of the Ores Proposal, submitted by ACE NY and AWEA to the ORES Executive Director Moaveni.