Comment
The New York State IBEW Utility Labor Council strongly supports the Public Service Commission's Nuclear Reliability Backbone, including preservation of New York's existing 3.4 GW nuclear fleet, development of at least 1 GW of new nuclear generation through NYPA, and a pathway to 4 GW of additional advanced nuclear capacity.New York's electric system is entering a period of declining reliability margins and rising demand. NYISO reports that the statewide summer reliability margin has fallen from 2,227 MW in 2019 to only 417 MW in 2026, as approximately 4.4 GW of generation retired while only 2.9 GW was added. At the same time, demand is increasing because of building and transportation electrification, semiconductor manufacturing, data centers, and other major economic-development projects. Winter reliability is also becoming a growing concern. Firm, zero-emission nuclear generation provides around-the-clock power that reduces pressure on the transmission and distribution system and limits dependence on fuel-constrained generation during extreme weather.New York's own experience demonstrates the value of preserving nuclear generation. In 2016, the State acted to preserve the upstate nuclear fleet through the Zero Emission Credit program. Those plants continue to provide reliable power, thousands of jobs, substantial economic activity, tax revenue, and major emissions benefits. By contrast, the closure of Indian Point removed roughly 2,000 MW of firm zero-emission generation from the downstate system. Much of that output was replaced by natural gas generation, fossil-fuel use increased, wholesale electricity prices rose, emissions increased, and skilled jobs and local tax revenues were lost. New York should not repeat that experience.The Nuclear Reliability Backbone is also critical to the future of the utility workforce. State policy is steadily reducing the long-term role of natural gas, and utility gas workers are already seeing slowing growth and declining employment prospects. Expansion of the electric system can provide a practical transition path for those workers into transmission, substations, interconnections, system protection, operations, maintenance, and other electric-side classifications. Nuclear generation is especially valuable because plants can operate for 60 to 80 years, anchoring decades of utility employment and long-term investment in the grid.Reliability must also be sequenced correctly. Existing dispatchable generation should not retire based on projected replacement dates that have not yet been achieved. With reliability margins already thin, New York should not remove firm capacity until replacement resources are actually in commercial operation.The Commission should integrate nuclear development with transmission, interconnection, and substation planning from the outset; include operating and maintenance workforce needs in the Advanced Nuclear Policy Options Paper; formally include utility operating workers in the technical conference; and monitor staffing, succession planning, and workforce retention at the existing nuclear fleet through the ZEC extension.The Nuclear Reliability Backbone is not simply a generation policy. It is a long-term reliability, economic-development, and workforce strategy. The utility workers who operate, maintain, and restore New York's electric system must be directly involved in its planning and implementation.