Hello! I'm Raya.
I'm an environmental advocate and policy storyteller. I help to translate science and technology data into policy change and community education to make transformative and equitable clean energy transitions.
Raya Salter Esq.
ENERGY & ENVIRONMENTAL LAW & POLICY CONSULTANT & EDUCATOR; MEMBER, NY STATE CLIMATE ACTION COUNCIL.
Climate Change & Clean Energy Law & Policy Analysis
Climate Change Advocacy and Campaign Management
Public Speaking & Media Appearances
Strategic Planning & Fundraising
Creative Content Development
December 31, 2023
Raya Salter Statement on theNew York Cumulative Impacts Environmental Justice Bill
Background: NY State Governor Hochul signed the Cumulative Impacts bill (S.8830/A.2103D), which ensures that existing burdens - or cumulative impacts - are considered in permitting decisions that impact disadvantaged communities.
“This law is important because it requires that cumulative impacts, or existing environmental burdens, be examined when permitting impacts disadvantaged communities. This new requirement enhances the environmental justice provisions already in New York law pursuant to the state’s 2019 Climate Act.
The 2019 Act requires that the state’s actions not create a “disproportionate burden” on “disadvantaged communities.” The Act did not specifically require, however, that a cumulative impacts analysis be performed in environmental impact studies. Requiring a cumulative impacts analysis gives the state, and communities, a powerful tool to ensure that disproportionate burdens are not created by new and potentially polluting projects. Few states have similar laws on the books.
Cumulative impacts analyses provide insight into where historical environmental racism has increased environmental burdens on Black, Brown and low-income communities. A cumulative impacts analysis is designed to determine when incremental harm will be caused by a new project when added to past, present, and reasonably foreseeable future actions.
If, for example, a new polluting project is to be sited in a community that already has several existing environmental burdens, the state must now consider the overall additional impacts before giving a green light. The goal is to prevent disadvantaged communities from suffering a disproportionate burden from pollution.
What is needed is for the state to fully implement section 7(3) of the existing Climate Act with regards to "no disproportionate burden" to disadvantaged communities. Cumulative impact statements are a small part of the state's environmental justice mandates. Further, the effective date of this bill should not implicate analyses already required by law. This bill could be seen by some as a stalking horse, making it easier for existing projects to make it through the pipeline. I would argue that the existing DAC provisions of the CLCPA are not in any way limited by this bill.""
December 27, 2022
RAYA SALTER NY DAILY NEWS Op-ED
Climate Council Member Raya Salter Statement on Final NYS Scoping Plan
December 19, 2022
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“The release of the final Scoping Plan is a landmark moment for climate action in New York State -the Plan delivers meaningful change in state policy that will lead to climate and energy justice outcomes.
I was a member of the Council’s Gas Transition Subgroup and worked directly on the Scoping Plan’s vision to retire fossil fuel plants and decarbonize the buildings sector. A highlight of the Plan is a blueprint for the retirement of New York City’s most-polluting fossil fuel facilities and their sites by 2030. The NYC fossil fuel plant retirement blueprint will inform broader planning to retire fossil fuel plants throughout the State. This sends a clear message to the fossil gas industry that their days in New York State are numbered.
Another sea change in State policy is the Plan’s framework for New York’s gas system transition that will adhere to the State’s emissions targets, prioritize affordability, health and frontline communities while ensuring a just transition for the gas industry workforce.
The Plan’s gas transition framework clearly signals that New York state is turning away from fossil gas in New York state. Fossil gas is a threat to New York’s homes, health, economy and well-being - the proven and viable alternatives like heat pumps must be embraced now.
Another important highlight in the Plan is the creation of a new state office of Just Transition to guide the state’s plans to shut down fossil fuel facilities and equitably transition workers while increasing access to jobs for everyone.
The Plan is not perfect - while New York’s climate law should ultimately prohibit most “renewable natural gas” and hydrogen for use in pipelines on an emissions basis, the plan includes too much contemplation of these false solutions. So-called “advanced-nuclear” is another false solution contemplated for development in the Plan that is bad for New York.
The Plan does, however, provide a comprehensive approach to reaching the state’s nation-leading climate goals across all sectors with a focus on justice and equity. Plans for economy-wide strategies to address emissions, including carbon pricing, “cap and invest” and a clean transportation standard will need to be carefully evaluated to ensure justice, equity, and the prioritization of frontline communities as New York law requires.
Ultimately, the final Scoping Plan is the accomplishment of thousands of activists in New York state. In 2019 I stood with activists in Albany who shut down then-Governor Cuomo’s office in an action to demand what ultimately became the Climate Leadership and Community Protection Act. Together, we witnessed an advocacy arc that has led to a sea change in New York climate policy as manifested in the final Scoping Plan. At the same time, we transformed the national landscape as the inspiration for the Biden administration “Justice40” policy to prioritize investments into “disadvantaged communities.”
Throughout the entire Plan process, activists attended meetings, wrote letters, rallied and are the true reason for the Plan’s climate justice accomplishments. We will need to continue the work of making sure that the Plan, and the Climate Law, are implemented in the public interest for the benefit of New Yorkers with a focus on frontline communities.”