WESTCHESTER COUNTY ASSOCIATION

NEW YORK ADVOCACY AGENDA 2026

The Westchester County Association (WCA) is the county’s professional roundtable.  We unite and mobilize business leaders to advance issues and lead initiatives that strengthen our regional economy.  Through collaboration, we drive economic vitality, stimulate new business and job creation, and provide our members with the resources and talent they need to grow.

Our members include hundreds of the mid-Hudson region’s foremost organizations in industries as diverse as healthcare, real estate, finance, law, energy, technology, hospitality, higher education, and the nonprofit sector.  They collectively employ hundreds of thousands of workers.  For over 75 years, the WCA has served as the leading independent voice of the professional community.

While the WCA conducts general business advocacy (responsible budgeting, minimizing tax burden, a light-touch regulatory environment) we, as set forth herein, more specifically address certain top-level priorities consistent with our primary focus areas.  This agenda likely will be revised during the legislative session as individual priorities are introduced and advanced.

For additional information about our advocacy initiatives and policy positions on specific items of interest please contact:

Michael N. Romita                                                           Vjola Isufaj

             President & CEO                                                   Director of Public Policy

      Westchester County Association                               Westchester County Association

mnromita@westchester.org                                         visufaj@westchester.org

   O: (914) 948-3671                                                             O: (914) 948-2090

  C: (914) 906-7821                                                             C: (923) 353-5470

HEALTHCARE

The WCA’s membership includes hundreds of the region’s foremost organizations representing a broad range of industries including healthcare, real estate, finance, law, energy, technology, hospitality, and higher education.  One of the WCA’s primary focus areas is support for a strong and vibrant healthcare system.  Our board members include the heads of most major hospital and healthcare providers in the region.  We regularly advocate on their behalf, and to expand access to high quality healthcare for our residents and workers.

Healthcare remains the largest single economic engine in Westchester County and the surrounding region.  Our hospitals alone contribute over $14 billion in annual economic impact and employ close to 60,000 workers.  Moreover, the benefits to the community are both quantitative and qualitative.  It is a primary reason businesses, workers, and residents are attracted to the region.  The expansion of world-class healthcare facilities throughout the Hudson Valley is a great success story.

Fully Fund Medicaid and Disperse Approved Funds in Timely Fashion

In FY 2025-26, New York State committed $37.7B for Medicaid funding which represented a 10% increase in reimbursement to providers, who still receive approximately $.73 for every dollar of care they provided.  Much of this increased funding was expected to come from the implementation of the federally approved Managed Care Organization (MCO) tax, which is designed to generate several billion dollars in new federal matching funds.  However, ensuing federal budget legislation (H.R.1) has placed this funding stream at risk.  New York State elected officials must continue to pressure their federal colleagues to support the full implementation of the New York State MCO tax as approved by the Centers for Medicare and Medicaid (CMS) in December 2024.

Regardless of cuts to Medicaid funding from the federal government, New York State must continue to fund its Medicaid obligations and ensure that every hospital receives its fair share of that funding in a timely manner.  Approximately 7 million New Yorkers, or 35% of the State’s residents, rely on the Medicaid program for their healthcare needs.

Moreover, the FY 2025-26 Budget included $650 million in capital funding for IT and cybersecurity, but most of this funding has not been released. At one point, the Division of the Budget indicated that a portion may become available, though it is expected to be limited.  Tracking these funds has been difficult due to the various iterations and combinations of grant programs included in the FY 2025 budget.  Timely disbursement of this funding is critical to ensure providers can make the infrastructure investments needed to comply with the recently released State cybersecurity regulations.

Address the Healthcare Workforce Shortage and Fund Targeted Workforce Initiatives

Healthcare workforce shortages continue to grow in virtually every county in New York State.  Shortages preexisting the pandemic are now magnified by recently enacted staffing ratio laws for nursing homes and hospitals.  The State has made some movement towards alleviating those shortages, including passage of clinical simulation legislation which allows for up to 30 percent of clinical hours to be earned via simulation training.

However, unrealistic staffing ratio requirements for nursing homes and hospitals cannot be met.  The hospitals have complied with recent legislation requiring the establishment of an advisory staffing committee.  The WCA resists additional efforts to increase healthcare staffing ratio requirements or levy fines due to unrealistic staffing goals.

In direct response to the regional workforce shortage, the WCA has developed targeted solutions in partnership with our major regional providers.  Modest investments of approximately $3 million spread over the next several years in each of the following programs will deliver substantial benefits to healthcare employers as well as the regional economy.  These programs should be funded to help alleviate healthcare workforce shortages in the region.

• Healthcare Talent Pipeline Program (HTPP): The HTPP is a program created by the WCA to train and place job seekers into roles such as CNA, CMA, and MAA with regional providers. With funding made available through ARPA over the past three years, over 280 individuals have been hired through the HTPP with a measured annual return on program investment (job growth, salaries, economic impact) of greater than 20 to 1.  However, ARPA funding for this highly successful program is set to expire and the HTPP will end absent additional resources.
• Nurse Educator Pilot Program: As the nursing workforce ages, the need for Registered Nurses continues to grow.  The key barrier to training new nurses is the shortage of nurse educators—primarily due to the wage gap between clinicians and faculty.  In addition to financing HTPP, the WCA proposes a three-year, Westchester-based pilot to offer wage subsidies and cover training costs for nurse educators at our topflight nursing schools to teach the next generation of nurses for our Hudson Valley hospitals.

Make Permanent Scope of Practice Flexibility

During the pandemic, numerous temporary measures were enacted through executive orders that provided scope of practice flexibility among the various health care professions.  The pandemic proved the value of those provisions.  They remain an invaluable tool in ensuring access to services otherwise unavailable due to staffing shortages.  To ease workforce issues, every clinician should be allowed to use the fullest extent of their training.

The WCA specifically proposes the following changes:

• Authorize Certified Registered Nurse Anesthetists (CRNAs) to administer anesthesia without physician supervision. 357 (Cooney) / A.6771 (Reyes)

• Allow Medical Assistants (MAs) in health centers to administer vaccines, as is permitted in private physician offices and pharmacies. S.5340A (Stavisky) / A.5460B (Paulin)
• Allow a licensed pharmacist to order and administer certain tests.  We support legislation introduced in 2025 which accomplishes that goal. S.1619 (Rivera) / A.3285 (McDonald)
• Authorize New York State to Join the Physician and Nurse Licensure Compacts, as nearly all other states have done.  Launch a pilot program in underserved communities and expand statewide when proven successful.  This goal could have been advanced through Bill S.8341A (Stavisky) / A.8472B (Woerner), if not for the inclusion of a “poison pill” provision requiring a three-year in-state practice.  Strip the offending provision and reintroduce the legislation.
• Support A.1983 (Paulin) / S.5657 (Skoufis) introduced in 2025 which would establish the Interstate Medical Licensure Compact

Regulatory Relief

Excessive regulations consume valuable staff time and monetary resources that could otherwise be spent on patient care.  Providing regulatory relief, are non-fiscal remedies for financially challenged providers.

Specifically, the WCA recommends:

• Review and amend implementation of the Health Equity Impact Assessment (HEIA) mandate – while well-intentioned, this unfunded mandate adds considerable cost and time to an already lengthy state-required project approval process, often delaying needed services from coming online. DOH should amend current implement regulations to ensure DOH staff time and applicant resources are focused on the most consequential projects.

• Simplify Hospital Closure Plans. Hospital leaders should be given the flexibility to make necessary operational changes without being subject to undue restrictions.  The DOH guidelines released in 2023 imposed a protracted and burdensome process that was expanded to include projects proposing to remove only a small percentage of beds from a facility’s operating certificate and those proposing to move beds or services from one location to another.  In addition, facilities are experiencing delays in receiving feedback or approval of submitted closure plans from DOH, leading to delays in necessary system reconfigurations.

• Eliminate unnecessary reporting requirements and synchronize state and national requirements – for example conform State regulations to protected health information (PHI) regulations contained within federal law. This will avoid unnecessary duplication of reporting and allow staff resources to be more efficiently deployed.

Address Market Abuses by For-Profit Health Insurers

For profit health plans wield enormous market power over the state’s healthcare system.  Collectively, the largest for-profit health insurers drive record profits while hospitals continue to struggle, typically with 1 percent profit margins or worse.  We propose the following market conduct reforms:

• Address Payment Delay and Unfair Denial of Claims – Healthcare providers and patients alike are routinely denied or delayed care deemed medically necessary and included as part of a contractual insurance plan. Insurers have made it part of their profit model to deny and delay payment for claims. By some estimates, an average of $4.9 million per hospital has been put at risk due to denials.  Enacting legislation to address these issues would mitigate the cash flow impact to hospitals for withheld payments and ensure that patients receive the treatment they need without delay.  Insurers would remain able to challenge any procedure believed not medically necessary but would no longer be able to lever unfair financial advantage by holding hostage caregivers and patients.  Recent legislative solutions supported by the WCA include:
• Prior Authorization- A.3789A (Weprin) – requires that health plans use evidence-based and peer-reviewed clinical criteria to make medical necessity determinations and require plans’ utilization review agents to make determinations within 72 hours (not three business days) for standard requests. The bill would also extend authorizations to cover a series of treatments.
• Deem Claim Approved If Insurer Fail to Issue Timely Response — A.6898 (Weprin) / S.3402 (Fahy) – Health Plans are incentivized by current law to delay or ignore requests for care. This legislation would ensure better enforcement of the statutory timeframes for insurers to issue determinations.
• Address Down-Coding Abuses – A.3707 (Weprin) / S.4833 (Skoufis) – Prevents Insurers from changing the claim to a lower level of service than what was actually performed by the provider and prohibits plans from reversing medical necessity determinations made by a utilization review or external appeals agent.
• Enact a Healthcare Reinvestment Act – The large national health insurers are often domiciled outside of New York, and their significant profits are funneled back to their corporate headquarters and to shareholders. The banking industry is encouraged by law to invest in communities in which they do business through the Community Reinvestment Act.  For-profit health insurers should do likewise where they derive significant profit.  The reinvestment should be earmarked for technology and capital upgrades, workforce training programs and other community-based health initiatives.

Oppose Detrimental Legislation

• The WCA opposes the Grieving Families Act – A.6063 (Lunsford) / S.4423 (Hoylman-Sigal) following its fourth consecutive veto.  In its current form, this legislation would vastly inflate medical malpractice premiums (45% or higher by some estimates) by expanding the kinds of damages recoverable in a wrongful death as well as the pool of potential claimants.  Healthcare providers in the Hudson Valley already pay some of the highest malpractice premiums in the region.  Premium increases caused by this legislation will drive healthcare providers from New York to competing markets and limit access to care.  The Governor has vetoed this bill four times, and the WCA will continue to oppose it if reintroduced in its current form.
• The WCA opposes the Local Input in Community Healthcare (LICH) Act – A.6004 (Simon) / S.1226 (Rivera), which makes the regulatory process for discontinuing healthcare services and facilities more expansive and burdensome and is duplicative of measures already in place.  The LICH Act would create an extensive, nine-month long process for the closure of hospitals and nearly as burdensome a process for the much more routine changes in service lines that hospitals must make to respond to patient demand, competition in the market and clinical staffing.  The legislation will further distress hospitals already facing difficult decisions in a financial crisis and hamper routine business decisions.  This bill was vetoed for the second time by the Governor, and the WCA will continue to oppose similar legislation if re-introduced during the next session.

REAL ESTATE AND HOUSING

The Westchester County Association remains focused on statewide solutions to address local zoning and land use barriers to building the housing we need.  The Hudson Valley remains in the midst of a housing crisis which will impact the long-term health of the regional economy.  Despite the need to address our housing shortage rising to the top of the State’s legislative agenda over the past several years, no meaningful reform has yet materialized.

A new report entitled “Building Growth” published jointly by the WCA and the Regional Plan Association provided fresh research and data on the state of the housing shortage in Westchester.  This research concluded that despite recent progress, the supply of new housing units has not kept pace with demand — resulting in historically low vacancy rates and spiraling rents.  If Westchester does not increase efforts to address its housing gap, it could cost the county over a half a billion dollars in annual wages and over $50 billion in economic growth.  Learn more here:  Report: Building Growth

The economic, social, and environmental costs of inadequate housing transcend local boundaries and affect the entire region.  Although we share this issue with other states in the region, New York stands alone in its inability to marshal statewide solutions.  According to research by the Brookings Institute, NYU’s Furman Center and other leading think tanks, as compared to its peer states, only New York lacks the statutory tools to promote land-use reform and housing production in its suburban communities.  While there has been some recent progress, decades of experience with a piecemeal, jurisdictional approach to the housing crisis has failed to yield the necessary results and we need a statewide fix.

Support Statewide Housing Reform

Create a Reasonable and Predictive SEQRA Process for High-Value Housing Projects

The State Environmental Quality Review Act (SEQRA) is creating costly and unjustifiable delays in the development of new housing.  The law’s noble underpinnings are designed to protect the environment by avoiding hasty decision-making.  But SEQRA has become weaponized by overuse and has morphed into a procedural quicksand of delay.  Reform it by creating fast-track consideration for certain classes of development – e.g., housing with a certain level of affordability, housing with certain policy benefits like passive house construction or other climate mitigation features, or housing in a particular valuable zone for redevelopment as part of a Downtown Revitalization Initiative grant.  Environmental review is the most time-consuming and costly phase of the land use decision-making process.  It is also unpredictable and unevenly applied across local jurisdictions.

The WCA supports a streamlined local zoning and land use approval process subject to strict deadlines for qualifying housing developments.  Local land use decisions should remain with local governments.  However, the state retains the power to set the terms and standards for local review and it should exercise that power to advance statewide goals.  Some specific suggestions for SEQRA application:

• Classify high-value “infill housing” sites as Type 2, thereby limiting them from full scale environmental review.
• Create a streamlined process for projects which meet clear and objective planning standards.  Establish a tiered but finite timeline for the municipal application review process depending on whether the review is short-form or long-form and the size of the development.  Extensions can be accommodated presuming they are supported by reasonable circumstances with a specific and clear path for process conclusion.
• Reduce the number of topics to review outside of those with direct environmental impacts.
• Increase size threshold triggering environmental review.
• Exemptions for projects with clear environmental impacts and unlikely to have adverse impacts.
• Support an appeals process for zoning changes rejected by local governments.
• Support “vested rights” reform to prevent zoning changes from negatively impacting developments in process.

Prior bills that partially take this approach:

A.6283A (Kelles) / S.3492 (May) provides that housing and infill projects where the applicants have been certified by an expert that they do not violate state environmental laws, meet an affordability threshold, and where the application receives certification for sustainable construction techniques, should either have a limited SEQRA review or be deemed exempt from SEQRA.  Last year, this legislation passed the Senate but did not proceed out of committee in the Assembly.

A.1492 (Kelles) / S.4058 (May) provides that qualifying projects, with a substantial percentage of low – and moderate-income housing, shall receive an up-or-down decision within 40 days of the end of a public hearing on the project and enumerates a concrete list of factors that would justify a no vote.

In addition, the WCA supports the Governor’s administrative efforts to streamline process at the NY State Department of Environmental Conservation to address the need for additional housing.

Other Examples Include:

California’s 2025 CEQR SB 131/AB130 legislative reforms streamlined or exempted new project categories from CEQR review and reduced litigation risks across the state.  These reforms mark a bold shift in California’s approach to balancing environmental review with the urgent need for expanded housing, infrastructure, and climate resilience.  Learn more here:  Newsom CEQR.

Massachusetts 2025 MEPA Regulations provides expedited review for residential construction that meets certain criteria for density, pre-existing infrastructure, and consistency with comprehensive plans.

Pursue Transit Oriented Development Which Maintains Local Decision-Making Authority

While recent transit-oriented development (“TOD”) proposals created a firestorm, the concept does need to be pursued as one of the most high-value ways of increasing housing stock.  Increasing housing capacity near public transit hubs and commercial corridors is low-hanging fruit.  However, there are approaches that would yield better results and less opposition to the blunt circle-drawing as-of-right zones envisioned by the failed Housing Compact.  Local authorities can retain discretion to establish their own solutions so long as they commit to take action.

Examples Include:

Massachusetts Transit-Oriented Development law (Sec. 3A of MGL 40A) requires the 170 MBTA communities to submit a plan for an as-of-right TOD density zone within half a mile of transit stations but allows the local community to pick the zone so long as it is “of reasonable size” rather than hold the entire radius of land to a prescribed density.  Local governments retain the authority to undertake their own zoning decisions.

New Jersey’s Transit Village Initiative represents another approach.  This incentive-only, multi-agency Smart Growth partnership creates incentives for municipalities who meet certain Transit Village Criteria and complete a Transit Village Application.  Those so designated receive technical assistance and priority consideration for grant funding by the state agencies that make up the Transit Village Task Force.

Require Communities to Create a Local Housing Action Plan

The oft-expressed virtue of local control is that those closest to the community have the best sense of local needs and can plan accordingly.  Unfortunately, only a handful of Westchester communities have wrestled with the housing needs in their community and the region with thoughtful planning.  Many have comprehensive plans that are decades out of date or barely mention housing.  Generic Environmental Impact Studies are rare. Most housing applications are still considered as one-offs rather than as part of a local plan to address the severe needs for housing while also factoring in infrastructure concerns, available lands, the redevelopment of underutilized buildings, and the specific needs of that community in terms of income levels, housing costs, and at-risk communities.  Similarly, each community need not use the same tools and strategies.

As with the 2020 executive order requiring each local government in New York State to adopt a policing reform plan, each community should be required to produce a local housing plan reflecting the needs of the community and local factors established through a preponderance of evidence, rather than the particular concerns of a small number of individuals at a single public hearing.

Prior bills that partially take this approach:

A.2017 (Thiele) requires local governments to prepare and adopt an affordable housing plan with public input and update it every five years.   Unfortunately, the current version of the bill includes a “character of community,” element which is both vague and also has a negative history of misuse.

Strongly Incentivize Comprehensive Plans Which Contain a Robust Housing Element

Ideally, a local housing plan would be accompanied by a comprehensive plan for a holistic look at the community. This is a large endeavor, however, and many municipalities lack funding, bandwidth, or expertise to run the whole process.  The state should take a leading role with incentives so that more municipalities can employ any of the following options:

1. Funding for adopting comprehensive plan component that furthers one or more housing types that meet local market, social, and environmental needs.
2. Amended SEQRA rule declaring these housing types receive presumptively negative declarations.
3. Create a class of sustainable development projects that are eligible for administrative review and approval and waiver of land use regulations.
4. Provide infrastructure funding to support sustainable development projects.
5. Enhance set asides of LIHTC and other affordable housing funding.
6. Incentivize housing development through increased eligibility for real property tax abatement, more AIM funding, school funding, and bonus consideration for other relevant state funds.

Utilize Infrastructure and Other Funding to Incentivize Housing

Sufficient funding for infrastructure improvement grants tied to measurable progress in addressing the statewide housing shortage is a fundamental building block for progress, and a must in the next year’s state budget.  We also recommend additional financial support for municipalities who can demonstrate that they are addressing housing, including:

• Grants for the process to update a municipality’s comprehensive plans.
• Incentive funding to cover the costs of a Generic Environmental Impact Statement (GEIS) for communities that have created a housing growth overlay zone or other rezoning to support increased multifamily.
• Adding an annual bonus to Aid in Municipality (AIM) funding tied specifically to achieving pro-housing actions or bringing new housing online.
• Creating additional points or AIM bonuses for achieving key pro-housing milestones, like completing a comprehensive plan update, or achieving a threshold of new units open for sale/rental in a calendar year, with increased weight for affordable units.

Strengthen the Pro-Housing Communities Program

The State’s Pro-Housing Communities Program limits eligibility for certain discretionary funding grants to local governments that take action to support housing growth.  Eligible grant programs include numerous programs which apply directly to Westchester and the Mid-Huson region such as the Downtown Revitalization Initiative, the Mid-Hudson Momentum Fund, and the NY Main Street Fund.  As of writing, 17 Westchester communities had qualified as Pro-Housing and 20 additional communities had started the process of becoming certified.

The WCA advocates for expanding the Pro-Housing Communities Program to act as an umbrella certification for a broader array of funding, especially programs designed to address infrastructure capacity issues and technical support needs.  In addition, the funding streams should allow for additional flexibility to permit an array of uses related to housing supply.  The WCA further advocates for an enforcement mechanism to ensure that discretionary funds under the Program actually lead to new housing supply.

Create An Enforcement Mechanism

The WCA supports legislation establishing a state-level appeals procedure with the authority to review decisions on qualified low-or-moderate income housing applications when found to be unreasonable and not consistent with local needs.  Local decision-making should be retained but must be held accountable when not supported by objective standards and empirical facts.

Examples include:

A.1492 (Kelles) / S.4058 (May) — Creates a state zoning board of appeals to consider applications for low or moderate-income housing development that may have been wrongly rejected at the local level.

The New Jersey Mt. Laurel Doctrine — Sets a “Fair Share” percentage goal of housing that must be affordable in each town, and allows for enforcement if towns fail to comply with their fair share obligations, including compliance challenges in court.

Chapter 40B in Massachusetts (a.k.a. “the Builder’s Remedy”) – Sets a fixed percentage of housing units that must be affordable for each municipality.  If the municipality is under that goal, and if it has rejected an application for housing, the applicant can appeal that decision to a State Zoning Board of Appeals.  If it is empirically determined that the municipality is under its goal, the rejection can be overruled.

Connecticut CGS 8-30g – Creates a housing appeals procedure similar to Massachusetts 40B and places a reasonableness burden on local boards that deny proposals for affordable housing developments.  TTL8$$30GU (ct.gov).

OPPOSE PREVAILING WAGE LEGISLATION

The WCA opposes efforts to expand prevailing wage legislation which acts as an impediment to developments addressing our housing shortage.  At a time when federal policy is injecting uncertainty and inflationary pressure on the construction industry, such legislation is poorly timed and damaging to the economy.  Moreover, recent efforts to apply prevailing wage in New York City pursuant to newly enacted housing incentives illustrate its damaging impact on new developments.

REPEAL THE SCAFFOLDING LAW

New York’s Scaffold Law (Labor Law 240) is an outdated vestige of a bygone era.  The law employs an absolute liability standard holding property owners and contractors fully responsible for gravity-related injuries, even when workers are partly at fault.  It inflates construction costs, drives up insurance premiums, and discourages investment in housing and infrastructure projects.  New York is the only state to enforce such as strict standard.

SUPPORT THE WELCOME HOME WESTCHESTER “5 IN 25” LOCAL HOUSING AGENDA

In addition to focusing closely on state-level solutions, the WCA also steers the Welcome Home Westchester campaign and its “5 in 25” agenda.  This agenda is tailored towards local municipalities and sets forth five voluntary steps that every village, town, and city in Westchester can take to help address the housing crisis as follows:

• Produce a Housing Action Plan that is specific to local needs and considers unique conditions and characteristics;
• Create Fast Track Environmental Review for sustainable, energy efficient housing and transit oriented development;
• Promote Accessory Dwelling Units and Transit Oriented Development by passing ordinances encouraging such developments;
• Establish a “Core Training Curriculum” for volunteer land use board members to help them understand the housing crisis and how their decisions can impact the issue; and
• Become a Pro-Housing Community pursuant to the State’s Pro-Housing Communities Program.

ENERGY AND SUSTAINABILITY

With the passage of the Climate Leadership and Community Protection Act (CLCPA) in 2019, New York has embarked on an ambitious state-level effort to address climate change.  The state’s Climate Action Council’s scoping plan followed passage and provided a strategic plan on how to meet the CLCPA’s emissions reduction targets.

Over the ensuing years, progress has been slowed by economic headwinds, infrastructure challenges, and regulatory uncertainty.  This past summer, the New York State Independent Systems Operator (NYISO) issued an interim report detailing the continuing challenges in meeting anticipated growth in energy demand and concluding that, on our current trajectory, the state’s electric grid is headed towards reliability problems.  Read more here:  NYISO Press Release

Meanwhile, energy costs continue to increase, the WCA continues to support the Climate Act’s underlying premise and its ultimate goal to transition to a carbon-free economy by 2050.  The WCA focuses on balancing climate ambition with the practical realities of grid capacity, housing affordability, commercial development, and fiscal impacts.  We advocate for clear regulatory frameworks and agency accountability to ensure that state climate goals are implemented efficiently and effectively.  We further advocate for coordinated planning with regional stakeholders so that New York’s transition to a low-carbon economy is orderly, financially attainable, and supports both economic growth and community resilience.

Provide a Rational Approach to Building Electrification Coupled with State and Federal Funding Mechanisms

The WCA supports adjustment to the implementation timeline of the All-Electric Buildings Act.  Further, the WCA opposes an accelerated fossil fuel phase out for existing buildings absent major funding mechanisms and technical assistance programs tied to the increased costs of construction or conversion.

Passage of the All-Electric Buildings Act requires most newly constructed buildings in New York to be built with electric heat and appliances beginning in 2026 for smaller buildings and 2029 for larger buildings.  The law’s intent is consistent with meeting the State’s climate mandates under the CLCPA and advancing decarbonization in the building sector.  At the same time, we must acknowledge significant reliability challenges recently identified by the New York Independent System Operator (NYISO).

WCA advocates for a carefully managed transition, as the current timeline for new building electrification will create cost pressures and supply constraints that threaten housing affordability and project feasibility. Furthermore, converting buildings to net-zero or all-electric will be very expensive.  Estimates show commercial retrofits could cost over 45 dollars per square foot, with even higher costs for older or larger buildings.  Many projects in Westchester would not offer reasonable payback, and residential buildings, especially co-ops and condos, could face severe financial strain.  Lower property values in the region make these challenges even more significant.

A sequenced and strategic transition, accompanied by clear infrastructure planning and financial support, reflects the practical considerations raised by developers, real estate professionals, and other regional stakeholders. Particularly with respect to energy reliability concerns, the pace of decarbonization will depend as much on the speed at which the built environment can physically transition from fossil fuels as on the timeline for developing new sources of supply.

Accelerate Large Scale Renewable Energy Projects

The WCA strongly supports continuing statewide efforts to streamline large-scale renewable energy infrastructure projects (production and transmission) through the Public Service Commission and the Office of Renewable Energy Siting.  Moreover, the state must be flexible in managing its contractual arrangements with large scale developers where macro-economic issues, such as inflation or supply chain demands, challenge project viability.  Public private partnerships such as those advanced by Westchester-based New York Power Authority are critical to advancing our energy goals, cutting emissions of carbon and other criteria pollutants, and spurring job creation.

The State must accelerate passage of new regulations for siting large-scale renewable energy projects through the Office of Renewable Energy Siting as required by the Accelerated Renewable Energy Growth and Community Benefits Act.

In addition, the State should extend credits and other incentives for distributed generation through the NY-Sun program, with a focus on the mid-Hudson and downstate markets.

Support for “Cap and Invest”

The WCA supports a trading mechanism which will improve the efficiency of any cap and invest program, which is sensitive to the concerns of disadvantaged communities, and which mitigates increased costs to low- and moderate-income households.  The Department of Environmental Conservation proposal under Part 253 for mandatory GHG reporting is a positive step toward establishing the data backbone needed for the Cap and Invest program.  However, the core rules under 6 NYCRR Part 252 regarding allowance allocation, auction design, compliance timing and cost containment are still under development and lack final definitions.  The State must clearly define emissions measurement boundaries, establish cost mechanisms (including support for small and medium businesses in the region), and ensure that the burden on regional employers and households is minimized before any allowance obligations are imposed.

Fix the CLCPA’s Accounting Methodology

The WCA supports efforts to align the State’s GHG emissions accounting system with federal standards consistent with the Intergovernmental Panel on Climate Change.

The accounting methodology employed by the CLCPA for measuring greenhouse gas emissions reductions is an outlier amongst other states which have undertaken similar measures and also within the international community. Without a legislative fix, it will hurt New York businesses and consumers by placing the State at a competitive disadvantage. In addition, inconsistencies with other similar programs will severely complicate a regional approach to meeting New York’s emissions reduction goals and will hinder available federal funding from reaching the State. Recent legislation advancing this goal includes S2471 (Parker).

Local Land Use Restrictions Which Hinder Clean Energy Siting Must Be Overcome

As with housing, local land use and zoning restrictions often impede the development of small-scale renewables and smart building technologies.  The Climate Action Council’s Scoping Plan identifies the need to address local land use restrictions and clean energy siting as one of its goals primarily through public outreach and education.  Recent experience in the housing context foreshadows the need for a cohesive statewide approach and a stronger, more proactive legislative hand.  This will take a combination of mandates and incentives.  Local moratoria and blanket renewable energy bans should be rejected.

Moreover, just as with the dedicated ORES to streamline and expedite the siting of renewable energy supply, New York will require SEQRA workarounds and statewide zoning requirements to create more environmentally favorable projects such as transit-oriented development (“TOD”), multi-family development, and utility scale solar, wind, battery storage and geothermal projects.

Ensure Adequate Funding for Public Transportation

A robust and well-functioning mass transit system linking New York City to the suburbs is integral in reducing carbon emissions caused by transportation.  The State must continue to invest in the Metropolitan Transit Authority’s capital projects and ensure that dedicated transit funds are not diverted to other uses.

Put the Environmental Bond Act and Similar Programs to Work

WCA calls for the rapid deployment of the $4.2 billion authorized under the Environmental Bond Act, prioritizing projects that directly benefit Westchester County, including water infrastructure upgrades, flood resilience, green stormwater systems, and emissions-reduction initiatives.

The slow pace of distribution, driven by complex applications, coordination challenges among state agencies, and delayed grant approvals, has limited timely access to these resources.  The WCA urges the State to align Bond Act funding with existing programs such as the Climate Smart Communities initiative, which provides technical and financial assistance to municipalities pursuing climate adaptation and resilience goals.

WCA also supports full utilization of the Brownfield Cleanup Program and the Brownfield Opportunity Area Program to revitalize underutilized or contaminated sites and promote equitable economic development. We advocate for maintaining tax incentives for smaller developers and local businesses, expanding pre-development funding, and ensuring municipalities receive the support they need throughout the cleanup and redevelopment process.

By coordinating Bond Act investments, brownfield redevelopment, and Climate Smart Communities initiatives, New York can implement a unified strategy that strengthens environmental resilience, supports housing and commercial revitalization, and drives sustainable economic growth across Westchester and the Hudson Valley.

BROADBAND AND DIGITAL CONNECTIVITY

Westchester County’s Office of Economic Development recently released a strategic report concluding that “the digital divide…is a key hurdle in economic development” (Westchester Economic Development Strategy, Recovery & Implementation Plan, Dec 2020).  Moreover, a recent NY State comptroller’s report illustrates both that there is an overweighted need for broadband infrastructure and connectivity in the mid-Hudson region and that this region is not seeing our share of state grant funding. See  https://www.osc.state.ny.us/reports/availability-access-and-affordability-understanding-broadband-challenges-new-york-state

U.S. Census Bureau data identifies 40,000 households in Westchester County without an internet subscription.  Further, these households are strongly concentrated in impoverished and/or minority neighborhoods.  This same data shows a gap in device ownership, or reliance on smartphones only, affecting 20,000 households.

The Westchester County Association supports both a light-touch regulatory environment that encourages the rapid deployment of broadband infrastructure as well as robust programs enhancing digital equity.  Moreover, the WCA opposes legislation designed to create unnecessary and artificial barriers to business for internet service providers.

Leverage Funding by Streamline Regulation and Broadband Construction

The WCA advocates for pro-broadband state legislation including streamlining permitting of fiber and wireless projects and/or municipal implementation of pro-broadband policies.  Layers of duplicative regulations add unnecessary expense to infrastructure build-out.  The WCA further opposes the dissemination or amplification of scientifically bogus theories concerning the health impacts of mobile infrastructure which would delay the implementation of 5G technology.

Eliminate Unnecessary and Duplicative Restrictions for Broadband Infrastructure Builds

The WCA supports legislation to repeal the DOT survey law such as A.1282 (Paulin).  In recent years, the State has taken several actions which have caused a significant backlog in the deployment of fiber-optic facilities throughout New York State and, as such, have delayed the availability of broadband services to many New York residents and businesses. In 2019, New York became the first state in the nation to charge fees on fiber cables used for broadband deployment when the fiber is placed on state highway rights-of-way.  This fee has since been repealed.

However, in 2020, the DOT added a new requirement to the expanded consolidated permit application for the deployment of fiber used for broadband deployment. Specifically, this new application requires an applicant to provide certified engineering surveys for all infrastructure (both the applicant’s infrastructure and third-party infrastructure) located in the State’s own rights-of-way (ROW) — even when the applicant proposes to install or modify facilities on infrastructure that already exists in the rights-of-way. This unnecessary, costly, and burdensome step adds significant expense and time to the deployment process and there is no reasonable or rational need for such a survey in this circumstance.  A better solution is to eliminate all requirements for certified surveys as New York seeks to invest billions towards broadband builds across the State to close the digital divide and to catapult New York toward the top of the list of the states that lead the technology curve.

The WCA opposes the Pole Attachment Safety and Accountability Act (S.6997A / A.7544A) and has urged Veto.  This legislation, though well-intentioned, risks upending the coordinated, evidence-based approach New York has been building to expand broadband access — and may ultimately delay the very infrastructure improvements it seeks to support. Instead of reinforcing the PSC’s oversight framework, this bill creates a duplicative enforcement system with rigid timelines, steep penalties, and unfunded mandates for local governments. For already overextended municipalities, the added administrative burden risks slowing or halting broadband projects. This is significant step backwards just as the state has been making progress in closing the digital divide.  In addition, the bill’s stop-work orders and funding disqualification provisions are especially concerning. They could disrupt active projects serving hospitals, schools, and emergency responders — delaying access in the very communities that need it most.  In the last few days of the year the Governor decided to sign and enact the bill into law.

Support For Digital Equity Initiatives

The WCA remains at the forefront of innovative projects designed to connect underserved populations to the digital economy.  It’s Y-Zone digital opportunity zone in Yonkers, N.Y. – now expanded into Connect Westchester —  brings a direct physical presence to the community for digital navigator assistance to enable households to source free or low-cost internet from existing broadband providers and fund new devices and critical tech education.  This creates economic opportunities through workforce training and job development, healthcare access, financial literacy, and connection to on-line resources.

We advocate for the expansion of statewide programs such as the Statewide Digital Equity Plan to support use of the internet.  Both the State’s ConnectAll office, and federal dollars received by the State through the National Telecommunications and Information Administration (NTIA)  should fund proven programs such as Connect Westchester that enhance access to broadband and not just infrastructure deployment.  The State’s digital equity focus must include utilization outcomes as opposed to simply physical buildout.

Support Renewed Funding for the Federal Affordable Connectivity Program

New York must support refunding the ACP through legislation such as this year’s Federal ACP Extension Act.  The Affordable Connectivity Program (ACP) was established pursuant to the bipartisan Federal Infrastructure law of 2021 to make high-speed internet access more affordable.  Prior to expiration, it assisted over 40,000 households in Westchester County with a $30 monthly discounted internet bill.  The ACP’s wind-down jeopardizes New York’s taxpayer-funded broadband investment and digital equity plans.